Overview

• The stipulated deal combines a $1 billion civil penalty, the FTC’s largest for a rule violation, with $1.5 billion in refunds for an estimated 35 million consumers.
• Refunds are structured for automatic payments within 90 days of the court’s order to low‑use subscribers enrolled through challenged flows, followed by a claims process for others, with payments capped at $51 per person for enrollments between June 23, 2019 and June 23, 2025.
• The order requires a clear “Decline Prime” button, upfront disclosure of costs and auto‑renewal terms, cancellation that is as simple as sign‑up, and oversight by an independent monitor.
• Filings name senior Amazon executives, while the company denies wrongdoing and says the resolution lets it focus on improving customer experiences.
• Tax analysis indicates the $1.5 billion in restitution should be deductible as a business expense, whereas the $1 billion civil penalty is not, with half the penalty due within 14 days of the order and the remainder in 18 months.