Utah and FTC Secure Proposed Consent Order with Aylo Over Unconscionable and Deceptive Practices

SALT LAKE CITY, Utah — The Utah Department of Commerce’s Division of Consumer Protection (Division), represented by the Office of the Utah Attorney General, and the Federal Trade Commission (FTC) today announced a proposed consent order with Aylo, the company that owns and operates some of the largest and most-visited pornography websites in the world, including Pornhub.com and Redtube.com. This decisive action mandates the implementation of a robust program to remove and prevent child sexual abuse material (CSAM) and non-consensual material (NCM). Additionally, Aylo will pay a penalty of $5 million to resolve claims it engaged in unconscionable and deceptive business practices. Aylo’s websites, including Pornhub.com, attract an enormous global audience. 

The Utah Division of Consumer Protection and the FTC alleged that Aylo allowed videos and photos containing CSAM, or any visual depiction of sexually explicit conduct involving a person under 18 years old, and NCM, such as revenge porn and spy camera videos, to be present on its websites. The particularly egregious violations prompting this action include allegations that:

• Since 2012, Aylo has distributed tens of thousands of videos and photos featuring CSAM and NCM.
• A member of Aylo’s internal compliance team reportedly described Pornhub.com as “a goldmine” for “rape content”.
• Aylo ignored hundreds of thousands of flags—some of which identified content as CSAM and NCM—for years, allowing this content to remain live on its websites.
• Consumers viewed, downloaded, and further distributed this illegal content millions of times, often without knowing it was CSAM or NCM.

These practices were specifically alleged to have violated the Utah Consumer Sales Practices Act (Utah Code § 13-11-1 et seq).

“This consent order is an important step in protecting people from some of the most harmful and exploitative material online,” said Utah Governor Spencer J. Cox. “Companies that profit from such conduct must be held accountable. I’m grateful to the FTC and our Division of Consumer Protection for their work to safeguard Utah’s children and families.”

The harm inflicted upon Utahns and other consumers was substantial due to the widespread distribution of illegal content. Broader concerns about Pornhub have been growing, leading to a petition to shut the site down that has received 2.1 million signatures, a deferred prosecution agreement with the Department of Justice requiring Aylo to pay $1.8 million to the United States, and actions by companies like PayPal to cut services.

“Pornhub’s operators inflicted grave harm on children and nonconsenting adults by promoting and distributing truly horrific material online,” said FTC Commissioner Melissa Holyoak. “As today’s complaint and proposed order make clear, the FTC will use every tool in its arsenal to stop such outrageous conduct.”

Under the terms of the proposed consent order, Aylo must:

• Implement a CSAM and NCM prevention program to prevent the publication or dissemination of CSAM and NCM content, which must include policies, procedures, and technical measures to ensure that such content is not published on its websites and a process to respond to reports about CSAM and NCM content on its websites;
• Implement a system to verify that people who appear in videos or photos on its websites are adults and have provided consent to the sexual conduct, as well as its production and publication;
• Remove content uploaded prior to the implementation of the CSAM and NCM prevention program until Aylo verifies that the individuals participating in those videos were of age and consented to the sexual conduct and its production and publication;
• Post a notice on its website informing users about the FTC’s and Utah’s allegations and the requirements of the proposed order; and
•  Implement a comprehensive privacy and information security program to address the privacy and security issues alleged in the complaint.

To ensure continuous accountability and compliance, an independent third party will conduct audits every two years for the next 10 years. As part of the settlement, Aylo has agreed to pay Utah up to $15 million, with $5 million due immediately and an additional $10 million if Aylo violates the order requirements.

“Aylo has failed to protect children from abuse and exploitation, distributing child sexual abuse material to millions. The victims behind these horrific videos and photos have endured unimaginable abuse at the hands of predators, and Aylo profited from it,” said Utah Attorney General Derek Brown. “Today, we send a clear, unequivocal message: If you profit from child sexual abuse material or any other non-consensual sexual material, you will be held accountable here in Utah. We will be relentless in pursuing justice for these children.”

Margaret Woolley Busse, Executive Director of the Department of Commerce, stated, “Today’s consent order with Aylo marks a pivotal step towards holding accountable those who perpetuate illegal and harmful content online. We cannot stand by while companies allow child sexual abuse material and non-consensual content to thrive on their platforms. The robust measures we impose will enhance all users’ safety and ensure that vulnerable individuals are protected from exploitation.”

The Utah Division of Consumer Protection, led by Director Katherine Hass, sincerely appreciates Douglas Crapo, Stevenson Smith, Carina Wells, and Michael Gadd at the Office of the Utah Attorney General for their dedicated work on this case and for representing the Division.

A press conference will be held at the Utah State Capitol Gold Room on Wednesday, September 3, 2025, at 10:00 am with FTC Commissioner Melissa Holyoak, Attorney General Derek Brown, and Utah Department of Commerce Executive Director Margaret Woolley Busse.

Press are invited to attend in person or via Zoom.

A copy of the complaint, proposed consent order, and the announcement from the FTC are below. 

CONTENT WARNING: This Complaint contains references to, and descriptions of, various sensitive content, including pornographic content, sexually explicit content involving minors, violence, kidnapping, sexual assault, and other non-consensual acts.