A federal judge ruled for the Federal Trade Commission on every count in 2023, an appeals court upheld that ruling in 2026, and in September the company at the center of it agreed to settle the separate administrative case. Corpay, the fuel-card and payments company known in court filings as FleetCor, would pay $100 million to harmed business customers under the deal, and would face a civil penalty of up to $53,088 for each violation of the order in the future.
Two different numbers, two different jobs
The two dollar figures in the FTC’s September 17 announcement do not describe the same money. The $100 million is the redress the FTC says will go to harmed business customers. The $53,088 is a ceiling on what a single future violation of the consent order could cost the company, and it applies only once the order becomes final.
That distinction matters because the figure is easy to misread as a bill. No one is paying $53,088 today. The amount works like a standing price tag on misbehavior that has not happened: if Corpay later breaks the order, each separate violation can be penalized up to that amount.
What the FTC says the fees looked like
According to the FTC’s complaint, as described in the release, the company’s practices fell into four patterns. It allegedly imposed undisclosed charges that added up to hundreds of millions of dollars, billed late fees to customers who paid on time or were blocked from paying on time, held fees back from view for several billing cycles so customers noticed them late, and obscured charges on account reports or left them off entirely.
The agency says tens of thousands of small business customers, the overwhelming majority of the customer base, were on the receiving end. Christopher Mufarrige, Director of the FTC’s Bureau of Consumer Protection, put the agency’s view bluntly: “FleetCor deceived its small business customers by promising fuel savings that never materialized, while unfairly charging them hidden and unauthorized fees.”
Seven years from complaint to consent order
The FTC filed its complaint in federal court in 2019. In 2023 the district court granted summary judgment to the agency on all counts, a ruling that means the judge found no genuine dispute of fact worth sending to a trial. The appeals court upheld that judgment this year and affirmed the permanent injunction against the company.
That court-imposed injunction bars the company from billing without express, informed consent and clear disclosures, from hiding material information about charges behind hyperlinks, and from making deceptive fuel card claims. A court order dated June 8, 2023 remains in place, according to the company’s own statement.
The settlement the FTC announced in September is a separate matter: the administrative action, which carries the consent order and its per-violation penalty. Few corporate enforcement cases arrive at the settlement table with a litigated win, an affirmed appeal and an injunction already behind them, which is what gives the agency unusual leverage here.
What is still pending
The settlement is not final. The FTC says it is subject to a 30-day public comment period that begins after the order is published in the Federal Register, followed by final Commission approval. Only then does the $53,088 penalty structure take effect.
Corpay, for its part, has not admitted wrongdoing. The company says the proposed settlement resolves allegations about marketing and disclosure practices in its U.S. Vehicle Payments business and that it does not expect a material effect on operations or financial results. Chairman and CEO Ron Clarke said in the company’s statement: “We are pleased to resolve this matter and move forward. Corpay is committed to transparent customer disclosures, consent-based practices, and strong compliance controls across our U.S. Vehicle Payments business.” The company’s release also states that its chief executive is not subject to any financial payment under the deal.
How the forward-looking penalty will be judged
Because the penalty attaches to future conduct, it will only become a real number if the FTC alleges and proves a breach after the order is final. The order’s own language about consent, disclosure and hyperlinks is what any later violation would be measured against, and each violation is counted separately.
The FTC’s release is the controlling document for every figure above, including the 2019 filing, the 2023 judgment and the per-violation amount. The agency’s full text, including the order terms, is the place to check the final figure once the comment period ends and the Commission votes.
For households that have already been targeted by a scammer
The Senior Fraud Defense & First-Hour Recovery Kit is written for people who have already been hit by a scam or identity theft and need to know what to do next, in order. It replaces a scramble of phone calls and half-remembered advice with one sequence.
The Senior Fraud Defense & First-Hour Recovery Kit is a 9-page kit that pairs the first-hour recovery plan with a fraud evidence and report log, so each call, account and report is written down as it happens.
Open the first-hour recovery plan and evidence log for a scam that has already happened →
This article was prepared with AI assistance from the FTC’s published release and the company’s public statement. It is news reporting, not legal advice.
Warren Cohen is a finance writer based in Phoenix, Arizona, covering personal finance topics including credit, banking, and beginner investing. He earned his degree in business administration from Arizona State University and began his career working in consumer finance, where he gained direct experience with lending and credit systems. He now writes for personal finance websites and fintech platforms, focusing on clear, practical content that helps readers make informed financial decisions.
