The U.S. Court of Appeals for the Eleventh Circuit affirmed a Federal Trade Commission enforcement victory against payment technology company Corpay, Inc. and its CEO Ronald Clarke, ruling that the company's fuel credit card marketing constituted deceptive business practices.

In an opinion filed Jan. 6, 2026, Circuit Judge Robin Rosenbaum colorfully described Corpay's business model, writing that the FTC found the company to be 'all hat and no cowboy' - meaning 'all talk and no substance, or something looks much better than it really is.' The three-judge panel, which also included Circuit Judges Barbara Lagoa and Britt Grant Wilson, upheld the district court's summary judgment ruling in favor of the FTC.

The case centers on Corpay's marketing of fuel credit cards to large and small businesses. According to the court's opinion, Corpay promoted these cards as offering 'savings, control, and transparency' to customers. However, the FTC's investigation revealed a different reality beneath the company's marketing promises.

'When the FTC looked under the hat, it found no cowboy,' Judge Rosenbaum wrote in the opinion. 'Beneath Corpay's promises of big savings, the FTC alleged, stood hidden charges, misleading practices, and broken commitments.'

The enforcement action originated in the U.S. District Court for the Northern District of Georgia, where the case was docketed as Federal Trade Commission v. Corpay, Inc. The district court granted summary judgment for the FTC against both Corpay and Clarke, finding that the defendants had engaged in deceptive practices in violation of federal consumer protection laws.

Following the summary judgment ruling, the district court entered permanent injunctive relief against Corpay. The injunction includes specific requirements designed to prevent future deceptive practices and ensure greater transparency in the company's business operations.

According to the court documents, the permanent injunction prohibits Corpay from putting fee disclosures behind hyperlinks, a practice that allegedly made it difficult for customers to understand the true costs of the company's services. The injunction also requires Corpay to make fee disclosures 'unavoidable' for customers, ensuring that important pricing information cannot be hidden or easily overlooked.

The case represents a significant enforcement victory for the FTC in its ongoing efforts to combat deceptive business practices in the financial services sector. Fuel credit cards have become an important business tool for companies seeking to manage fleet expenses and track fuel purchases, making transparency in pricing and terms particularly important for business customers.

Corporate payment solutions have grown increasingly complex in recent years, with companies like Corpay offering integrated platforms that combine credit services, expense management, and reporting tools. However, this complexity can sometimes make it difficult for customers to understand the true costs and terms of these services, creating opportunities for deceptive practices.

The Eleventh Circuit's decision affirms the district court's finding that Corpay's marketing practices violated federal consumer protection standards. The appellate court's colorful language in describing Corpay's business model reflects the strength of the evidence presented by the FTC in demonstrating the gap between the company's marketing promises and the reality of its services.

Ronald Clarke, who served as Corpay's CEO during the period covered by the FTC's enforcement action, was named as an individual defendant in the case. The inclusion of corporate executives as individual defendants in FTC enforcement actions reflects the agency's strategy of holding corporate leaders personally accountable for deceptive business practices.

The case began in 2019 when the FTC filed its initial complaint in the Northern District of Georgia. The matter proceeded through discovery and motion practice before the district court granted summary judgment in favor of the FTC, finding that the evidence clearly established violations of federal consumer protection laws.

Corpay and Clarke appealed the district court's ruling to the Eleventh Circuit, arguing that the lower court had erred in its legal analysis and factual findings. However, the appellate court rejected these arguments and affirmed the district court's decision in its entirety.

The permanent injunction against Corpay will remain in effect indefinitely, requiring the company to maintain the transparency and disclosure practices mandated by the court. The FTC will monitor Corpay's compliance with these requirements and can seek additional enforcement action if the company fails to meet its obligations under the injunction.

This case demonstrates the FTC's continued focus on ensuring transparency in business-to-business financial services, particularly in sectors where complex pricing structures and technical jargon can obscure the true costs of services. The decision also reinforces the importance of clear, prominent disclosure of fees and terms in marketing materials and customer agreements.