On the one hand, good on the FTC. Especially for the followup reviews.
On the other hand, this once again proves that it's far easier to just do something contractually and ethically questionable yet massively profitable and wiggle out of the consequences later (especially if you've the money for a squadron of lawyers) than to do things above the board from the get go.
Yeah, better to ask for forgiveness than ask for permission.
Put not your trust in money, but put your money in trust.