FTC Sues GovAssist and Entry Over Alleged Passport Impersonation Ads

FTC Sues GovAssist and Entry Over Alleged Passport Impersonation Ads

The Federal Trade Commission sued GovAssist LLC, Entry LLC and Scott Zuckerman on October 22, 2026 in the District of Puerto Rico, alleging their paid Google ads and passport application sites posed as the federal government. Every statement in the complaint is an allegation, and nothing has been decided.

Information last verified on October 24, 2026. This is a developing story; we update it as the record changes.

Status: The FTC filed its complaint on October 22, 2026 in the U.S. District Court for the District of Puerto Rico, FTC v. GovAssist LLC, Entry LLC, and Scott Zuckerman, No. 3:26-cv-01675. There has been no ruling, no answer on the public record and no finding that any defendant did anything unlawful. The FTC's own case page said the matter was "Pending" and listed no document later than the complaint and the October 22 press release when we read it on October 24, 2026. We could not independently check the court docket, because CourtListener refused automated requests from our environment that day, so the only docket activity we can confirm is the filing itself.

Jurisdiction scope: This article addresses a federal civil enforcement action under the FTC Act, one FTC trade regulation rule and one Gramm-Leach-Bliley Act provision, filed in a United States district court. It does not address state consumer-protection claims, criminal charges, any private lawsuit, or passport rules outside the United States. For the broader pattern these allegations fit, see how impersonators borrow agency names, seals and logos.

What Happened

The FTC filed a five-count complaint against GovAssist LLC, Entry LLC and Scott Zuckerman on October 22, 2026 in the U.S. District Court for the District of Puerto Rico. The 31-page filing alleges the defendants operated an impersonation scheme that sold United States passports and passport services by creating the appearance that they were the federal government or were affiliated with it (Compl. 2). It alleges they bought Google search ads that appeared above the State Department website for queries including "apply for a new passport" and "passport renewal online," then routed the clicks to application pages on IVS.us and Entry.com carrying an American flag seal, a summary chart listing the "Issuing Agency" as "U.S. Department of State," and a large blue "Get My Passport" button (Compl. 3, 30, 36). The FTC alleges the defendants collected at least $40,000,000 from over 300,000 consumers in the three years before filing (Compl. 76). None of it has been tested in court.

The corporate defendants are described as a single operation. GovAssist LLC is a Puerto Rico limited liability company that the complaint says now does business at 18 Calle 1, Suite 401, Guaynabo; Entry LLC is a Wyoming limited liability company registered in Sheridan that the complaint says shares GovAssist's San Juan street address and operates from the same Guaynabo office (Compl. 11, 12). Zuckerman is alleged to be the sole member and 100 percent owner of both, a signatory on their bank and merchant accounts, and a resident of the District (Compl. 13). The FTC pleads the two companies as a common enterprise, each liable for the other's acts, and notes Zuckerman represented that GovAssist is a DBA of Entry (Compl. 14). The complaint lists eight websites it says are the defendants': govassist.com, entry.com, ivs.us, quickpassport.com, travelassist.us.com, usvisaconnection.com, tvspassports.com and invitationletter.com (Compl. 17).

The advertising the FTC describes

The complaint's impersonation theory is built on what a searcher sees, not on any single sentence. It alleges the Google ads carried official-looking stock images of passports and American flags, language identical or substantially similar to the State Department's own ("Renew Your Passport Online" appeared in both the IVS.us ad and the State Department's result), links promising "Apply for Passport Online," a badge carrying the abbreviation "IVS" and the URL apply.ivs.us, and an image of a priority mail package showing the GovAssist logo alongside the United States Postal Service logo (Compl. 32). The FTC pleads that "IVS" is reminiscent of "INS," the former Immigration and Naturalization Service, and that in context a URL ending in .us suggested government affiliation (Compl. 32(d)).

The complaint reproduces two dated examples: a September 16, 2026 result set for "get a new passport" that included the line "Get your passport delivered in as little as 3 days," and an October 5, 2026 result for "online passport renewal" promoting apply.entry.com (Compl. 33, 34, 57). It also alleges that since at least April 2026 some of those ads did carry the words "Not a government website," but "in significantly smaller, black font above larger blue eye-catching advertisement text" (Compl. 35). On the landing pages, the FTC alleges the disclaimers sat in page footers, in small font and odd font colors that made them very difficult to read, and that consumers arriving from an ad never saw the parts of the site where disclaimers appeared (Compl. 41).

The complaint also alleges the funnel kept the impression going after payment. A confirmation screen is said to have read "Your passport application has been submitted" at a point when neither the consumer nor the defendants had submitted anything to the State Department (Compl. 45). The FTC alleges the photo tool that followed carried no disclaimer and told users "we need a fresh photo of your face taken now," and that a "My Passport" portal then said the "application has been submitted for processing," that "your passport will be mailed to this address," and that "your passport will be shipped via USPS Priority Mail with tracking" (Compl. 46, 47). Separately, the complaint alleges GovAssist.com listed a K Street address in Washington, D.C. rather than the Puerto Rico operating address (Compl. 39), that the company and domain names themselves leaned on government references, including "Gov" in GovAssist and "Entry" as an echo of U.S. Customs and Border Protection's Global Entry program (Compl. 44), and that the pricing sat very close to the government's, with a $169 tier against a $165 government fee (Compl. 40(c)).

The service promises and the reviews

Counts II and III rest on narrower, checkable claims. The FTC alleges that on April 27, 2026 Entry.com claimed its services started at $89 while its application page priced work from $119 to $499, with the real floor at $119 plus a $29 shipping charge, or $148 (Compl. 53). It alleges the defendants promised delivery in 3-6 weeks, 6-10 business days or 3-4 business days, and that the two faster tiers were false because the fastest service available from the only issuer of U.S. passports is not available through third parties at all (Compl. 56). It alleges checkout estimated 31-49 days including "3-6 weeks government processing," while in some instances the consumer received only application forms 23 days after paying, by which point the State Department's own stated timeline would still have to run (Compl. 61, 62). Upgrade tiers were sold on promises of "faster turnaround, white-glove handling" and "priority queue placement," which the FTC alleges are false because the defendants cannot affect how fast the State Department works (Compl. 58).

"No consumer received a passport from Defendants without taking additional, independent action beyond Defendants' services, such as an in-person appointment, mailing in a prior passport, or submitting an online passport renewal application to the State Department." Compl. 7

On reviews, the complaint alleges Entry.com displayed an "Excellent" Trustpilot rating "Based on 11,000+ reviews" on May 6, 2026, and GovAssist.com a rating based on 6,881 reviews on July 16, 2025 (Compl. 65, 66). It alleges Trustpilot independently identified hundreds of reviews as fabricated using review content, IP addresses, device characteristics and location data, removed them, notified the defendants in May 2025, and that the defendants did not dispute the finding even though they answered other Trustpilot messages (Compl. 67, 68).

Who filed it, and one thing the complaint does not say

The complaint is signed by FTC staff attorneys Iris Micklavzina and K. Michelle Grajales. The Commission's October 22, 2026 press release says the vote authorizing staff to file was 2-0, quotes Bureau of Consumer Protection Director Christopher Mufarrige saying that "Using paid Google search ads and landing pages to impersonate the government and target American travelers is illegal," and states plainly that "The case will be decided by the court."

That press release also says Zuckerman "ran this scheme while under an FTC order in a prior, unrelated case," describing a stalkerware matter that produced a final administrative order on data privacy. The FTC's case page for that matter, In the Matter of Support King, LLC (SpyFone.com), FTC Docket No. C-4756, names "Scott Zuckerman, individually and as an officer of Support King, LLC," carries a Decision and Order dated December 21, 2021, and records a Commission order of December 8, 2025 denying a petition to reopen and vacate or modify it. The GovAssist complaint we read makes no reference to that order, to Support King or to SpyFone anywhere in its 31 pages. That matters for how the two should be read: the prior order is a statement in the Commission's publicity, not a pleaded allegation in this case, and it is not among the five counts the court will decide.

What the Law Actually Says

Three bodies of law carry this complaint, and they operate differently from one another.

Section 5(a) of the FTC Act. The statute declares that "unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce" are unlawful (15 U.S.C. 45(a)(1)). Deception under Section 5(a) is a net-impression test applied to the whole presentation, which is why Counts I through III are pleaded as representations made "directly or indirectly, expressly or by implication" (Compl. 80, 83, 86). Count I is the impersonation theory: that the defendants represented they were a federal agency, or authorized affiliates of the State Department (Compl. 80-82). Count II is the service theory: three-business-day passports, completion with no further steps, and an $89 all-in price (Compl. 83-85). Count III is the review theory: that reviews of the businesses were truthful reviews by actual customers (Compl. 86-88).

The Impersonation Rule, 16 C.F.R. Part 461. This is the newest piece and the reason this case reads differently from a pre-2024 impersonation suit. The rule was promulgated under Section 18 of the FTC Act (15 U.S.C. 57a) and became effective April 1, 2024 (Compl. 89). The eCFR source note for Part 461 gives its Federal Register publication as 89 FR 15030, March 1, 2024. Its two operative prohibitions are short. Section 461.2(a) makes it a violation to "materially and falsely pose as, directly or by implication, a government entity or officer thereof, in or affecting commerce ..." and section 461.2(b) makes it a violation to "materially misrepresent, directly or by implication, affiliation with, including endorsement or sponsorship by, a government entity or officer thereof ..." The definitions in section 461.1 do the heavy lifting: "materially" means "likely to affect a person's choice of, or conduct regarding, goods or services," and "government" includes "federal, state, local, and tribal governments as well as agencies and departments thereof." A parallel section, 461.3, prohibits impersonating a business; the FTC did not charge it here.

What the 2024 rule added is a direct prohibition where previously there was only a general deception theory. Posing as a government entity, or misrepresenting affiliation with one, is now its own violation on the rule's own terms, measured against a defined materiality standard, and Count IV accordingly reaches only conduct "on or after April 1, 2024" (Compl. 94). The complaint also spells out why the FTC pleads the rule alongside Section 5(a): Section 18(d)(3) of the FTC Act deems a rule violation an unfair or deceptive practice under Section 5(a), Section 19(a)(1) lets the Commission sue anyone who "violates any rule . . . respecting unfair or deceptive acts or practices," and Section 19(b) gives the court "jurisdiction to grant such relief as the court finds necessary to redress injury to consumers, including but not limited to rescission or reformation of contracts, the refund of money or return of property" (Compl. 93). The rule count is the route to the refund remedy the FTC asks for.

Section 521 of the Gramm-Leach-Bliley Act. This is the pretexting provision, in force since November 12, 1999 (Compl. 96). Under 15 U.S.C. 6821(a), it is a violation "for any person to obtain or attempt to obtain, or cause to be disclosed or attempt to cause to be disclosed to any person, customer information of a financial institution relating to another person" by "making a false, fictitious, or fraudulent statement or representation to an officer, employee, or agent of a financial institution" or "to a customer of a financial institution." The second route is the one the FTC uses. Count V alleges the defendants made false statements to customers of financial institutions in order to obtain customer information such as bank account and routing numbers, listing the same five representations that anchor Counts I and II (Compl. 99, 100). The statutory definitions of "customer," "customer information of a financial institution" and "financial institution" come from 15 U.S.C. 6827, as the complaint recites (Compl. 97). Enforcement runs an unusual path: Section 522(a) gives the FTC the same powers it has under the Fair Debt Collection Practices Act, FDCPA Section 814(a) treats an FDCPA violation as an FTC Act violation enforceable as if it were a rule violation, and Section 19 again supplies the redress power (Compl. 98).

The prayer for relief asks for a permanent injunction against future violations of all three, for "monetary and other relief within the Court's power to grant, including the rescission or reformation of contracts, the refund of money, or other relief necessary to redress injury to consumers," and for any additional relief the court finds just and proper.

Analysis: Why This Matters

The following is analysis from the Recording Law Editorial Team.

The interesting thing about this filing is not that the FTC says a passport site looked governmental. It is how the complaint is built. The same alleged conduct is charged three separate ways, and each charge demands a different kind of proof. Count I asks what impression the whole presentation created. Count IV asks a narrower question the 2024 rule poses on its own terms, whether the defendants materially posed as a government entity or misrepresented affiliation with one, with "materially" already defined in the regulation as likely to affect a person's choice or conduct. Count V asks whether false statements were used to get at financial account information. A defense that works against one of those framings does not necessarily touch the others.

That is the practical content of the Impersonation Rule, two years into its life. Before April 1, 2024, the FTC had no rule aimed at government impersonation as such, so that conduct was charged as Section 5(a) deception. Since then, as this complaint illustrates, the Commission can plead both, and the rule count is the one the complaint ties to Section 19's redress power, which is what makes refunds part of the ask (Compl. 93). Reading the pleading in that order explains why Count IV is carefully dated to the rule's effective date while the Section 5(a) counts are not.

The disclaimer allegations are the part worth sitting with, because they describe a design problem rather than a missing sentence. The complaint says the words "Not a government website" were present in at least some ads from April 2026 onward, and that the footers said as much on the landing pages (Compl. 35, 41). Its theory is that placement, size, contrast and sequence decided what the ad communicated: small black type above larger blue type, disclaimers placed inconspicuously in page footers, no disclaimer at all on the photo-upload step or the customer portal where the alleged impression peaked (Compl. 41, 46, 47). Whether that proves a material misrepresentation under 16 C.F.R. 461.2 is for the court. What the pleading demonstrates is the standard the Commission is applying: a disclosure is assessed by whether a reader actually takes it in, not by whether it appears somewhere on the page.

One pleading choice stands out by its absence. The alleged fake Trustpilot reviews are charged under Section 5(a) alone, in Count III. The FTC also has a rule aimed squarely at this conduct, the Rule on the Use of Consumer Reviews and Testimonials, 16 C.F.R. Part 465, published at 89 FR 68077 on August 22, 2024, whose section 465.2(b) reaches a business that disseminates a testimonial it "knew or should have known" misrepresented that the reviewer exists or used the service. The complaint does not charge Part 465. We are not going to guess why, and the reason may be as mundane as the timing of the conduct the FTC can prove. It is simply worth noting that the Commission reached for one 2024 rule here and not the other.

Finally, the channel. The complaint's account of the harm does not depend on a forged seal or a spoofed domain; it depends on position. The allegation is that an ad bought against the query sat above the agency's own result, and that the position itself carried meaning: the search results "shape consumers' net impression that Defendants are the government and frame consumers' interactions with Defendants going forward" (Compl. 3, 30). Government impersonation is an old category, and the FTC's own reporting has tracked its cost to consumers, including in its 2026 accounting of fraud losses among older adults. What is newer is the claim that an auction for a keyword is where the impersonation happens.

How to Tell the Official Passport Site From a Paid Ad

This section is general information about how the official process works, not advice about anyone's own application or payment.

One agency issues passports. Under 22 U.S.C. 211a the Secretary of State may grant and issue passports, and "no other person shall grant, issue, or verify such passports." No private company can issue one. On speed, the complaint reports the State Department's own advice that using a registered courier company will not get an applicant a passport faster than applying directly (Compl. 27).

A first passport means showing up in person. USAGov, the General Services Administration's official guide to federal services, states that "You must apply in person at a passport acceptance facility for a new passport. It cannot be done online or by mail" (read October 24, 2026). An online form that promises to finish a first-time application end to end is describing something the process does not allow.

Renewal online happens in one place. USAGov states that "The State Department offers the only authorized place to renew your passport online," and links to the State Department's own online renewal system. The complaint identifies that system as opr.travel.state.gov and alleges the State Department warns consumers that a company is not authorized to accept or process online renewals even if it has "Gov" in its name, and that they should check for a site ending in .gov rather than .com, .us or .org (Compl. 26). There is a structural reason no third party can file an online renewal for you: the application requires an electronic signature and a self-submission attestation, so the State Department permits applicants to sign and submit only on their own behalf (Compl. 25).

The fees are set by regulation, so they are checkable. The current Schedule of Fees for Consular Services at 22 C.F.R. 22.1, which we read on October 24, 2026, lists a $35 "Passport Book or Card Execution" fee "required for first-time applicants and others who must apply in person," $50 for "Passport Book Application Services" for applicants age 16 or over including renewals, $20 for applicants under 16, an $80 passport book security surcharge, and $60 for expedited service. The application-side charges for an adult book therefore come to $130, and $165 once the in-person execution fee applies, which is exactly the figure the complaint gives for the official route (Compl. 23). For an applicant under 16 the schedule adds to $100, or $135 with execution.

Expedited is a government service with a government price. The $60 expedite fee appears in the same schedule. Under 22 C.F.R. 51.56(b), expedited passport processing means "completing processing within the number of business days published on the Department's Web site," counted from when the application reaches a Passport Agency, and section 51.56(c) says the fee "does not cover any costs of mailing above the normal level of service ...", which the applicant pays separately. Faster government service does exist, but it comes from the agency, not a vendor. The State Department's own options, as the complaint describes them, run in four tiers: life-or-death emergency appointments for travel inside 14 days, urgent appointments for travel inside two to three weeks, expedited service for travel inside six weeks, and routine service beyond that (Compl. 24, 40(b)). The complaint alleges the fastest of those is a 14-day delivery available only in particular circumstances and not available through third parties at all (Compl. 56).

On processing times, a candid note. We could not read travel.state.gov on October 24, 2026; every request from our environment was refused with an HTTP 403 by the site's bot protection, and the regulation deliberately points to that page rather than fixing a number. So we are not going to publish a current figure. What we can report is what the FTC's complaint describes the State Department's site as showing, including a September 29, 2026 screenshot of the department's own "how to get a passport faster" page (Compl. 40(b)): routine service of four to six weeks of processing, plus up to two weeks for the application to reach the department and up to two weeks for mailing back, which the complaint summarizes as a routine process typically taking eight to ten weeks (Compl. 23), and expedited service of two to three weeks not including mailing (Compl. 24, 40(b)). Those are the FTC's figures as of that date, not ours as of today. Anyone who needs the live number should read it on the State Department's own page.

Couriers exist, and they are limited. Private firms can register with the State Department as courier companies, which lets them submit applications and pick up passports for customers. Even then, the complaint alleges the State Department does not permit third-party couriers to submit online applications, and advises that using a courier will not get a passport faster than applying directly (Compl. 27). The FTC alleges these defendants were not registered couriers and were not affiliated with the department in any way (Compl. 28).

A sponsored result is bought, not ranked. The slot at the top of a search page labeled as an ad is sold by auction. It carries no vetting of the advertiser's authority and no relationship to the official source, and the agency's own page can sit below it. The pattern the complaint describes is adjacency rather than forgery: a name that borrows a government word, a top-level domain that reads official, an acronym that resembles a defunct agency's, a price a few dollars off the statutory one. The same pattern shows up across the category we cover in our guide to scams and fraud. When something that looked official turns out not to be, which agency takes which kind of report and what the rules are for reversing a charge by payment method are the two general questions that follow, and both depend on facts specific to the transaction.

What Happens Next

The case is at its earliest stage. A complaint has been filed and docketed in the District of Puerto Rico; the defendants have not yet answered on the public record, no schedule has been reported, and no court has evaluated any allegation. The FTC's own statement is that "The case will be decided by the court."

Three things are worth watching, stated as what the record will show rather than as forecasts. First, whether the defendants respond to the merits of the rule count separately from the Section 5(a) counts, since Count IV turns on the rule's own materiality definition and reaches only post-April 2024 conduct. Second, what the FTC asks for by way of interim relief, since the prayer seeks a permanent injunction and monetary redress including rescission and refunds. Third, whether the Commission's statement about the prior Support King order surfaces in this litigation at all, given that the complaint we read does not plead it.

As of October 24, 2026 the FTC's case page lists only the complaint and the press release, both dated October 22, 2026, and we could not reach CourtListener to check the docket independently. We will update this page as the docket moves.

This is general legal information, not legal advice. It describes a federal civil complaint filed in the U.S. District Court for the District of Puerto Rico on October 22, 2026, together with the statutes and regulations that complaint invokes, verified against FTC, eCFR, govinfo and USAGov sources on October 24, 2026. Every accusation described here is an allegation that remains unproven, and no defendant has been found liable. Laws change, this story is developing, and nothing here is advice about any particular application, charge or dispute. Anyone who needs to know how these rules apply to their own situation should consult a lawyer licensed in their jurisdiction.

Related articles

• How government impersonation scams use agency names and seals
• What to do after a scam, and what the law lets you recover
• Where to report a scam, and which agency handles it
• Getting money back after a scam, by payment method
• Fake invoices and tech-support scare screens
• The FTC's 2026 report on fraud losses among older adults

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Last updated: 2026-10-24. This is a developing story; details verified as of 2026-10-24.

Frequently Asked Questions

Has a court found that GovAssist impersonated the government?

No. The FTC filed a complaint on October 22, 2026 in the U.S. District Court for the District of Puerto Rico, No. 3:26-cv-01675. A complaint sets out what a plaintiff alleges and must prove. As of October 24, 2026 there has been no ruling and no finding of liability against GovAssist LLC, Entry LLC or Scott Zuckerman, and the FTC's own release says the case will be decided by the court.

What is the FTC Impersonation Rule, and when did it take effect?

It is the Trade Regulation Rule on Impersonation of Government and Businesses, codified at 16 C.F.R. Part 461 and published at 89 FR 15030 on March 1, 2024. The complaint states it became effective April 1, 2024. Section 461.2 prohibits materially and falsely posing as a government entity and materially misrepresenting affiliation with one; section 461.1 defines 'materially' as likely to affect a person's choice of, or conduct regarding, goods or services.

Does putting 'Not a government website' in an ad settle the question?

That is one of the contested issues in this case, and no court has resolved it. The FTC alleges such a line appeared in some ads from at least April 2026 but in significantly smaller black font above larger blue advertisement text, and that landing-page disclaimers sat in footers in small, hard-to-read type while the photo step and customer portal carried none at all (Compl. 35, 41, 46, 47). The rule asks whether a material misrepresentation was made, not whether a disclaimer exists somewhere.

Is it unlawful to charge a fee for help with a passport application?

The complaint does not allege that charging for help is itself illegal. It alleges specific misrepresentations: that the defendants posed as or claimed affiliation with the federal government, promised passports in as little as three business days, promised completion with no additional steps, and advertised an $89 price that was not available (Compl. 80, 83). The State Department does register private courier companies, though the complaint alleges it does not let them file online applications and advises that using one is not faster (Compl. 27).

What does the official passport process actually cost?

The Schedule of Fees for Consular Services at 22 C.F.R. 22.1, as we read it on October 24, 2026, sets a $35 execution fee for anyone who must apply in person, $50 in application services for applicants age 16 or over including renewals, $20 for applicants under 16, an $80 passport book security surcharge, and $60 for expedited service. For an adult book that is $130 in application charges, or $165 with the in-person execution fee, which matches the figures the complaint gives (Compl. 23).

Can a company renew my passport online on my behalf?

USAGov states that the State Department offers the only authorized place to renew a passport online. The complaint adds the structural reason: the online renewal application requires an electronic signature and a self-submission attestation, so the State Department permits applicants to sign and submit only on their own behalf, and it does not allow third-party couriers to submit online applications (Compl. 25, 27).

Will consumers get refunds from this lawsuit?

Nothing has been ordered. The FTC's prayer for relief asks the court for a permanent injunction and for monetary and other relief, including rescission or reformation of contracts and the refund of money, and the complaint grounds that request in Section 19 of the FTC Act (Compl. 93, 98). Whether any money is ordered, and on what terms, is for the court.

Was Scott Zuckerman already subject to an FTC order?

The FTC's October 22, 2026 press release says he ran this alleged scheme while under an FTC order in a prior, unrelated stalkerware case. The Commission's case page for that matter, In the Matter of Support King, LLC (SpyFone.com), Docket No. C-4756, names Scott Zuckerman individually and as an officer of Support King, carries a Decision and Order of December 21, 2021, and records a December 8, 2025 order denying a petition to reopen and vacate or modify it. The GovAssist complaint itself does not mention that order.