We’ll review the ground-up approach for implementing compliance methods for your affiliate program, from setting policies to how-to’s of monitoring and detection. Experience level: Beginner Target audience: Merchants/Advertisers Niche/vertical: Compliance Kellie Stevens, President, AffiliateFairPlay.com (Twitter @KellieAFP)

1. Kellie Stevens
President
AffiliateFairPlay.com

3. The Compliance Mind Set: The Name Game
Compliance
Monitoring Your Program
Policing Your Program
Quality Assurance
Cleaning Your Program
Best Practices
Fraud Detection
A Legal Term
Avoid Affiliate Fraud Unless It Really Is
Different Meanings But We Use Them
Interchangeably

4. The Compliance Mind Set: Purpose/Goals
Integrity of Program
Regulatory Guidelines
Accurate Channel Attribution
Quality
Improved Quality Inherently Brings Growth
Attract Affiliates To Program
Improved Performance (Cost Effectiveness)
Improved ROI/ROAS
EPC, Conversion Rate Are Wrong Stats!
Improve Statistical Data For Decision Making
Garbage In Garbage Out

5. The Compliance Mind Set: The Hard Part
You Must Change Your Mind Set When In
Compliance Mode
Put On The Compliance Hat
Focus On The Goals Of Compliance
Forget The Bottom Line
Questionable Practices Can Equal Increased Revenue
Someone Will Be Ticked Off
Be Consistent, Fair And Systematic
TOS Are Meaningless If Not Enforced

6. The Compliance Mind Set: Those Bad Affiliates
Where Can I Get The LIST?
Most Frequently Asked Question
Static List = Ineffective Compliance
False Sense of Security
Not Tailored Specifically To Your Program
Quickly Out-Dated
Affiliate Marketing & Compliance Are Dynamic
Lists Can Be A Tool When Understood And Used
Correctly

7. Fundamentals: Concepts To Understand
What Is Affiliate Marketing?

8. Fundamentals: Concepts To Understand
What Is Affiliate Marketing?
Performance Based
Unique Visitors
Incremental Sales
Don’t Lose Sight Of The Channel

9. Fundamentals: Concepts To Understand
Understand The Network’s Affiliate TOS
What Types of Affiliate Promotion/Behavior Does
Your Network Allow?
If the Network Allows It Then It’s “Compliant” for
the Network

10. Fundamentals: Before You Can Police A Program
Understand How Affiliate Tracking Works
Link Structure, Tracking Domains, Encryption, Type of
Tracking (Cookie, Flash, Session, etc)
Commission Tracking vs. Impression Tracking
Develop Your TOS
Legal Document
Framework For What You Monitor
Let’s Your Affiliates Know What Promotions Are
Allowed Or Not

11. Fundamentals: Before You Can Police A Program
Develop Policy & Procedures For TOS Violations
Document All Activity: Behavior, Communications,
Actions
Establish Protocols For Different Violations
Warning: How Many? Time Frame To Come Into
Compliance
Termination With Outstanding Commissions Paid
Termination Without Paying Of Outstanding Commissions
Ignore The Behavior
Establish Protocols For Different Violations

12. Fundamentals: Before You Can Police A Program
Develop Policy & Procedures For TOS Violations
If Affiliate Remains In Program, Probation Period Is
Warranted (Increased Monitoring)
Use All Instances Of Known Violations To Establish
Indicators For Future Violations By Others

13. Fundamentals: Red Flags
Only Indicates a Possibility of Bad Behavior
Red Flag Traffic Can Be Legitimate
For Every Rule There Is An Exception
Affiliates May Utilize Techniques To Minimize Red
Flags
Use Known Offender Statistics To Develop
“Footprints”

14. Fundamentals: Common Red Flags
Sudden Increase In Traffic
Higher Than Normal Conversions
Short Duration Between Click Time and Transaction
Time
Short Duration Between Click Time and Arrival
From Another Source
No Referral Information

15. Tools: Network Log Analyzer
Most Important Tool
Logs All Traffic On Your Network. You Can See
Everything Coming Through Your Internet
Connection
More Robust Software Gives More Info But Is More
Technical
WireShark My Personal Favorite. Not Browser
Dependent
http://www.wireshark.com
LiveHTTPHeaders Captures Header Info Only FireFox
http://livehttpheaders.mozdev.org/installation.html
Fiddler Now works with multiple browsers
http://www.fiddler2.com/fiddler2/
IEWatch http://iewatch.com/ieprofessional.aspx

16. Tools: Using A Network Log Analyzer
Turn Off All Software Running In Background You
Don’t Need!
Set Filters For Traffic If Possible
Save All Captures For Documentation

17. Tools: Network Log Analyzer WireShark

18. Tools: Network Log Analyzer WireShark

19. Tools: Network Log Analyzer LiveHTTPHeaders

20. Tools: Competitive Intelligence
Not All Affiliates Fully Disclose Their Web Sites
Can Assist You In Determining Where/How
Affiliates Are Promoting
Assist In Building An Overall Picture Of Affiliate
Promotion

21. Tools: Competitive Intelligence Resources
DomainTools
http://www.domaintools.com
Basic Whois Information (free)
Name Server & Whois History (paid)
Reverse IP (paid) All Sites Registered On Same IP
Address.
Shared Hosting Accounts May Not Be Owned By Same
Person

22. Tools: Competitive Intelligence Resources
Reverse Internet
http://www.reverseinternet.com
Backlink Checker
Can Show If Affiliate Is Spamming Blogs/Forums
Will Show If BackLink Is A Frame Or A Redirect
Affiliates Framing Your Site May Show In Your Own
Backlinks
Reverse Affiliate ID, Google Analytic, AdSense
Search
Organic SERP’s, Anchor Text
Caution! Some Info Is Outdated & Data Is Still Being
Added To Site

23. Tools: Competitive Intelligence Resources
EWhois
http://www.ewhois.com
Free Site
Whois Lookup
Reverse IP Lookup
Reverse Google Analytics
Organic SERPs
Free Account Allows For Downloading Reports

24. Tools: Competitive Intelligence Resources
Push2Check
http://www.push2check.com
Free Site
Aggregates Several Competitive Intelligence Sites
Site Traffic Resources (e.g. Alexa, Compete)
SEO Sites (e.g. SEMRush, KeywordSpy, MajecticSEO)

25. Tools: Competitive Intelligence Resources
Google
http://www.google.com
Be Creative In Your Searches
Company Names
Footer Info
Add Relevant Behavior To Search (eg “spam”,
“adware”, “spyware”, “toolbar”, etc)

26. Affiliate Behavior
Automated Clicks: Cookie Stuffing, Forced Clicks
Trademark Infringement: Trademark Bidding,
Typosquatting
Software Technology: adware, malware, spyware,
apps, toolbars, plug-ins, extensions
False/Misleading Advertising
Disclosures

27. Affiliate Behavior: Automated Clicks
Cookie Stuffing, Forced Clicks, Hidden Forced Clicks
End User Did Not Physically Click On The Affiliate
Link
Many Different Flavors:
End User Can’t See The Merchant’s Site (Hidden)
End User Sees Merchant’s Site But Framed Within A
Web Page
Automatic Redirects Of Browser Of Affiliate Link
(Meta Refresh, 301/301 Redirects, Software)

28. Affiliate Behavior: Automated Clicks
Many Different Methods:
Frames
Seen On The Affiliate’s Site And Through Adware
Being Seen More Often On Blogs With Numerous
Scripts/Plug-Ins Available to Automatically Add Code
To Site
With Hidden Forced Clicks Frame With Affiliate Link
Is Sized Smaller Than Can Be Seen By Naked Eye
Frame May Be Viewable But Embeded In Other
Content (Affiliate’s Site, Press Releases, Classified
Ads)

29. Affiliate Behavior: Automated Clicks
Legal Cases
Wire Fraud?
Civil Case Ebay Vs Digital Point Solutions et al
http://dockets.justia.com/docket/california/candce/5:20
08cv04052/206526/
Criminal Case United States Vs Shawn Hogan
http://www.affiliatefairplay.com/extra/hoganindictment.
pdf
Criminal Case United States Vs Brian Dunning
http://www.affiliatefairplay.com/extra/dunningindictmen
t.pdf
Criminal Case United States Vs Christopher Kennedy
http://www.wired.com/threatlevel/2010/02/feds-bust-
cookie-stuffing-code-seller/ Guilty Plea
Sold Cookie Stuffing Script
Pled Guilty

30. Affiliate Behavior: Automated Click Detection
Must Visit Where Behavior Is Happening
Viewing Your Cookies Is The Least Reliable Method
Run A Sniffer When Testing
For Most Accurate Testing
Clear Cookies, History First
Use New Browser Session
Use Proxy If Necessary
Note! Some Will Look For “Proxy” In HTTP Header
Info To Suppress Behavior

31. Affiliate Behavior: Automated Click Detection
Finding Code That Shows “How” They Did It Isn’t
Necessary!
If Affiliate Tracking Link And Redirect To Merchant
Site Shows On Sniffer The Test Is Positive

32. Affiliate Behavior: TypoSquatting
Affiliate Buys Domains Which Are Misspellings Of
The Merchant’s Domain.
Typically Will Automatically Redirect Through Their
Affiliate Link (301/302 Redirects, Meta Refreshes,
JavaScript)
Less Frequently May Display A Minimal Landing
Page For The Merchant
Some Affiliates Partner With ISP’s To Automatically
Redirect Unregistered Typo Domains And DNS
Errors (eg merchant.cmo)
Should Normally Be Free Traffic For Merchant

33. Affiliate Behavior: TypoSquatting Detection
Check Your Referral Information For Domain Mis-
spellings (least effective)
Run Sniffer While Loading Typo Domains
Typo Domain Tools
Push2Check.com Domain Typo Tool
SEOBook Keyword Typo Generator (Enter Your
Domain)
http://tools.seobook.com/spelling/keywords-
typos.cgi
SEOChat Domain Typo Generator
http://www.seochat.com/seo-tools/domain-typo-
generator/

34. Affiliate Behavior: TypoSquatting Detection
Automate Loading Of Domains With Sniffer
Running
I-Macros http://www.iopus.com/iMacros/
WebReplay
http://iewatch.com/wrprofessional.aspx
Consulting Firms
Citizen Hawk http://www.citizenhawk.com

35. Affiliate Behavior: Trademark Bidding
PPC Search Campaigns Using Your Trademark
Company and Products
Be Clear With Affiliates What Is Allowed Or Not
Allowed
Trademark + Additional Terms?
Not Setting Up Negative Broad Search Matches Is
No Excuse
May Geo-Target & Day-Part

36. Affiliate Behavior: Trademark Bidding Detection
Consulting Firms
BrandVerity http://www.brandverity.com
Specific To Affiliate Marketing
Investigates Techniques To Thwart Dection
AdGooRoo http://www.adgooroo.com
The Search Monitor
http://www.thesearchmonitor.com/trademark_mo
nitor
ITrademarkBidding http://itrademarkbidding.com/
Script By An Affiliate

37. Affiliate Behavior: Adware
Behavior Can Be Benign To Malicious
Low Threshold For Affiliates To Acquire Software
Technology
Hundreds of Thousands of Apps Out There & Not
All Monetize Through Affiliate Marketing
Rapidly Changing
Affiliate May Own Software Or Buy Traffic Through
3rd Party

38. Affiliate Behavior: Adware Considerations
FTC Compliant?
Consumer Consented To Installation
Accurate EULA
Accurate Privacy Policy
Ability To Uninstall
Disclose If Bundled With Other Software
Ads Must Be Labeled As Coming From Adware

39. Affiliate Behavior: Adware Considerations
The Consent Debate
End User Agreed To The Installation
Some Networks Deem Click To Install As On-Going
Affirmative Action By The Consumer
Counts As Clicking The Affiliate Link Anytime In The
Future
How Far Does End User Consent Cover Revenue
Generation Tactics?
Ultimately It’s The Merchant’s Decision To Allow Or
Disallow Tactics

40. Affiliate Behavior: Adware Considerations
Distribution
Different Versions With Different Behaviors
Depending On Distribution Source
Most Aggressive Behavior Typically Installs Found In
“Wild”, Bundled Or Pay-Per-Install
Distribution Methods For “Loyalty” Software
Incentive and Coupon Sites
Remind Consumer About Incentive or Discount
Bundled and Pay-Per-Install
Software Becomes Mechanism To Obtain “Users”
Are They Bringing You Loyal Customers?

41. Affiliate Behavior: Adware Revenue Tactics
Contextual Adware
Also Called PPV/CPV
Affiliates May Buy Traffic But May Also Act As An
Affiliate Themselves
Low Cost Traffic = Lower Barrier To Entry
Ads Displayed Based On Page In Browser
Can Target Domains & Keywords
Used To Cookie Stuff At Times On Merchant’s
Shopping Cart Page

42. Affiliate Behavior: Adware Revenue Tactics
Contextual Adware
Companies
Zango, LeadImpact, Hotbar, ShopperReports
Pop-ups, Sidebar, Browser Toolbar
MediaTraffic, Vomba
Pop-ups
TrafficVance, PlaySushi, GameVance
Text Link Injection
DirectCPV
Interstitials
AdKnowledge
Text Link Injection

43. Affiliate Behavior: Adware Revenue Tactics
Contextual Adware
Capabilities
Geo-Targeting
Day-Parting
Remove User Agent References
Will Suppress In Virtual Testing Environments

44. Affiliate Behavior: Adware Revenue Tactics
Static Toolbars/Plug-ins
Least Invasive
No Automatic Behaviors
All Actions Require A True Click From End User
Used By Affiliates For Branding And Stickiness
Think Google Toolbar

45. Affiliate Behavior: Adware Revenue Tactics
Automatic Redirects
Will Automatically Redirect The Browser Through
The Affiliate Link Under Set Conditions, Usually
When Arriving To Merchant’s Site
May Suppress Automatic Redirections For Certain
Conditions
Some Traffic From Other Affiliates
Paid Search Listings
If End User Returns To Site Via A Different Source
Will Automatically Redirect
Will You Pay For Traffic That Is On Your Site
Already?

46. Affiliate Behavior: Adware Revenue Tactics
Automatic Prompting
End User Is Visually Prompted When On Merchant
Web Site
Affiliate Link Is Not Automatically Set
Less Likely To Suppress Based On Traffic Source
When Prompt Is Clicked Affiliate Link Is Set Or
Consumer Is Taken To Affiliate Site (In Same
Browser Window Or New Window/Tab)
Do You Allow Affiliates To Promote Once Consumer
Is On Your Site?

47. Affiliate Behavior: Adware Revenue Tactics
Automatic Prompting Examples

48. Affiliate Behavior: Adware Revenue Tactics
Automatic Prompting Examples

49. Affiliate Behavior: Adware Revenue Tactics
Ad Injection
High Profile Companies Did This In Early Days Of
Adware (Gator, Ezula/TopText)
Increasing In Prevalence The Last Few Years
Inject Banners, Text Links, Images, Overlays Onto
Sites Not Owned By The Affiliate
Some Networks Seem To Allow This Behavior
Affiliate Owned and 3rd Party
Do You Allow Promotion On Sites Not Owned By
The Affiliate And Not Approved By The Site Owner?

50. Affiliate Behavior: Adware Revenue Tactics
Ad Injection Examples

51. Affiliate Behavior: Adware Revenue Tactics
Ad Injection Examples

52. Affiliate Behavior: Adware Testing
Must Have The Adware Installed
Use A Secure Testing Environment!
Virtual PC or Sandboxed
Always, Always, Always Isolate Testing System
VMWare http://www.vmware.com
VirtualBox http://www.virtualbox.org
Parallels http://www.parallels.com/
Symantec http://www.symantec.com/virtual-pc

53. Affiliate Behavior: Adware Testing
Appropriately Set Up Sniffer & Run During Testing
Ideally Run From Host Not Guest Computer
One Application Per Testing Environment (VPC)
Don’t Assume When Affiliate Link Is Set By What
You See On Screen. Verify With Sniffer Logs.
Don’t Test From Company IP Address If You Have
Dedicated IP
Use Proxy If Needed But Avoid Encrypted Proxies
Test For Link Injections On Your Site And Other Sites

54. Affiliate Behavior: Adware Testing
Test What Happens For Different Traffic Sources
Direct Type-Ins
Organic Search, Paid Search
Traffic From Other Affiliates
Shopping Comparison Listings
Emails Blasts
Bookmarks
Is End User Surfing Being Tracked?
Is the URL the End User Browsing Sent Back To the
Adware Servers?
If So, Is That Behavior Disclosed In The
EULA/Privacy Policy

55. Affiliate Behavior: False/Misleading Advertising
Regulatory Agencies Focusing On Online Marketing
FTC and Law Enforcement Compliance
Several FTC Guidelines Available
http://www.ftc.gov/bcp/guides/guides.shtm
Can’t Make Claims That Aren’t True
Can’t Misrepresent Yourself (e.g. Fake Comments,
Fake Authority Sites)
If You Aren’t Sure, Then Better To Not Do It
Is Affiliate Misrepresenting Your Brand?

56. Affiliate Behavior: Disclosures
Focus on Blog Disclosures But Any Site Must
Disclose If Endorse or Give Testimonials
FTC Guidelines
http://ftc.gov/os/2009/10/091005revisedendorse
mentguides.pdf
If Disclosure Is Such That Consumer Won’t See It,
It’s Probably Inadequate
You Can’t Bury The Disclosure In Small Text As A
Link In The Footer Of The Page

57. Covering Their Tracks
Day-Parting
Behavior Is Seen Only At Certain Times
Check For Behavior Outside Of Normal Business
Hours
Geo-Targeting
Displays Or Suppresses Behavior In Certain
Geographical Locations
Use Proxies If Suspect Geo-Targeting
Suppression Based On Header Proxy Information

58. Covering Their Tracks
Dynamic Site Generation
Scripting For Conditional Web Page Generation
Geo-Targeting, Day-Parting, Cookie-Based,
Browsing History
Signs: Inconsistent Behavior
Adware
Multiple Software Versions May Behave Differently
Will Not Work In Virtual PC/Sandboxed
Environment
Geo-Targeting
Programmed For Inconsistent Behavior

59. Covering Their Tracks
Obfuscation/Encryption Of Code
Offending Code (When Affiliate Link Is Called) Is
Not Easily Read By Human Eye
Many Ways To Accomplish This
Indicates They Know They Shouldn’t Be Doing It!
You Don’t Have To See It Since The Electronic Trail
Will Still Be There

60. Covering Their Tracks: Obfuscation/Encryption
Decimal HTML Encoded

61. Covering Their Tracks: Obfuscation/Encryption
Base 64 Encoded

62. Covering Their Tracks: Decoding
Opinionated Geek
http://www.opinionatedgeek.com
Hashemian
http://www.hashemian.com/tools/

63. Presentation Resource List
http://www.affiliatefairplay.com/asc12