Lilly Ghalichi Instagram Database

TINA.org investigated 21 social media influencers who have received two FTC letters notifying them of their legal obligation to clearly and conspicuously disclose their relationships with brands when promoting products or services on social media platforms, such as Instagram. TINA.org collected more than 1,400 ads from 20 of the 21 influencers collectively promoting more than 500 companies between May 2017 and December 2018, each of which lack appropriate disclosures of the influencers’ material connections to the brands promoted.

Below is a sampling of Lilly Ghalichi’s inadequately disclosed Instagram ads. For posts that were accompanied by lengthy captions, TINA.org opened the full caption by clicking on “more” prior to capturing the post. Thus, the view presented below is not necessarily what a consumer would see when scrolling through an Instagram feed, highlighting the importance of placing disclosures at the beginning of a caption. Further, in some of the posts captured by TINA.org, Instagram’s built-in disclosure tool was used but, in those cases, the disclosure is separated from the caption and the image and is thus not sufficient.

TINA.org has also collected evidence that Lilly Ghalichi has a material connection to the brand(s) in the posts that must be clearly and conspicuously disclosed. (To view such evidence, click on each brand name below.)

TINA.org audited these findings in February 2019. Any Instagram posts that had been taken down or edited to clearly and conspicuously disclose the influencer’s material connection as of that time are shown below in gray.