This guide will assist in-house counsel and private practice lawyers understand how to comply with the Restore Online Shoppers’ Confidence Act (ROSCA), enacted to address ongoing consumer protection concerns around deceptive sales practices and data sharing in online retail. The guide sets out the background to implementation and what ROSCA does, considers the key prohibitions and disclosure requirements, and provides an overview of penalties and enforcement actions in the event of non-compliance.In addition, the guide sets out general requirements when drafting a compliance program for ROSCA. The validity and enforceability of such compliance programs may vary among US jurisdictions. The discussion in this guide should be taken as a general statement of the laws applicable in most US jurisdictions. You are advised, however, to consult the local laws in your jurisdiction before drafting a compliance program of this type.