The past few years alone have seen influencer marketing expand from traditional celebrity product reviews and oral endorsements to more nuanced imagery by less-known influencers ranging from self-made Instagram personalities to “virtual,” computer-generated personas (who are nearly indistinguishable from humans when scrolling through social media). The category of products promoted by influencers is also expanding, transitioning from general consumer products to a greater number of partnerships in the health and wellness space.

The ubiquitous and evolving nature of influencer advertising has not been lost on regulatory agencies, with both the Food and Drug Administration and Federal Trade Commission announcing efforts to update the agencies’ perspective on the impact of influencers on consumers.