⚠ Penalty Exposure — Washington
Per Violation
$1,000
Willful
$2,000
AG Max/Violation
$2,000
10,000 Calls
$10,000,000
= exposure
Overview
Washington is a high-risk state for telemarketing compliance. It combines the Commercial Electronic Message Act (CEMA, RCW 19.190) — which regulates unsolicited commercial emails and text messages — with robust automatic dialing device restrictions under RCW 80.36. Washington is also a TWO-PARTY consent state for call recording (RCW 9.73.030), meaning you must inform the called party and get consent before recording any call. The Washington AG office is one of the most active in the country for CPA enforcement, and the state CPA (RCW 19.86) provides a private right of action with treble damages. Any business running automated outbound calls, texts, or AI voice to Washington consumers needs airtight consent procedures.
Consent Requirements by Channel
| Channel | Consent Required | One-to-One |
|---|---|---|
| Voice Call | Prior Express | — |
| SMS | Prior Express | — |
| AI Voice | Prior Express | — |
| Prerecorded | Prior Express | — |
| Ringless VM | Prior Express | — |
| MMS | Prior Express | — |
| Fax | Prior Express | — |
Key Court Decisions
WA v. Hulu, LLC
6/10Washington Superior Court · Sep 2023
Washington AG obtained settlement for Commercial Electronic Message Act violations involving unwanted marketing texts.
Recent Enforcement Actions
Robocall Scam Protection Act (HB 1051) — enforcement framework effective
Jul 2023 · telecommunications
WA Robocall Scam Protection Act took effect July 23, 2023. Mirrors federal DNC protections enforceable in state court. Criminalizes deliberate caller ID spoofing. Creates VoIP provider liability for knowingly facilitating illegal robocalls. Private right of action: $1,000 per violation or actual damages (whichever greater). AG enforcement: up to $2,000 per violation. WA went from relying on federal TCPA to having comprehensive state-level tools.
Global Grid Telecom Inc. (Corvallis, OR)
Oct 2021 · telecommunications
WA AG Ferguson sued Global Grid Telecom for making 54,000+ robocalls to WA residents selling a purported robocall-blocking service — via illegal robocalls. Peak irony. Company based in Oregon but targeted WA consumers. WA enforces against out-of-state callers targeting WA numbers regardless of caller location.
Associated Community Services Inc. / Directele Inc.
$495,000Mar 2021 · financial services
WA AG Ferguson + 39 AGs + FTC shut down sham charity operation that made 1.3 billion robocalls targeting 67 million consumers, collecting $110M+ through deception. 1.7 million calls into WA alone. $495K directed to legitimate charities. Managers permanently banned from fundraising and robocall telemarketing. Illustrates that charitable solicitation robocalls get the same enforcement treatment as commercial telemarketing.
Key Rules
Operating in Washington?
Get a compliance review from Catalyst Partners. We will tell you exactly what you need to do — and what you need to stop doing.
Book a Compliance Call →Stay Current
Weekly digest: what changed this week
New enforcement actions, statute updates, and rule changes in Washington — delivered once a week.
No spam. Unsubscribe anytime. Powered by Brevo.
Compliance Review
Not sure if you're compliant in Washington?
Get a 30-minute compliance review with Catalyst Partners — we'll map your outreach program against Washingtonlaw and tell you exactly where you're exposed. No generic advice. No billing by the hour after. Just the facts and a clear action list.
Book Free Consultation →Catalyst Partners · Palm Harbor, FL · +1 (727) 777-3204
This is a compliance reference tool, not legal advice. Data compiled from public statutes, LegiScan, CourtListener, state AG offices, and AI-assisted analysis. Verify all information with qualified counsel before relying on it. Full terms & data sources →