Consumers nationwide just lost out on a “free” cruise following a settlement between a U.S. consumer protection agency, two executives and several Florida-based cruise vacation companies.

But it is corporate counsel that might be most affected by the $6.4 million settlement—in addition to $100,000 in civil penalties the principals must pay—the Federal Trade Commission reached with Jonathan Blake Curtis, Anthony DiGiacomo, and five cruise vacation companies, including Grand Bahama Cruise Line LLC.