Key takeaways: 

• With the arrival of FTC Chair Lina Kahn, the FTC has entered a new era of aggressive enforcement. This comes despite a number of recent judicial defeats that have significantly impacted the FTC’s enforcement authority.
• Companies developing FTC compliance programs, or under investigation by the FTC’s Bureau of Consumer Protection, should be aware of significant developments impacting the Commission’s regulatory authority and enforcement priorities. This article provides an overview of ten key points companies should be aware of when developing FTC compliance programs, remediating past behavior, or confronting FTC privacy or cybersecurity enforcement.