Lina Khan after the FTC: her playbook is still driving enforcement

TL;DR:

Khan stepped down on January 20, 2025.
FTC secured a $2.5B Amazon Prime settlement on September 25, 2025.
ROSCA powered the case, signaling tougher action on “dark patterns.”
Expect more case-by-case actions against deceptive subscriptions.
Firms should audit sign-up and cancellation flows now.

Lina Khan left the Federal Trade Commission on January 20, 2025. Andrew N. Ferguson became chair after her term. Even with the leadership change, the FTC’s September 25, 2025 action against Amazon shows her approach is still shaping policy. The agency announced a $2.5 billion deal over claims that Amazon used deceptive Prime sign-ups and an obstructive cancel flow. The case leans on the Restore Online Shoppers’ Confidence Act, a law aimed at subscription abuses.

The details, dates, and tools

Reuters reported on September 29, 2025 how the case hinged on ROSCA, a once overlooked statute. The FTC’s press release on September 25 details two buckets of penalties, civil fines and consumer restitution. The agency says Amazon misled users into enrolling and made cancellation hard.

Why it matters

Khan championed tighter rules for dominant platforms and a crackdown on manipulative interfaces. Even after her exit, companies face higher risk if they rely on dark patterns. Law firms are already advising clients that the FTC is signaling case-by-case actions against noncompete abuses and subscription traps.

What companies should do this quarter

Map every click in sign-up and cancel journeys.
Present clear prices, frequency, and auto-renew terms.
Offer simple, self-service cancellation with one or two steps.
Log consent with time stamps and store confirmation emails.

Quick checklist

Area	Good practice
Disclosure	Price, renewal cadence, trial limits on the pay button
Consent	Unchecked boxes, clear “Start trial, pay ₹X/mo on DD MMM”
Cancellation	Web self-service, one page, instant confirmation
Records	Event logs, screen captures, audit trails

What’s next

Expect enforcement against subscription trickery across retail, media, fitness, and software. Keep an eye on additional ROSCA cases. Academic and policy circles are also pushing for clearer rules on “dark patterns.”

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