She is a former FTC Chair so she knows what she's talking about, although her approach to enforcement was more expansive than others. The FTC would investigate, likely along the lines she summarizes, build a case in writing, and refer it to the Justice Dept, which would actually prosecute the case. Not going to happen under this administration, but Khan is saying it's entirely possible that such an enforcement action could be brought to bear, now or later. Personally I hope she gets her job back at some point and does it herself.