MISCONDUCT PENALTY:

After a series of incidents in which the company broke its promises to protect users' privacy and security, Twitter effectively agreed to put itself in the penalty box. It has been under an FTC order since 2011, and last year agreed to new, more-intrusive sanctions as part of a $150 million settlement of new alleged violations.

If Twitter doesn't live up to the commitments it made under that deal, the FTC could seek more severe financial penalties and sanctions.

"Unless Twitter can really prove to the FTC that it is adhering carefully to the new consent decree, which has lots of provisions that are supposed to ensure compliance-monitoring, record-keeping, all those things, then they're going to get another enforcement case," said David Vladeck, a Georgetown University law professor who previously ran the FTC's consumer-protection bureau.

Cobun Zweifel-Keegan, managing director at the International Association of Privacy Professionals, said the rapid-fire changes being made at Twitter could expose the company to legal risks, if regulators determine that the changes weren't deliberated carefully as required under the FTC order.

"Any time a decision is being made very quickly, that could easily raise questions in the mind of a regulator about whether a compliance, design and review process is being followed," Mr. Zweifel-Keegan said.

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