What the records show
Block → Participating state money-transmission regulators
owes separate penalty and administrative costs
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
USD 80 m settlement comprises USD 79.075 m penalty and USD 925,000 state administrative costs, payable 20 calendar days after payment instructions. Block later expected payment by/about February 2025; no receipt acquired. Costs are neither consultant fees nor consumer redress. Covered-conduct release is conditioned on full payment. Financial details: value: 80,000,000; currency: USD; kind: settlement obligation; no payment receipt established; period: 20 calendar days after receipt of payment instructions
Block → Required CFPB Redress Plan and allocation
must reserve funds for ordered redress
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
117 requires USD 75 m reserved or in segregated deposit within 10 calendar days; consumer redress capped at USD 120 m. If consumer redress is below USD 75 m, specified shortfall goes to CFPB, with possible further redress/Treasury residue. Neither figure proves cash received by consumers or actual reserve establishment. Financial details: value: 75,000,000; currency: USD; kind: ordered reserve or segregated-deposit obligation; not observed payment; period: Within 10 calendar days of order effective date
Block → National Association of Attorneys General
agreed investigation-expense reimbursement allocation
State-specific agreed texts stipulate effective 8 July 2026. Party assent observed; judicial entry and subsequent changes/performance unverified.
Oregon48 allocates USD 264,153.73 from the same USD 45m state pool to NAAG for participating states investigation costs/expenses, by wire using Oregon instructions. Agreed entitlement, not observed payment, a separate fine, named judgment creditor or proof of allocation to any fund or letter campaign. Financial details: value: 264,153.73; currency: USD; kind: agreed reimbursement allocation inside USD 45m pool; not additional or paid; period: July 2026 agreement; stated payment within 30 days
Block → Mandated independent AML consultant
selects replacement subject to independence and notice
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
II.D.8: company Compliance Management Committee must notify state Executive Committee within 10 calendar days after becoming aware of replacement need. Block must notify that committee within 10 calendar days AFTER making its selection, then engage the replacement within 30 calendar days of selection notification. No 10-day selection deadline is stated. Replacement must be qualified, independent and unaffiliated; no named firm, initial appointment method or express state veto established.
46 participating July Block-settlement AGs → Block
agreed a conditional notice and response process
State-specific agreed texts stipulate effective 8 July 2026. Party assent observed; judicial entry and subsequent changes/performance unverified.
Where the State determines material failure and, in its sole discretion, no health/safety/welfare threat, it will notify before legal action. Block has 15 business days for a good-faith written response, potentially describing ongoing correction/timetable; not necessarily a completed cure. Only enumerated duties sunset at five years, direct education at seven; not whole-judgment expiry.
July 2026 Block / state-AG agreed resolution → Block
sets distinct transfer-error and anti-fraud duties
State-specific agreed texts stipulate effective 8 July 2026. Party assent observed; judicial entry and subsequent changes/performance unverified.
Notice-of-Error evidence rights and credit timing have their own trigger, including no required contact with the P2P recipient/law enforcement before investigation. Fraud controls also identify suspected scam accounts and prevent operation/return. Neither universal closure-document access nor a prescribed Lantern supplier follows.
July 2026 Block / state-AG agreed resolution → Block
sets agreed restriction-review procedures
State-specific agreed texts stipulate effective 8 July 2026. Party assent observed; judicial entry and subsequent changes/performance unverified.
Literal deadline By June 30, 2026 precedes stipulated effective date. Prompt notice, access information, review and reasonable restoration efforts have appropriateness/legal-prohibition qualifications. Flexible language does not say it replaces CFPB 24h notice/10-business-day appeal rules; breach or intent not inferred.
Block → July required company compliance committee/report
agreed to maintain internal compliance oversight
State-specific agreed texts stipulate effective 8 July 2026. Party assent observed; judicial entry and subsequent changes/performance unverified.
Qualified committee, documented compliance management, training and quarterly Board reporting. Annual compliance report must be prepared and committee-approved, available to state on request. Not CFPB annual sworn Board-approved submission or an observed outside monitor. Existing adequate procedures may satisfy terms.
From the investigation
Cash App US: published contractual authority over access and balances
Observed 9 September 2026. Bounded agreement lane; no customer account, support contact, private API, historical contract reconstruction or enforceability opinion. The main instrument is the agreement with Block, Inc. It grants service-access and fund-access discretion separately. Neither contractual power proves why any particular account was closed, nor does closure itself establish loss of ownership of the remaining money.
Read the research & sources ↗Parties, examination and allegation boundaries
The order names Block, Inc., formerly Square, Inc., NMLS 942933 , as the company operating Cash App. The other parties are participating states' money-transmission regulatory agencies. CSBS and MTRA supply coordination protocols, and the states work through the Multi-State MSB Examination Taskforce (MMET); they are not additional company respondents or substituted state enforcement authorities. Jack Dorsey signs for Block as Block Head and Chairperson (Maine PDF11), not as a separately named personal respondent.
Read the research & sources ↗Respondent's position and limits
Official SEC submission metadata was captured successfully to identify filings. Ordinary GETs of the2025K,2026Q2 and Block-response pages returned403; these routes are closed. Their saved HTML files are explicitly error responses, not retained originals. The primary web reader worked and provided the scoped substantive passages above. Investor filing-list pages rendered only navigation, so the successful public SEC metadata route supplied exact filing addresses. No challenge bypass or authenticated route was used.
Read the research & sources ↗Parties, examination and allegation boundaries
CSBS's release describes due-diligence, identity-verification, suspicious-activity reporting and high-risk-account requirements, and says regulators found noncompliance with certain requirements. Those explanatory categories must not be silently turned into an enumerated, proved list of specific Block failures: the public order refers to the underlying ROE without setting those particulars out. Likewise, the broad list of practices covered by the release in V.C is a release definition, not a separate finding that every listed practice failed.
Read the research & sources ↗