Money. Identity. Technology.
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Governing body
Board has ultimate responsibility under both orders; specified review/approval/reporting duties. No inference particular directors exercised every required action.
Block Board compliance responsibility → Required AML Corrective Action Plan
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Board or authorized committee has formal CAP approval and ultimate compliance responsibility. CAP is submitted to state Executive Committee; receipt is not an express additional CAP approval requirement. Actual plan and approval not acquired.
Block Board compliance responsibility → Required CFPB Compliance Plan
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
Board/executives must review relevant plans and submissions and ensure necessary actions/resources; annual sworn Compliance Report must be Board approved. Does not prove the required reports were prepared or accepted.
July required company compliance committee/report → Block Board compliance responsibility
State-specific agreed texts stipulate effective 8 July 2026. Party assent observed; judicial entry and subsequent changes/performance unverified.
Agreed corporate committee reports to Board quarterly. Annual compliance report has separate committee approval/on-request availability; no report, actual meeting or blanket prior AG approval.
July 2026 multistate AG / Block resolution ↗
CFPB / Block: account restrictions, error redress and accountable decision-making ↗
Block/Cash App multistate BSA/AML order: decision rights and public limits ↗
Block Board compliance responsibility → has ultimate compliance responsibility → Required CFPB Compliance Plan
Order entered 16 January 2025; conditional duration and written modification provisions. Performance and any later modification unverified.
Board/executives must review relevant plans and submissions and ensure necessary actions/resources; annual sworn Compliance Report must be Board approved. Does not prove the required reports were prepared or accepted.
Block Board compliance responsibility → must formally approve corrective action plan → Required AML Corrective Action Plan
Order effective 15 January 2025; conditional clocks and written changes. Performance, payment and extensions unverified.
Board or authorized committee has formal CAP approval and ultimate compliance responsibility. CAP is submitted to state Executive Committee; receipt is not an express additional CAP approval requirement. Actual plan and approval not acquired.
July required company compliance committee/report → must provide quarterly compliance reporting → Block Board compliance responsibility
State-specific agreed texts stipulate effective 8 July 2026. Party assent observed; judicial entry and subsequent changes/performance unverified.
Agreed corporate committee reports to Board quarterly. Annual compliance report has separate committee approval/on-request availability; no report, actual meeting or blanket prior AG approval.