Public enforcement pressure directed at private seller-access rules

22 August 2025 NCII payment-platform letter

The 22 August 2025 payment-platform letter is a coordinated request from 47 attorneys general concerning sellers of tools and content for deepfake nonconsensual intimate imagery. It addresses Visa, Mastercard, American Express, PayPal, Google Pay and Apple Pay.

Demands and subsequent pressure

The payment text asks recipients to describe existing controls and commit to further seller exclusion. It carries NAAG letterhead, and Pennsylvania's official announcement credits Vermont AG Charity Clark with authorship. Idaho AG Raul Labrador later warned of legal consequences in September 2025. The retained record establishes these requests and pressure, but no compulsory response deadline or confirmed recipient implementation. Its scope is nonconsensual imagery and associated sellers, rather than a general pornography prohibition.

What the records show

22 August 2025 NCII payment-platform letterAmerican Express Company

requests proactive NCII seller payment-authorization removal

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to American Express legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

22 August 2025 NCII payment-platform letterGoogle

requests proactive NCII seller payment-authorization removal

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to Google Pay legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

22 August 2025 NCII payment-platform letterMastercard

requests proactive NCII seller payment-authorization removal

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to Mastercard legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

22 August 2025 NCII payment-platform letterApple Inc.

requests proactive NCII seller payment-authorization removal

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to Apple Pay legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

22 August 2025 NCII payment-platform letterPayPal

requests proactive NCII seller payment-authorization removal

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to PayPal legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

22 August 2025 NCII payment-platform letterVisa

requests proactive NCII seller payment-authorization removal

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to Visa legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

Raul Labrador — Idaho AG, September 2025 statement22 August 2025 NCII payment-platform letter

reiterated demand and threatened legal consequences

Official newsletter 19 September 2025.

19 September official newsletter presents safeguards or legal consequences as the choice facing recipients. A signatory public warning makes consequence-free-persuasion framing inadequate, but supplies no filed action, operative order or company outcome; not attributed to every co-signatory.

47-AG NCII letter coalition22 August 2025 NCII payment-platform letter

endorsed requests to payment-platform counsel

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Combined dated letters and official announcement identify 47-AG coalition. Payment body seeks control descriptions and commitments to proactive NCII seller exclusion under private rules. No compulsory deadline, statutory order, sanction or proved recipient action.

Further reading

Public officials ask payment networks to use private rules

Response/outcome search: 22 August 2025 NAAG deepfake-NCII letters

San Francisco notices: the original remains a specific gap

California’s third-party deepfake-service liability route

Read the original sources 5

What the connections say

11 relationships
1

47-AG NCII letter coalitionendorsed requests to payment-platform counsel22 August 2025 NCII payment-platform letter

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Combined dated letters and official announcement identify 47-AG coalition. Payment body seeks control descriptions and commitments to proactive NCII seller exclusion under private rules. No compulsory deadline, statutory order, sanction or proved recipient action.

Read the original sources 2
2

National Association of Attorneys Generalappears as letterhead and coordinating identity22 August 2025 NCII payment-platform letter

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Original visibly bears NAAG letterhead and 2025 officers/staff. That establishes institutional presentation; actual drafting, funding, dispatch and jurisdiction sign-off record remain not obtained. May 2026 procedure is not backdated as proof.

Read the original source 1
3

Charity Clark — Vermont AG, letter attributionofficial announcement attributes authorship to her22 August 2025 NCII payment-platform letter

Attribution published 26 August 2025 concerning letters dated 22 August; drafting date unknown.

Reported by the cited source

Pennsylvania participant announcement attributes combined-letter authorship to Vermont AG Charity Clark and names five co-sponsors. Original drafts and individual staff composition are unknown; not proof she controlled every signature or subsequent company decision.

Read the original source 1
4

22 August 2025 NCII payment-platform letterrequests proactive NCII seller payment-authorization removalVisa

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to Visa legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

Read the original source 1
5

22 August 2025 NCII payment-platform letterrequests proactive NCII seller payment-authorization removalMastercard

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to Mastercard legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

Read the original source 1
6

22 August 2025 NCII payment-platform letterrequests proactive NCII seller payment-authorization removalAmerican Express Company

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to American Express legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

Read the original source 1
7

22 August 2025 NCII payment-platform letterrequests proactive NCII seller payment-authorization removalPayPal

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to PayPal legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

Read the original source 1
8

22 August 2025 NCII payment-platform letterrequests proactive NCII seller payment-authorization removalGoogle

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to Google Pay legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

Read the original source 1
9

22 August 2025 NCII payment-platform letterrequests proactive NCII seller payment-authorization removalApple Inc.

Letter dated 22 August 2025; announcement 26 August. Actual dispatch/receipt and response not acquired.

Addressed to Apple Pay legal representatives: asks present controls and further action enforcing existing terms/acceptable-use policies against sellers of deepfake NCII tools/content. Seller-level scope; no named bank instruction, adjudication, compulsory response deadline or confirmed receipt/implementation. Not a general pornography ban.

Read the original source 1
10

Raul Labrador — Idaho AG, September 2025 statementreiterated demand and threatened legal consequences22 August 2025 NCII payment-platform letter

Official newsletter 19 September 2025.

19 September official newsletter presents safeguards or legal consequences as the choice facing recipients. A signatory public warning makes consequence-free-persuasion framing inadequate, but supplies no filed action, operative order or company outcome; not attributed to every co-signatory.

Read the original sources 2
11

22 August 2025 NCII payment-platform letterwas reportedly cited as earlier noticeSF Apple/Google notices — July 2026 reporting

2026-07-16 – 2026-07-16

Reported by the cited source

Chronicle says the later SF notices cite the47-AG warning. This is a reported document link; the old general letter alone does not establish current(c)(2) service-specific evidence, routing, receipt or subsequent failure predicates.

Read the original sources 3