Bounded regulator lane, observed 9 September 2026. Acquisition closed after the original operative text, one fuller official copy, its current state landing page and the coordinator's explanatory release. No outreach, paid/private access, additional state case or NYDFS acquisition. Root's Block disclosures and the separate CFPB lane are not incorporated here.
Result
This is an actual consent order binding Block, Inc., rather than a voluntary industry recommendation. It establishes a state-to-company oversight mechanism: state Executive Committee receives reports/workpapers and can question the consultant; Block's board approves corrective plans and carries ultimate compliance responsibility; an independent consultant assesses and validates the work. The public instrument does not reveal the consultant's identity, executed engagement, specific implemented controls, payment receipts or completed remediation. It establishes no Lantern causal link and no bank-owner instruction.
Sources, versions and scoped reading
The [CSBS announcement](http[local research file] dated 15 January 2025, links a [10-page order body](http[local research file] That PDF ends by saying signature pages follow, but contains no signature pages or appendices. It is retained as state-csbs-order-body.pdf; its operative pages 1–10 were read, with emphasis on recitals, II governance, III payment, IV enforcement, V release and VI duration/private rights.
The [Maine enforcement entry](http[local research file] dated 16 January 2025, reproduces the order and links a [22-page fuller official copy](http[local research file] retained as state-maine-order-full.pdf. Maine's HTML operative sections and signature/appendix text were read; the PDF's signatures/appendices were extracted, and PDF pages 11, 19, 20 and 21 were rendered locally and visually inspected. The text layer of PDF11 is empty although the signed page is visible. Maine's HTML is a derivative presentation of the same instrument, not independent corroboration; use the PDF for signature/table ambiguities. The different copies are not represented as byte-identical.
Originals, URLs, retrieval timestamps, hashes, reading scopes and derivative ancestry are in captures-state.json. All four public GETs succeeded. The web screenshot route returned cache-miss errors; the already retained PDF was rendered locally with pypdfium2 instead, without another network attempt.
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.
The recitals describe an examination begun around 15 May 2023, covering 1 January 2021–31 March 2023, conducted by California, Colorado, Kentucky, Massachusetts, New Hampshire, Ohio, Texas and Washington. A joint Report of Examination (ROE) issued 6 November 2023 identified AML-program adequacy findings. Block's approximately 6 December 2023 response described new and planned controls. The actual ROE and response are not attached in the retained copies. Block neither admits nor denies wrongdoing or violations (CSBS PDF1–2; Maine HTML recitals).
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.
There are three different regulator groupings. The examination had the eight jurisdictions above; the public release credits seven enforcement leads (Arkansas, California, Massachusetts, Florida, Maine, Texas and Washington); the initial Executive Committee has five (Arkansas, California, Massachusetts, Texas and Washington). Do not merge these rosters into a single approval body.
Operative rights
| Actor / relation suitable for the map | Exact scope and locus |
|---|---|
| Participating state regulators → Block: enforce order | Jurisdiction under I and IV; each state retains enforcement/examination authority. Before enforcement under the agreement, the state gives the Executive Committee and Block written allegations and an opportunity to respond (IV.C, PDF7). This does not bind every other government agency. |
| State Executive Committee → compliance process: receives and questions | II.A and II.C.3, PDF2–3: receives consultant/company communications and can obtain all Board Reports. II.D.4/6, PDF5: simultaneous consultant reports to Block and committee; committee can obtain workpapers and other work product. IV.D, PDF7: participating regulators may obtain information held by committee/MMET. |
| Block → Compliance Management Committee: appointment | II.B, PDF3: company representatives across relevant divisions, quarterly meetings/minutes. Continues until the later of receipt of validation report or eight quarters from effective date; only then may Block dissolve it at its discretion. No present dissolution or meeting record obtained. |
| Block board → compliance/CAP: ultimate oversight and formal approval | II.C, PDF3; II.D.2, PDF4: board or authorized committee formally approves the Corrective Action Plan (CAP). CAP and updates are sent to the state committee. The text does not separately state that the state committee must formally approve each CAP. |
| Independent consultant → AML program: assessment/priority/validation | II.D.1–3, PDF3–5: assess adequacy under applicable BSA requirements and 31 CFR 1022.210, prioritize corrective measures, validate completed measures and give progress reports. Block must provide relevant personnel, vendor, facility and record access (II.D.7, PDF5–6). This is review/validation authority, not proof of power to close individual customer accounts. |
| Block → replacement consultant: selection/engagement; state committee receives notice | II.D.8, PDF6: notice of replacement need within ten days of awareness, notice of selection within ten days, engagement within thirty days of selection notice; qualified independent unaffiliated third party. No named consultant, initial selection procedure or express state appointment-veto provision was located in this operative text. Do not infer veto merely from the word independent. |
| State Executive Committee → reporting deadlines: extension discretion | II.D.9, PDF6: reasonable-ground request by Block, good-cause grant by committee. CAP duration extensions have a separate consultant-review mechanism in II.D.2(c), PDF5. |
Clocks and money states
Effective date is 15 January 2025 (VI.A, PDF8). Assessment report: within nine months of that date, subject to reporting extensions. CAP submission: within 90 calendar days after the assessment report is issued, with immediate implementation; consultant priority must be appropriately incorporated. CAP completion: 12 months, with the consultant documenting the basis/need for an extension (II.D.2(c)). The CSBS release describes this as twelve months after report filing; the operative paragraph itself states the period without an equally explicit start phrase. Do not turn that summary into proof of an actual filing date or expired obligation.
Other specified clocks include consultant progress reports at least quarterly and within ten days of request/quarter end; questions and responses have separate 20/15-day or 45/15-day periods. CAP completion triggers independent validation and a report; continued deficiencies trigger an updated CAP within 60 days of the validation report. Board progress reports are due within thirty days of each company committee meeting. No actual report, validation, extension or schedule performance is established here.
USD80,000,000 is the settlement obligation, composed of USD79,075,000 administrative penalty plus USD925,000 administrative costs (III.A, PDF6). Each payment clock is twenty calendar days after receipt of payment instructions, not simply twenty days after signing. Appendix C (Maine PDF22) allocates costs: Arkansas150,000; California250,000; Massachusetts150,000; Maine75,000; Texas150,000; Washington150,000. These are state administrative-cost allocations, not the consultant's fees or consumer redress. Unpaid sums may be claimed against relevant surety bonds under III.B. The covered-conduct release depends on both effectiveness and full payment (V.D, PDF8). An obligation or release condition is not a payment receipt.
Visible 48/49 allocation/version question
The 15 January announcement reports 48 state regulators. Maine's fuller copy visibly contains a Colorado signature dated 16 January 2025 (PDF19), and Appendix A enumerates 49 jurisdictions including DC (PDF20). Appendix B contains 48 allocation rows, includes Colorado and omits Wyoming, although Wyoming appears in Appendix A and has a signature block in PDF17. Its stated penalty total remains USD79,075,000 (PDF21). Independent numerical review confirms that the48 listed values sum exactly to that total; the open question is the allocation basis for the differing party list, not an arithmetic shortfall. These are visible record differences, not OCR artifacts. The Maine HTML likewise includes Colorado and lacks a Wyoming penalty row.
A later signature, publication assembly or allocation adjustment could explain parts of the difference. No corrected allocation schedule, alternative-payment election or reconciliation notice was obtained, so do not assert a particular explanation, missing money or that Wyoming was not a party. Preserve the total obligation as stated and leave per-state payment completeness unestablished.
Current public status and stopping point
The live Maine entry still presents its 16 January 2025 date, this agreement text and attached full copy. No linked completion certification, amendment, extension, consultant appointment or payment acknowledgment is displayed in the inspected entry. The CSBS release remains dated 15 January 2025. This narrow present inspection is not an exhaustive docket search and cannot establish current compliance or noncompliance. VI.C/I requires written changes by the parties (or other stated cessation conditions); VI.J creates no private enforcement right under this order. The agreement preserves Block's later hearing/appeal rights in a compliance disagreement (recitals, PDF2).
The next discriminating records are the executed consultant engagement/selection notice, assessment and validation reports, board-approved CAP with state receipt and any extensions, payment instructions/receipts and any corrected Appendix B. Block, the consultant and the state Executive Committee are the directly identified holders for the compliance records; the recipient regulators hold payment records. The unreleased ROE is the record needed to specify original deficiencies. Their absence from this packet is not evidence that none exist or that the required work was not performed. No subsequent branch is opened pending the forest assessment.