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New York’s Department of Financial Services (NYDFS) ordered Block, Inc. to pay a $40 million civil penalty under an April 10, 2025 consent order. NYDFS said Block failed to maintain an effective anti-money-laundering (AML) program. The action was not limited to Cash App: the regulator’s account describes controls across Block’s fiat and virtual-currency operations, and the order lists additional violations.
What NYDFS said Block did wrong
The consent order says Block failed to maintain an effective and compliant AML program, citing New York regulations 23 NYCRR § 200.15 and 3 NYCRR § 417.2. NYDFS’s April 10, 2025 consent order sets out the settlement terms. Its 2025 annual report, published in 2026, gives more detail about the department’s AML findings.
NYDFS described gaps in customer due diligence, risk-based controls, transaction monitoring, and oversight of high-risk Bitcoin transactions. These are the regulator’s findings; the sources cited here do not include Block’s response or a separate independent audit of them.
Customer checks and risk-based controls
According to NYDFS, Block’s customer due diligence was inadequate, and its controls designed to prevent money laundering and illicit activity were insufficiently risk-based. In practice, those weaknesses can make it harder for a financial-services business to understand customer risk and apply appropriate safeguards.
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Transaction monitoring and alert backlog
NYDFS also reported that Block did not effectively and promptly monitor transactions. The department said rapid growth between 2019 and 2020 contributed to a severe backlog of transaction alerts that remained unresolved for a significant period. That explanation is NYDFS’s account; the reviewed sources do not independently establish the cause of the backlog or its eventual resolution.
High-risk Bitcoin transactions
The annual report also points to insufficient oversight of high-risk Bitcoin transactions. That finding is one reason the enforcement should not be reduced to consumer payments through Cash App alone: NYDFS described Block’s AML program as covering both fiat and virtual-currency operations.
Why the $40 million penalty was not just a Cash App AML fine
Cash App appears in NYDFS’s enforcement announcement, but the consent order names Block, Inc. as the subject and lists violations beyond AML. In addition to the AML provisions, the order identifies issues involving board approval of cybersecurity policy, business continuity and disaster recovery, virtual-currency risk disclosures, and money-transmission receipts. The order sets a single $40 million civil penalty; it should not be described as a penalty solely for a Cash App-specific AML failure.
NYDFS lists Block, formerly Square, as holding New York virtual-currency and money-transmitter licenses. That regulatory context helps explain why the order addresses more than one type of financial activity.
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What Block agreed to do
NYDFS’s 2025 annual report says Block paid the penalty and agreed to a monitor-led review of its current AML program, along with a lookback into prior conduct and transactions. The reviewed sources do not establish whether the monitor’s work or the lookback has been completed.
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The enforcement concerns Block’s compliance systems and NYDFS’s findings about them. The sources cited here do not say that every Cash App transaction was affected, that customer funds were lost, or that Cash App has been shut down. Nor do they establish the present status of the alert backlog or the monitor’s review. The regulator’s general guidance on risk-based monitoring and virtual-currency controls provides broader context, but is not evidence of additional Block-specific findings.
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