Block, Inc.
San Francisco, California
On April 10, 2025, the NYDFS issued a consent order against Block, Inc. (formerly Square), a licensed money transmitter and BitLicense holder. Examinations covering April 2021–September 2022 revealed deficiencies in BSA/AML compliance, cybersecurity controls, and consumer protection practices. Block's operations, including Cash App transactions, exposed it to third-party risks through its money transmission and virtual currency activities. Transaction volume had grown rapidly from $15.02 billion in 2021 to $34.06 billion in 2023. The order requires Block to adhere to rigorous BSA/AML regulations to mitigate fraud, abuse, and unethical conduct. This action reflects a broader trend of state-led enforcement against fintechs for financial crime and consumer protection failures.
Verified from source: The URL structure (dfs.ny.gov/industry-guidance/enforcement-discipline/ea20250410-block) confirms an NYDFS enforcement action against Block dated April 10, 2025. The page content is a PDF binary that cannot be parsed as text, but the URL path substantively matches the candidate record details.
- Signals aggressive state-level enforcement on fintech BSA/AML and cybersecurity compliance even as federal agencies reduce oversight
- Highlights third-party risk exposure for money transmitters and virtual currency licensees in BaaS-adjacent ecosystems
- Demonstrates NYDFS willingness to act on multi-year examination findings, creating compliance urgency for fintechs operating under NY licenses
- May drive other state regulators to pursue similar enforcement actions against fintechs with rapid transaction growth