In the Matter of Block, Inc. (Block of Delaware): Consent Order ($40,000,000 penalty; independent monitor)

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Payment Processors

2025-04-10

Document text

Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

NEW YORK STATE
                             DEPARTMENT OF FINANCIAL SERVICES
                                    ONE STATE STREET
                                 NEW YORK, NEW YORK 10004

------------------------------------------------------x

In the Matter of                                     :

BLOCK, Inc.
BLOCK OF DELAWARE:
                                                     :

------------------------------------------------------x

                                             CONSENT ORDER

        The New York State Department of Financial Services (the “Department” or “DFS”) and

Block, Inc. d/b/a Block of Delaware and Block of Delaware (“Block” or “the Company”) are

willing to resolve the matters described herein without further proceedings;

        WHEREAS, Block is a publicly-traded financial services and technologies company. In

2023, Block had revenue of $21.91 billion. The Company’s total assets more than doubled from

2021 to 2023, growing from $15.02 billion to $34.06 billion;

        WHEREAS, Block, formerly known as Square, Inc., has been licensed by the

Department to operate a money transmission business in New York State pursuant to New York

Banking Law § 641 since 2013. In June 2018, the Department issued Block a BitLicense,

                                                          1
permitting Block conduct Virtual Currency Business Activity (“VCBA”), as defined by 23

NYCRR § 200.02(q), in New York State;

       WHEREAS, Block owns and operates Cash App, a peer-to-peer money transmission

service that allows users to send and receive fiat currency. In 2018, Block began offering Bitcoin

transactions through Cash App;

       WHEREAS, the Department conducted two full-scope examinations of Block covering

both its money transmitter (“MT”) license and BitLicense (“VC”);

       WHEREAS, the Money Transmitter Examination (“MT Exam”) covered the period of

April 1, 2021 through September 30, 2022 and the Virtual Currency Examination (“VC Exam”)

covered the period of February 28, 2021 through September 30, 2022;

       WHEREAS, following the MT Exam and VC Exam, the Department initiated an

enforcement investigation into Block’s compliance with applicable laws and regulations,

including but not limited to anti-money laundering (“AML”) regulations, consumer protection

regulations, and the Department’s Virtual Currency Regulation (23 NYCRR Part 200); and

       WHEREAS, the MT Exam and the VC Exam, as well as the subsequent enforcement

investigation, identified serious compliance deficiencies with respect to Block’s Bank Secrecy

Act/Anti-Money Laundering (“BSA/AML”) program. These failures include insufficient Know-

Your-Customer (“KYC”) and transaction monitoring processes, and a backlog of Suspicious

Activity Reports (“SARs”) during 2018-2021, which together created a high-risk environment

vulnerable to exploitation by criminal actors. The Department also identified violations of the

Department’s consumer protection regulations.

                                                2
       NOW THEREFORE, in connection with an agreement to resolve this matter without

further proceedings, pursuant to the Superintendent’s authority under Sections 39 and 44 of the

New York Banking Law, the Department finds as follows:

                             THE DEPARTMENT’S FINDINGS

       Introduction

       1.      The Department is the primary financial services regulator in the State of New York

and the Superintendent of Financial Services (the “Superintendent”), is responsible for ensuring

the safety, soundness, and prudent control of the various financial services businesses under the

Department’s supervision. To that end, the Superintendent enforces the laws and regulations

applicable to the financial services, insurance, and banking sectors, including the New York

Financial Services Law, the New York Banking Law, and the regulations promulgated thereunder.

       2.      The Superintendent has the authority to conduct investigations, to bring

enforcement proceedings, to levy monetary penalties, and to revoke the license of entities who

have violated the relevant laws and regulations.

       Applicable Laws and Regulations

       3.      Block, licensed as both a money transmitter and a BitLicensee, is subject to a

rigorous set of BSA/AML regulations promulgated by the Department and designed to promote

the safety and soundness of the financial services industry by reducing and eliminating fraud,

abuse, and unethical conduct. Additionally, Block is required to adhere to the law and the

Department’s regulations regarding cybersecurity and consumer protection.

       Money Transmitter Regulations

       4.      The regulations specific to money transmitters’ obligations to maintain an AML

program are found in Part 417 of the Superintendent’s Regulations. Specifically, Section 417.2

                                                   3
of the New York Codes, Rules, and Regulations requires money transmitter licensees to establish

and maintain an AML program that complies with all applicable Federal anti-money laundering

laws. Section 417.2 additionally requires each licensee to “demonstrate that it has in place risk-

based policies, procedures and practices to ensure, to the maximum extent practicable, that its

transactions comply with Office of Foreign Assets Control (“OFAC”) requirements” and to

comply with KYC requirements under Federal law.

       5.      Money transmitter licensees are further subject to the consumer protection

requirements contained in 3 NYCRR § 406.

       The Virtual Currency Regulation

       6.      The Department developed and oversees a first-of-its-kind regulatory framework

pertaining to virtual currency businesses. Companies that conduct VCBA in the State of New

York must be licensed to do so by the Department — either through the Department’s BitLicense

or a Limited Purpose Trust Company Charter — and are subject to the Department’s ongoing

supervision.

       7.      The specific obligations of those companies operating pursuant to a BitLicense

are set forth in the Virtual Currency Regulation. The licensing and compliance requirements

contained in the Virtual Currency Regulation include the requirement that each licensee develop

and implement various compliance policies and programs, including a robust AML program, see

23 NYCRR § 200.15, a cybersecurity program, see 23 NYCRR § 200.16, and a comprehensive

business continuity and disaster recovery (“BCDR”) policy, see 23 NYCRR § 200.17; and

ensure that consumers are fully informed as to all aspects of the transactions they enter into, see

23 NYCRR § 200.19.

                                                 4
       Events at Issue

       Background

       8.      Block is a Delaware corporation that, through its various lines of business, offers

an array of financial services and products designed to help both businesses and individual

consumers store, receive, spend, and invest their money. Block is licensed by the Department to

engage in the business of money transmission and VCBA in the State of New York.

       9.      The Department, through reviews conducted during both the MT Exam and the

VC Exam, as well as during the enforcement investigation, determined that Block failed to

maintain a compliant and effective AML program, as well as failed to comply with other critical

requirements contained in the Superintendent’s Money Transmitter and Virtual Currency

Regulations.

       10.     The policies, procedures, and processes at Block did not keep pace with the

significant growth the Company experienced immediately prior to and during the period covered

by the MT Exam and VC Exam, resulting in Block’s inability to fully comply with its obligation

to effectively monitor, and thereafter report, the transactions being conducted on its platforms for

suspected money laundering and other illicit criminal activity.

       Deficiencies in Block’s Anti-Money Laundering Program

       11.     Section 417.2 of the Superintendent’s Regulations requires that each licensee

establish and maintain an AML program that complies with applicable federal laws and

regulation. Federal regulation dictates that money services businesses, such as Block, must

develop an effective AML program “that is reasonably designed to prevent the money services

business from being used to facilitate money laundering and the financing of terrorist activities.”

31 CFR § 1022.210(a). This requirement is reiterated for BitLicensees in the Virtual Currency

                                                 5
Regulation which requires that a licensee’s AML program “provide for a system of internal

controls, policies, and procedures designed to ensure ongoing compliance with all applicable

anti-money laundering laws, rules, and regulations.” 23 NYCRR § 200.15(c)(1). Importantly, the

Virtual Currency Regulation also requires that licensees “monitor for transactions that might

signify money laundering, tax evasion, or other illegal activity.” 23 NYCRR § 200.15(e)(3).

       12.     The AML program run by Block, which governs both fiat and Bitcoin

transactions on the Cash App platform, failed to adequately consider the substantial risks posed

to an entity of its new size and complexity. This is demonstrated by the suspicious activity alert

backlog Block maintained for an extended period of time which delayed the filing of suspicious

activity reports (“SARs”) and action against potential suspicious activity, insufficient screenings

as required for OFAC compliance, and shortcomings in its KYC and Consumer Due Diligence

(“CDD”) practices, among other things.

       Backlog in SAR Filings and Transaction Monitoring Alerts

       13.     Between 2018 and 2021, Block experienced a significant transaction monitoring

alerts backlog. In 2018, Block had accumulated a transaction monitoring backlog of

approximately 18,000 alerts, which grew to over 169,000 by 2020. This extensive backlog was

caused, in part, by Block’s inability to predict the impact of Cash App’s growing customer base

on alert volumes and staffing needs, as well as the increase in alerts generated by the

implementation of new transaction monitoring tools.

       14.     The backlog of alerts waiting to be processed caused an unacceptable number of

days to elapse between the filed SARs’ last transaction date and the report filing dates. Block’s

procedures for investigating and reporting suspicious activity require analysts to review an alert

                                                 6
and document a recommendation to file or not file a SAR within sixty days after an alert is

generated.

          15.    A review conducted by the Department revealed that between February 2021 and

September 2022 SARs, for both Bitcoin and fiat transactions, were at times filed over a year after

the alerts were first generated. The average number of days between the date of the transaction

monitoring alert and the SAR filing was 129 days. The average number of days between the date

of the transaction monitoring alert and the start of a case investigation was 70 days, which

further delayed Block’s reporting of suspicious activity.

          16.    The backlog and delays in processing transaction alerts allowed potential

suspicious, and illicit activity to continue on Block’s platforms unaddressed for an extended

period.

          Transaction Monitoring Failures

          17.    Pursuant to both Part 417 and Part 200, licensees are required to implement risk-

based policies and procedures to ensure compliance with the requirements and regulations of

OFAC. OFAC rules and regulations are designed to ensure that licensed entities are not engaging

in transactions with sanctioned entities or individuals.

          18.    Specifically, Section 417.2(c) of the Money Transmitter Regulation and Section

200.15(i) of the Virtual Currency Regulation require that each licensee implement risk-based

policies, procedures, and practices to ensure compliance with OFAC regulations.

          19.    Block utilized information from two vendors to block and alert transactions with

exposure to terrorism associated wallets. The Department’s investigation revealed that, with

respect to one of the vendors, Block’s system did not generate alerts on Bitcoin transactions until

the recipient’s wallet had more than 1% exposure to terrorism-connected wallets, and Block did

                                                  7
not automatically block transactions to wallets with exposure to terrorism-connected wallets until

the exposure exceeded 10%. Any amount of funds transferred to terrorism-connected wallets is

illegal and setting threshold alerts above 0% without a risk-based analysis supporting that

decision, falls short of the regulatory requirement that licensees implement risk-based policies,

procedures, and practices to ensure compliance with BSA and OFAC regulations.

       20.     The Department also determined that existing service providers and employees

were not subject to subsequent screening against updated OFAC sanctions listings. In 2021,

Block also reported fifteen rejected Bitcoin transactions late with OFAC during the examination

period in violation of 31 CFR § 501.604(c). Further, prior to 2023, Block did not conduct OFAC

screening for restricted accounts, which transact in fiat and are subject to certain dollar-amount

thresholds.

       21.     Contributing to Block’s failure to effectively monitor Bitcoin transactions for

sanctioned counterparties, money laundering, and other potential illicit activity risks in violation

of Section 200.15(e)(3) of the Virtual Currency Regulation, was Block’s deficient monitoring

and risk rating of transactions that used anonymizing services aka “mixers,” a type of service that

obfuscates the source, destination and/or amount involved by combining different users assets in

an intermediary wallet. The untraceable and anonymous features of “mixers” makes them highly

susceptible to abuse by criminal and sanctioned actors, that pose a threat to National Security.

       22.     The Department issued guidance on April 28, 2022, in which it identified mixers

as a typology virtual currency licensees should be considering when evaluating their transaction

monitoring risk. Specifically, the Department’s guidance states that “it is important that VC

Entities evidence appropriately tailored transaction monitoring coverage against applicable

typologies and red flags, identify deviations from the profile of a customer’s intended purposes,

                                                 8
and address other risk considerations as applicable. Relevant typologies related to virtual

currency business activity include but are not limited to: assessing whether a virtual currency (1)

has substantial exposure to a high-risk or sanctioned jurisdiction; (2) is processed through a

mixer or tumbler; (3) is sent to or from darknet markets; (4) is associated with

scams/ransomware; and (5) is associated with other illicit activity relevant to the VC Entity’s

business model.”1

          23.      The use of mixers allows criminal actors to purchase illicit items on the

“darkweb,” including drugs, contraband, child sex-abuse material, and other illegal items with

little risk of detection. It allows a sender to obscure the ultimate destination of funds, which

could end up in the hands of terrorist organizations or sanctioned parties.

          24.      Despite the Department highlighting the elevated risk of these wallets, Block

risk rated transactions identified as having exposure to mixers as “medium” risk, rather than the

“high” risk rating that is appropriate.

          KYC/CDD Deficiencies

          25.      A core tenet of an effective AML program is the adoption of a risk based and

robust KYC/CDD policies and procedures. Both the Virtual Currency and Money Transmitter

regulations require licensees to maintain effective processes and controls to identify and

understand the nature and purpose of customer relationships to mitigate the risks related to

money laundering and other criminal activity. See 3 NYCRR § 417.2(a)(1)(i)(A) and 23 NYCRR

§ 200.15(h).

          26.      The Department’s investigation identified several deficiencies in Block’s

KYC/CDD program. For example, Block did not have a formal KYC refresh process to identify

1
    https://www.dfs.ny.gov/industry_guidance/industry_letters/il20220428_guidance_use_blockchain_analytics

                                                        9
changes to a customer’s initial KYC information and apply those changes to review and update a

customer’s risk rating. Further, customers opened multiple accounts using different email

addresses and phone numbers, thereby bypassing the transaction limits Block places on certain

accounts or individuals.

       27.     Of particular concern was Block’s oversight of Cash App “restricted” accounts.

Cash App restricted accounts are only permitted to transact in fiat under a certain limit and do

not require the customer to pass full Identity Verification (“IDV”). Block did not prohibit

opening of restricted Cash App accounts that shared attributes such as an email, phone number,

device, and/or financial instrument with customers that were denylisted for being the subject of a

SAR. This allowed bad actors to re-enter Block’s platform. During the exam period, Block

imposed a transaction limit of $1,000 in a rolling 30-day period for each individual Cash App

(fiat only) restricted accounts that used the same linked financial instrument. However, the

monetary limit, without the limit on the number of accounts that could be opened, did not

constitute an effective control, as individuals could have created multiple restricted accounts

using multiple financial instruments, thereby circumventing the transaction limits. For example,

a SAR was filed for $1.6 million with 91 subjects that were holders of 16,811 accounts with

19,518 transactions.

       28.     As part of a 2022 internal investigation, Block self-identified over 8,000 accounts

linked to a Russian criminal network. The Department acknowledges the immediate action Block

took in response to this issue, which included filing SARs, closing and denylisting the accounts,

and implementing new controls. However, this discovery further highlights the gaps in Block’s

KYC and on-boarding practices. The approximately 25-30 subjects involved in the Russian

                                                10
criminal network were able to open 8,359 Cash App accounts using falsified information, auto-

generated email addresses and phone numbers before the conduct was detected by Block.

           Cybersecurity Deficiencies

           29.     Cash App operates in an entirely virtual environment and collects non-public

information (“NPI”) for each of its approximately 54 million2 monthly transacting active

accounts, in addition to any new and inactive users registered on the platform. As such, it is

critical that Block maintain a robust cybersecurity program to protect its own information

systems and the consumer NPI stored in them. Management oversight, as well as ensuring that

all cybersecurity policies are sufficient and robust are critical components of the cybersecurity

requirements contained in both the Virtual Currency Regulation and the Cybersecurity

Regulations (23 NYCRR Part 500).

           30.     Notwithstanding these regulatory requirements, the Department’s examinations

and enforcement investigation revealed certain compliance failures within Block’s cybersecurity

program.

           31.     Initially, the Department’s investigation revealed that Block’s Information

Security Policy(“ISP”), as well as other policies that make up the Company’s cybersecurity

program were not subject to annual board review and approval, as required by 23 NYCRR §

200.16(b) until October 26, 2023. Instead, ISP review was delegated to Block’s Chief

Information Security Officer (“CISO”), which falls short of the requirement in Section 200.16(b)

that the licensee’s cybersecurity policy “be reviewed and approved by the Licensee’s board of

directors or equivalent governing body at least annually.” 23 NYCRR § 200.16(b). The

2
    Estimate as of June 2023.

                                                   11
Department further determined that Block’s cybersecurity policy failed to address capacity and

performance planning as required by 23 NYCRR § 200.16(b)(5).

       32.     Block also failed to maintain a compliant Business Continuity and Disaster

Recovery (“BCDR”) plan. Block’s BCDR plan was narrow, addressing only the Company’s

pandemic response plan and one additional scenario. Section 200.17(a) of the Virtual Currency

Regulation requires that a licensee’s BCDR plan address the documents, data, facilities,

infrastructure, personnel, and competencies essential to the continued operation of the

Company’s business, the procedures for back up of documents and data essential to the

operations of the Company and storing of information offsite, and identification of the third

parties necessary for the continued operations of the Company’s business. 23 NYCRR §

200.17(a). Though product-level teams at Block undertook business continuity processes, this

was not reflected in a companywide BCDR plan that complied with the regulation.

       33.     Moreover, while Block did conduct testing of its BCDR plan on an annual basis,

the Department found no evidence that the tests were observed by qualified internal personnel or

qualified third parties, in violation of 23 NYCRR § 200.17(e).

       Consumer Protection Deficiencies

       34.     The Department’s regulations require certain disclosures to be made at various

points for both Bitcoin and fiat transactions. The Department concluded that while all disclosures

required for virtual currency transactions pursuant to 23 NYCRR § 200.19(a) were present,

Block failed to present those disclosures to the consumer in “clear, conspicuous, and legible

writing.” Instead, the required disclosures were disseminated between various pages of the Cash

App Terms of Service document.

                                                12
       35.     With respect to receipts provided for fiat transactions from a customer’s stored

balance, Block failed to provide receipts containing the Company’s refund policy or a statement

of liability for non-delivery or delayed delivery as required by 3 NYCCRR § 406.3(f).

Violations of Law and Regulations

       36.     Block failed to maintain an effective and compliant anti-money laundering

program in violation of 23 NYCRR § 200.15 and 3 NYCRR § 417.2.

       37.     Block failed to obtain annual approval of its cybersecurity policy by its board of

directors, in violation of 23 NYCRR § 200.16(b).

       38.     Block failed to maintain an adequate business continuity and disaster recovery

policy and ensure independent testing of its business continuity and disaster recovery policy, in

violation of 23 NYCRR § 200.17.

       39.     Block failed to provide required disclosures of the risks of virtual currency

transactions in a clear and conspicuous manner, in violation of 23 NYCRR § 200.19(a).

       40.     Block failed to provide required disclosures on receipts for money transmission

transactions, in violation of 3 NYCRR § 406.3(f).

       NOW THEREFORE, to resolve this matter without further proceedings, the Department

and the Company stipulate and agree to the following terms and conditions:

                                SETTLEMENT PROVISIONS

       Monetary Penalty

       41.     No later than ten (10) days after the Effective Date (as defined below) of this

Consent Order, the Company shall pay a total civil monetary penalty pursuant to NYBL §

44(1)(c) to the Department in the amount of Forty Million Dollars and 00/100 Cents

                                                13
($40,000,000). The payment shall be in the form of a wire transfer in accordance with

instructions provided by the Department.

        42.     The Company shall not claim, assert, or apply for a tax deduction or tax credit

with regard to any U.S. federal, state, or local tax, directly or indirectly, for any portion of the

civil monetary penalty paid pursuant to this Consent Order.

        43.     The Company shall neither seek nor accept, directly or indirectly, reimbursement

or indemnification with respect to payment of the penalty amount, including but not limited to,

payment made pursuant to any insurance policy.

        44.     In assessing a penalty for the failures alleged in this Consent Order, the

Department has taken into account factors that include, without limitation: the extent to which

the entity has cooperated with the Department in the investigation of such conduct, the gravity of

the violations, and such other matters as justice and the public interest may require.

        45.     The Department acknowledges Block’s cooperation throughout this investigation.

The Department also recognizes and credits Block’s ongoing efforts to remediate the

shortcomings identified in this Consent Order. Among other things, Block has demonstrated its

commitment to remediation by devoting significant financial and other resources to resolving

backlogs and mitigating the risk of future backlogs, increasing compliance staffing resources,

limiting the number of accounts a customer can create, implementing additional controls to better

prevent bad actors from accessing or returning to the platform, and updating its BSA/AML and

OFAC compliance practices.

        Independent Monitor

        46.     The Company agrees to engage the services of an Independent Monitor selected

by the Department for a period of twelve (12) months following the execution of this Consent

                                                  14
Order, extendable by the Department in its sole regulatory discretion. The primary objective of

the engagement of the Independent Monitor is to inform and enhance the Company’s efforts to

remediate any deficiencies in the Company’s compliance programs.

       47.      The Independent Monitor shall base its monitoring on the findings and violations

contained in this Consent Order.

             a. The Independent Monitor will report to the Department and will: (i) commence a

                comprehensive review of the effectiveness of Block’s BSA/AML and Sanctions

                programs, which will primarily focus on Block’s current programs (the

                “Compliance Review”); (ii) prepare a written report of findings, conclusions, and

                recommendations (the “Compliance Report”); and (iii) oversee remedial measures

                (“Remediation”), as deemed appropriate between the Monitor and the

                Department. The Compliance Review and Compliance Report will, at a

                minimum, address and include:

                    i. A comprehensive, risk-based assessment of Block’s compliance with the

                        Virtual Currency Regulation, Money Transmitter Regulation, and Part 504

                        of the Superintendent’s Regulations (the “Transaction Monitoring

                        Regulation”);

                    ii. A review of Block’s suspicious activity identification, investigation,

                        escalation, tracking, documentation, and reporting procedures to determine

                        whether Block is meeting its suspicious activity reporting requirements

                        pursuant to 23 NYCRR § 200.15, 3 NYCRR § 417.2, and 3 NYCRR §

                        504.3;

                                                 15
                 iii. A review of the adequacy of any planned or implemented corrective

                      measures to prevent the types of historical transaction monitoring alert

                      backlogs referenced in the Consent Order;

                  iv. A review of a sample, based on the Independent Monitor’s expertise, of

                      Block’s transaction activity to determine whether transactions inconsistent

                      with or in violation of applicable OFAC regulations or suspicious activity

                      involving high-risk customers or transactions involving possible money

                      laundering, terrorist financing, or other illicit financial activity at, by, or

                      through Block were properly identified and reported in accordance to the

                      relevant OFAC regulations, suspicious activity regulations, and New York

                      State law. Nothing herein shall limit the Independent Monitor’s ability to

                      access any transactions it deems appropriate; and

                  v. A review of Block’s Blockchain Analytics Transaction Monitoring (TM)

                      Program to determine whether Block is in compliance with state and

                      federal BSA/AML and OFAC regulations, Part 504 of the

                      Superintendent’s Regulations (“Transaction Monitoring Regulations”) and

                      the Department’s April 28, 2022 “Guidance on Use of Blockchain

                      Analytics.”

       48.     The Independent Monitor shall, as it deems necessary, have system access to all

historical data and transactions at the Company from January 1, 2021, to the present.

       49.     The specific work to be performed by the Independent Monitor described herein

will be established through discussions with the Department and may be updated, in the

                                                 16
Department’s sole regulatory discretion, after consultation with the Company and the

Independent Monitor, as the engagement progresses, and additional information is obtained.

       50.     The Independent Monitor’s report to the Department will summarize the

remediation efforts completed and provide a further evaluation of the Company’s compliance

program, including recommendations for additional remediation that remains necessary, if any.

       Full and Complete Cooperation

       51.     The Company commits and agrees that it will fully cooperate with the Department

regarding all terms of this Consent Order.

       Further Action by the Department

       52.     No further action will be taken by the Department against the Company or its

successors for the conduct set forth in this Consent Order, or in connection with the remediation

set forth in this Consent Order, provided that the Company fully complies with the terms of the

Consent Order.

       Waiver of Rights

       53.     The Company submits to the authority of the Superintendent to effectuate this

Consent Order.

       54.     The parties understand and agree that no provision of this Consent Order is

subject to review in any court, tribunal, or agency outside of the Department.

       Parties Bound by the Consent Order

       55.     This Consent Order is binding on the Department and the Company, as well as

any successors and assigns. This Consent Order does not bind any federal or other state agency

or any law enforcement authority.

                                                17
       Breach of Consent Order

       56.      In the event that the Department believes the Company to be in material breach of

the Consent Order, the Department will provide written notice to the Company, and the

Company must, within ten (10) days of receiving such notice, or on a later date if so determined

in the Department’s sole discretion, appear before the Department to demonstrate that no

material breach has occurred or, to the extent pertinent, that the breach is not material or has

been cured.

       57.      The Company understands and agrees that its failure to make the required

showing within the designated time period shall be presumptive evidence of the Company’s

breach. Upon a finding that a breach of this Consent Order has occurred, the Department has all

the remedies available to it under New York Banking Law and New York Financial Services

Law, and any other applicable laws, and may use any evidence available to the Department in

any ensuing hearings, notices, or orders.

       Notices

       58.      All notices or communications regarding this Consent Order shall be sent to:

       For the Department:

             Ndidi C. Obicheta
             Senior Assistant Deputy Superintendent
             Consumer Protection and Financial Enforcement Division
             One State Street
             20th Floor
             New York, NY 10004

             Joseph C. Mineo
             Assistant Deputy Superintendent
             Consumer Protection and Financial Enforcement Division
             One Commerce Plaza
             20th Floor
             Albany, NY 12257

                                                 18
       For Block, Inc. and Block of Delaware:
             Chrysty Esperanza
             Counsel Lead
             1955 Broadway, Suite 600
             Oakland, CA 94612

             Roberto J. Gonzalez
             Paul, Weiss, Rifkind, Wharton & Garrison LLP
             2001 K St NW
             Washington, DC 20006

       Miscellaneous

       59.      This Consent Order and any dispute thereunder shall be governed by the laws of

the State of New York without regard to any conflicts of laws principles.

       60.      This Consent Order may not be altered, modified, or changed unless in writing

and signed by the parties hereto.

       61.      This Consent Order constitutes the entire agreement between the Department and

the Company and supersedes any prior communication, understanding, or agreement, whether

written or oral, concerning the subject matter of this Consent Order.

       62.      Each provision of this Consent Order shall remain effective and enforceable

against the Company, its successors, and assigns, until stayed, modified, suspended, or

terminated by the Department.

       63.      In the event that one or more provisions contained in this Consent Order shall for

any reason be held to be invalid, illegal, or unenforceable in any respect, such invalidity,

illegality, or unenforceability shall not affect any other provision of this Consent Order.

       64.      No promise, assurance, representation, or understanding other than those

contained in this Consent Order has been made to induce any party to agree to the provisions of

this Consent Order.

                                                 19
       65.     Nothing in this Consent Order shall be construed to prevent any consumer or any

other third party from pursuing any right or remedy at law.

       66.     This Consent Order may be executed in one or more counterparts and shall

become effective when such counterparts have been signed by each of the parties hereto (the

“Effective Date”).

                         [remainder of this page intentionally left blank]

                                                20
       IN WITNESS WHEREOF, the parties have caused this Consent Order to be signed on

the dates set forth below.

 NEW YORK STATE DEPARTMENT OF                          BLOCK, INC.
 FINANCIAL SERVICES                                    BLOCK OF DELAWARE

 By: /s/ Ndidi C. Obicheta                             By: /s/ Jack Dorsey
     NDIDI C. OBICHETA                                     JACK DORSEY
 Senior Assistant Deputy Superintendent                Principal Executive Officer
 Consumer Protection and Financial
 Enforcement                                           April 7, 2025

 April 7, 2025

 By: /s/ Madeline W. Murphy
    MADELINE W. MURPHY
 Deputy Director of Enforcement
 Consumer Protection and Financial
 Enforcement

 April 8, 2025

 By: /s/ Christopher B. Mulvihill
    CHRISTOPHER B. MULVIHILL
 Deputy Superintendent
 Consumer Protection and Financial
 Enforcement

 April 8, 2025

THE FOREGOING IS HEREBY APPROVED. IT IS SO ORDERED.

/s/ Adrienne A. Harris
ADRIENNE A. HARRIS
Superintendent of Financial Services
April 10, 2025

                                           21