Block, Inc. Settlement Agreement and Consent Order

1 SETTLEMENT AGREEMENT AND CONSENT ORDER BLOCK, INC. The States, listed in “Appendix A” attached to this Settlement Agreement and Consent Order (hereinafter referred to as the “Agreement” or “Order”), individually, a “Participating State,” and collectively, the “Participating States”, have each agreed, through their respective state money transmission regulatory agencies, to negotiate and enter into this Agreement. WHEREAS, Block, Inc. (f/k/a Square, Inc.) (“Block”) is a Delaware corporation with its principal executive office in Oakland, California and assigned NMLS identifier number of 942933. Block is licensed as a money transmitter under the respective laws of each Participating State. Block operates the funds transfer platform called “Cash App.” WHEREAS, the state money transmission regulators of the Participating States (hereinafter referred to individually as a “State Money Transmission Regulator,” and collectively as the “State Money Transmission Regulators”) are respective members of the Conference of State Bank Supervisors (“CSBS”) and/or the Money Transmitter Regulators Association (“MTRA”) and intend to address enforcement concerns with Block in a collective and coordinated manner, working through the Multi-State MSB Examination Taskforce (“MMET”). The State Money Transmission Regulators and Block are collectively referred to herein as the (“Parties”). WHEREAS, on or about May 15, 2023, the State Money Transmission Regulators commenced a multi￾state examination (the “Multi-State Examination”) of Block covering the period of January 1, 2021, through March 31, 2023, to determine Block’s compliance with applicable State and Federal laws and regulations. The Multi-State Examination was conducted by the State Money Transmission Regulators of California, Colorado, Kentucky, Massachusetts, New Hampshire, Ohio, Texas, and Washington. The Multi-State Examination of Block was conducted pursuant to their respective statutory authorities, and in accordance with the protocols established by the Protocol for Performing Multi-State Examinations as well as the Nationwide Cooperative Agreement for MSB Supervision (collectively the “CSBS/MTRA Protocol and Agreement”). The Joint Multi￾State Report of Examination (“ROE”) was issued on November 6, 2023, and identified findings related to the adequacy of Block’s Bank Secrecy Act/Anti-Money Laundering Program (“AML Program”), including certain anti-money laundering matters that have allegedly occurred over this and past examination cycles. On or about December 6, 2023, Block provided its response to the ROE, including a summary of new controls put into place during and following the exam period to enhance its AML Program and further planned enhancements. Block has worked cooperatively with the State Money Transmission Regulators throughout the Multi-State Examination. WHEREAS, Block enters into this Agreement solely for the purpose of resolving disputes with the State Money Transmission Regulators, including concerning the conduct alleged in the ROE. In entering this Agreement, Block neither admits nor denies any wrongdoing, allegations or implications of fact, and neither admits nor denies any violations of applicable laws, regulations, or rules governing the conduct and operation of its money transmission related business, including related to its AML Program. Block acknowledges that the State Money Transmission Regulators have and maintain jurisdiction over the underlying matters, including all matters referred to in these recitals, and therefore have the authority to fully resolve the matter. WHEREAS, the State Money Transmission Regulators have legal authority to initiate administrative actions based on the conduct alleged in the ROE. WHEREAS, the intention of the State Money Transmission Regulators in issuing this Order is to resolve their concerns regarding Block’s AML Program and the violations identified in the ROE and in these recitals, and 


     




    

Docket No. 250003 (BNK-CAO) FILED 2025 JAN 16 PM 2:46 PA DEPARTMENT OF BANKING AND SECURITIES