Protocols & Policy · Company news
Block books $764 million for proposed Justice Department anti-money-laundering deal
Block, the Cash App owner, said in a quarterly filing that it reached an agreement in principle with the Justice Department over a Bank Secrecy Act charge and accrued $764 million. The deal is not final and needs court approval.
Block books $764 million for proposed Justice Department anti-money-laundering deal
Block, whose two business segments are Square and Cash App, has accrued, or recorded as an expected cost in its accounts, $764 million for a proposed deal with the Justice Department over a charge that it failed to run an effective anti-money-laundering program, according to its quarterly report filed Nov. 3 [1]. Block says the two sides "reached an agreement in principle" in October [1].
The deal is not final. Block's filing says "the resolution remains subject to reaching a final agreement satisfactory to all parties and court approval" [1].
Block says the matter would be resolved through a deferred prosecution agreement, an arrangement in which prosecutors file a charge but agree to drop it if the company meets conditions for a set period. In the filing's words, "the DOJ will defer, for a period of three years, a charge that the Company failed to maintain an effective anti-money laundering program in violation of the Bank Secrecy Act" [1]. The Bank Secrecy Act is the federal law that requires financial companies to run programs to detect and report money laundering. "If the Company fully complies with the obligations to be set forth in the DPA during its three-year term, the DOJ will move to dismiss with prejudice the deferred charges," the filing says, meaning the charge could not be brought again [1].
| Item | Amount | Filing's wording |
|---|---|---|
| Gross monetary component | About $964 million | "expected to set forth a gross monetary component" |
| Credit | About $200 million (Le Coin's subtraction) | "credit for prior regulatory resolutions" |
| Net monetary payment | About $764 million | "require a net monetary payment" |
| Accrued, as of Sept. 30, 2026 | $764 million | "The Company has accrued $764 million for this matter" |
Table: Le Coin. Source: Block Form 10-Q.
The filing traces the matter to inquiries from the Securities and Exchange Commission and the Justice Department "shortly after the publication of a short seller report in March 2023" [1]. Those inquiries "primarily relate to the allegations raised in the short seller report, the Company's compliance and risk practices, and related disclosures," Block says [1]. In March 2026, SEC staff told Block it "did not intend to recommend an enforcement action," and the Justice Department "presented the Company with potential terms," according to the filing [1]. The filing does not say which Justice Department office is handling the matter, and it names the company, not a specific unit, as the party.
Block describes Cash App as including "peer-to-peer payments, bitcoin and stock investments" [1]. The filing does not say the charge involves bitcoin.
The objection
Block's figures are expectations. The company says it "cannot provide any assurance that a final agreement will be reached on the terms described above or at all," and that "it is reasonably possible that those terms could result in losses in excess of the amount accrued" [1]. The filing does not identify which prior resolutions produce the credit, and it does not list the obligations Block would have to meet.
The tell (Le Coin's view)
In Le Coin's view, the number that matters is the one already on the books: Block has accrued the full net figure, $764 million, as of Sept. 30, while the terms that would come with it remain unwritten.
Sources
- Block, Inc., Form 10-Q for the quarter ended Sept. 30, 2026, Note 16, Commitments and Contingencies. https://www.sec.gov/Archives/edgar/data/1512673/000162828026069524/xyz-20260930.htm (accessed 11:28 a.m. ET, Nov. 4, 2026)
- SEC EDGAR, filing index for accession 0001628280-26-069524, accepted 4:16 p.m. ET, Nov. 3, 2026. https://www.sec.gov/Archives/edgar/data/1512673/000162828026069524/0001628280-26-069524-index.htm (accessed 11:28 a.m. ET, Nov. 4, 2026)
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