Block, the payments company behind Cash App and Square, said in its third-quarter Form 10-Q filed November 3 that it reached an agreement in principle with the US Department of Justice in October over an allegation that it failed to maintain an effective anti-money-laundering programme under the Bank Secrecy Act.
The contemplated deferred prosecution agreement outlines a gross monetary component of roughly $964 million, which would be reduced to an expected net payment of approximately $764 million after credits related to earlier regulatory resolutions, according to the filing. Block said it accrued the latter amount as of September 30, 2026.
Proposed terms and conditions
Under the contemplated arrangement, prosecutors would defer the relevant charge for three years. If Block fully complied with the obligations in a final agreement over that term, the DOJ would seek dismissal of the deferred charge.
The company explicitly stated that the resolution is subject to a satisfactory final agreement and judicial approval. It also cautioned that it cannot guarantee the parties will reach final terms and that losses could exceed what it has accrued.
An agreement in principle is not the same as a completed final settlement or a judicial finding that every allegation has been resolved.
Why Cash App’s scale raises the stakes
Block is best known for the Cash App and Square ecosystems. Cash App users can interact with bitcoin, but the company also provides payments, cards, lending and other financial tools. A breakdown in monitoring or due diligence controls can affect far more than a narrow crypto trading product.
The DOJ inquiry is connected to questions raised about the company’s compliance and risk practices following allegations aired in 2023. Block’s filing notes that a separate Securities and Exchange Commission investigation ended in March 2026 without a recommendation for enforcement action. The end of that separate inquiry should not be confused with the Justice Department’s proposed criminal resolution.
A bigger issue than one legal charge
For a payments business, suspicious-activity monitoring, customer identification and escalation procedures must operate consistently at large scale. Even when individual transactions are small, the number of users and transfers can create a major supervisory challenge.
There is also an important distinction between financial penalties and technology investment. Paying a fine or reaching a deferred prosecution agreement does not by itself prove that controls have been fixed. Regulators and customers will look for the systems, staffing and governance needed to prevent a repeat.
The next step is whether Block and the DOJ complete a final agreement on the announced terms, including any independent monitoring or compliance obligations. Until then, the $764 million figure is the company’s expected net payment under a proposed resolution, not evidence that the case is fully closed.
