The Take It Down Act: A landmark step
On May 19, 2025, US President Donald Trump signed the Take It Down Act into law, creating the first federal criminal penalties for distributing non-consensual explicit imagery. This includes artificial intelligence (AI)-generated deepfakes, which can be used for sextortion, and revenge porn.
The law mandates swift content takedowns by online platforms and empowers the Federal Trade Commission to enforce compliance. It reflects growing bipartisan recognition that generative AI (genAI) has amplified the scale and severity of digital abuse, particularly against women and minors.
The role of cryptocurrency in sextortion
Sextortion, in its current form, increasingly involves bad actors using AI-generated explicit images or videos to coerce victims — often adolescents, women, or public figures — into paying to avoid public exposure. These schemes can begin with cybercriminals scraping victims’ photos from social media, then using AI tools to process them and fabricate convincing, though false, intimate content. The bad actors then threaten to publicly share the content unless victims pay a ransom, often in cryptocurrency.
The payments are often fragmented and structured to avoid detection. Addresses associated with known sextortion rings can exhibit patterns — multiple incoming payments in small denominations, followed by rapid outbound transfers.
In some cases, TRM has observed ransom payments sent to addresses with limited obfuscation — including two that led directly to centralized exchange deposit addresses, and a third that was only two hops away. This pattern suggests that some sextortion scams are operationally simple and may offer clear, actionable leads for investigators. Rather than relying on advanced laundering techniques, these schemes often prioritize speed and accessibility, creating opportunities for early intervention at key financial exit points. This underscores the importance of timely reporting and strong compliance protocols at virtual asset service providers (VASPs).
How romance scams and sextortion intersect
TRM has found that many sextortion incidents are scams in which perpetrators pose as romantic partners to obtain intimate images, later using those images to extort victims. Although most cases to date involve real content shared voluntarily, genAI is lowering the barrier to entry for fabricating convincing explicit imagery, and increasing the potential scale and psychological impact of these schemes. Furthermore, AI is reshaping how abuse is carried out, making scams more scalable, persuasive, and difficult to detect.
Deepfakes and the industrialization of exploitation
As covered in TRM’s AI-enabled fraud report and our TRM Talks episode with Dr. Hany Farid, the combination of genAI and pseudonymous payment systems has industrialized sextortion. Threat actors no longer rely on real content; the line between what is authentic and what is fabricated is increasingly irrelevant. The psychological leverage remains the same, and the resulting financial transactions continue to drive demand.
Groups running these schemes now operate with playbooks. They use scalable AI tools to generate deepfakes, encrypted messaging platforms to distribute threats, and cryptocurrency infrastructure to extract and launder payments. The model is low-cost, high-yield, and resilient — especially when it intersects with cash-out points that do not enforce strong compliance standards such as cryptocurrency platforms with lax or no Know Your Customer (KYC) standards.
How the act aims to help victims take back control
The Take It Down Act marks a significant shift in how victims can assert control over nonconsensual explicit imagery. Crucially, it removes the need to prove a victim’s age — now, any individual can request takedown of content simply by affirming that it was shared without consent. This lowers the barrier for legal recourse and could increase pressure on major adult content platforms, especially as cases like the ongoing lawsuit against Pornhub draw attention to systemic failures in consent verification. However, there are still challenges: victims need to locate the content online, and when AI-generated media is involved, legal action may hinge on whether the imagery is both convincing and clearly tied to an identifiable individual.
The need for complementary action
The Take It Down Act directly targets the dissemination of harmful content and creates new legal tools to hold perpetrators accountable. However, addressing the financial dimension of sextortion will require coordinated, sustained efforts from law enforcement and the private sector.
Law enforcement agencies must be equipped with the capacity and technical support to trace ransom payments, intervene early in laundering pathways, and coordinate across jurisdictions. At the same time, VASPs — particularly those functioning as cash-out nodes — must implement and enforce robust compliance programs. That includes customer due diligence, transaction monitoring, and proactive engagement with investigators when red flags emerge.
Compliance and enforcement at these financial exit points are essential to disrupting the profitability of these schemes. While content takedowns are critical to victim protection, long-term deterrence depends on disabling the monetization infrastructure that sustains the abuse.
Conclusion
The Act represents a significant step forward in combating the spread of nonconsensual explicit material, particularly as new technologies amplify both the scale and sophistication of these attacks. But sextortion is not only a content problem; it is also a financial crime.
Addressing this threat effectively will require more than legislation. It will demand collaboration across the digital asset ecosystem — between regulators, compliance teams, law enforcement, and blockchain intelligence firms — to track illicit flows, identify actors, and close the financial channels that incentivize abuse.
TRM Labs continues to support those efforts through intelligence, analytics, and investigative support to help protect victims and restore accountability in a rapidly evolving threat landscape.
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