Litigation and Regulatory Matters

The Company is currently subject to, and may in the future be involved in, various litigation matters, legal claims, investigations, and regulatory proceedings.

Regulatory and Governmental Matters

In July 2026, the Company entered into a resolution with Attorneys General from multiple states to settle for an immaterial amount claims related to, among other things, Cash App’s handling of customer complaints and disputes.

The Company also received inquiries from the SEC and Department of Justice ("DOJ") shortly after the publication of a short seller report in March 2023. In July 2024, the Company received a follow-on inquiry from the SEC. These inquiries primarily relate to the allegations raised in the short seller report, the Company’s compliance and risk practices, and related disclosures. In March 2026, the SEC staff notified the Company that it had concluded its investigation and did not intend to recommend an enforcement action against the Company.

In March 2026, the DOJ presented the Company with potential terms for resolving its inquiry. In October 2026, the Company and the DOJ reached an agreement in principle to resolve the matter pursuant to a deferred prosecution agreement ("DPA"), under which 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. 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 under the agreement. The DPA is expected to set forth a gross monetary component of approximately $964 million and require a net monetary payment of approximately $764 million based on credit for prior regulatory resolutions.

The resolution remains subject to reaching a final agreement satisfactory to all parties and court approval. The Company has accrued $764 million for this matter as of September 30, 2026.

The Company cannot provide any assurance that a final agreement will be reached on the terms described above or at all, or that the DOJ will not ultimately take legal action against the Company should the parties not finalize a resolution. If the DOJ were to determine during the term of a final DPA that the Company had violated its obligations, the Company could be subject to prosecution on the deferred charge. The Company cannot predict the final terms of the resolution, and it is reasonably possible that those terms could result in losses in excess of the amount accrued. The Company cannot provide any assurance that the ultimate resolution will not have a material adverse effect on the Company.