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Enforcement

FTC Takes Action Against Aylo Over CSAM and Non-Consensual Content on Pornhub

The FTC and Utah jointly acted against Aylo (formerly MindGeek) for distributing tens of thousands of CSAM and non-consensual videos. The $5M settlement requires age/consent verification for all existing content.

What Happened

In September 2025, the Federal Trade Commission and the State of Utah jointly took action against Aylo — the operator of Pornhub, Brazzers, and other adult sites — for deceiving users about its efforts to combat child sexual abuse material (CSAM) and non-consensual content.

The FTC's Findings

The complaint details a pattern spanning more than a decade:

  • Since 2012, Aylo distributed tens of thousands of videos and photos featuring CSAM and non-consensual material
  • Aylo ignored hundreds of thousands of content flags — some explicitly identifying content as CSAM — for years, leaving the material live on its platforms
  • An internal compliance team member reportedly described Pornhub.com as "a goldmine" for "rape content"
  • After Visa and Mastercard threatened to terminate relationships and impose massive fines, Aylo audited its tube sites and found tens of thousands of CSAM and non-consensual videos

Settlement Terms

The settlement requires Aylo to:

  1. Pay a $5 million penalty to the State of Utah
  2. Establish a comprehensive program to prevent distribution of CSAM and non-consensual material, including policies, procedures, and technical measures
  3. Implement a system to verify that all individuals appearing in content are adults and have provided consent to the sexual conduct and its publication
  4. Remove all pre-existing content until age and consent can be verified for each piece

Timeline: From NYT Exposé to Consent Order

DateEvent
December 4, 2020Nicholas Kristof's New York Times investigation documents CSAM on Pornhub
December 2020Visa and Mastercard sever payment processing ties with Pornhub
December 2020Pornhub purges millions of videos from unverified accounts; loses ~1/3 of traffic
August 2022Visa and Mastercard suspend card payments for MindGeek's advertising arm, TrafficJunky
2023Ethical Capital Partners acquires MindGeek; rebrands to Aylo
September 2025FTC and Utah announce settlement
September 2025Federal judge dismisses trafficking claims against Visa as payment processor

What This Means for Platform Operators

This settlement establishes a clear enforcement precedent: retroactive content verification is on the table. Aylo must now verify age and consent for content that has been live for years.

If your platform hosts user-generated adult content without robust verification of both performer age and consent, the FTC has demonstrated it will act — and the remediation costs dwarf what proactive compliance would have cost.

Immediate Steps

  1. Audit your content moderation pipeline. How quickly do flagged items get reviewed? The FTC specifically cited Aylo's failure to act on flags.
  2. Document your consent verification process. Written consent for every piece of content, from every performer, is now the baseline expectation.
  3. Review your 2257 records. If you can't produce age verification records for every performer on demand, you have exposure.
  4. Talk to your acquirer. If they're reading the same news you are, they may be tightening requirements proactively.