It’s Time to TAKE IT DOWN.

The creation, dissemination, and promotion of non-consensual intimate imagery (NCII) content has emerged as both an urgent and underreported harm area, thriving in the current digital age. With 90% of victim-survivors estimated to be women, NCII now spans the gamification of gender-based harm and the scaled online embodiment of sexual abuse, sextortion, intimate partner violence, and stalking.   

NCII comprises a range of content types, victimizing both minors and adults, including real-life assault, secretly recorded material, stalking-related content, leaked, hacked or stolen media, non-visual intimate violations, and now, synthetic content. 

“Synthetic” or AI-generated NCII introduces an additional and rapidly evolving dimension to this area of harm. Advances in generative AI have dramatically increased the scale, accessibility, and speed at which non-consensual intimate content can be created and distributed online.

In Alice’s research on the topic, we identified a 1,833% increase in upload volumes across synthetic NCII websites since 2021, reflecting the rapid commercialization and adoption of these ecosystems. These findings align with broader industry estimates suggesting that 96%–98% of deepfake abuse is linked to NCII. Today, bad actors can generate highly realistic synthetic intimate content at scale, often using only a single image to create non-consensual AI-generated material.

In an attempt to tackle the widespread proliferation of such harms, the US signed the “Tools to Address Known Exploitation by Immobilizing Technological Deepfakes on Websites and Networks” Act, better known as the TAKE IT DOWN Act, into federal law. 

Mitigating the Deepfake Crisis - The TAKE IT DOWN Act

The TAKE IT DOWN Act prohibits the online publication of authentic and synthetic NCII of minors and adults, outlining provisions for both online platforms, victim-survivors, and penalties for perpetrators. 

Online Platforms 

An online platform is classified in the Act as a public website, online service, or application that provides a forum for user-generated content. 

Now, online platforms are required to:

• Remove reported NCII within 48 hours of notification 
• Prevent reuploads of NCII by making “reasonable effort” to identify and remove duplicates of NCII content.  

A failure to comply will be seen as an infringement of the Federal Trade Commission (FTC) Act, resulting in civil penalties of up to approximately $51,000 per violation.
Interpreted broadly, platforms could face cumulative fines for unresolved reports.

Victim-Survivors

The TAKE IT DOWN Act aims to remove friction in reporting for victim-survivors of NCII. 

To submit a valid removal request, they must include at a minimum:

• A statement of non-consent of the victim-survivor (not malicious intent of the perpetrator) 
• Proof and confirmation of identity between the victim-survivor and the NCII content
• URLs or screenshots of the NCII content online

Perpetrators

The TAKE IT DOWN Act enacts criminal liability for the circulation, or threat of circulation, of NCII. 

Perpetrators face penalties including:

• Up to two years imprisonment for adult NCII
• Up to three years concerning minor NCII

Understanding the Deepfake Crisis - The Business Model 

Build a tool. Generate a deepfake. Sell the deepfake. Repeat. 

With the growth of AI-generated NCII, comes the establishment of self-sustaining business models, with bad actors profiting across the spectrum of AI sexualization. 

Whether it’s the more innocuous end of the spectrum (AI hugging and dancing), the AI intimacy ecosystem (AI influencers, and AI companions), or AI nudification (AI faceswapping and AI undressing, and concerningly, AI child sexual abuse material), the TAKE IT DOWN Act reaffirms that the generation of deepfakes without consent, is NCII. 

The democratization of AI tooling has emboldened a spectrum of bad actors, from peer-reinforcement, to abusers and organized AI pimping networks, to industrialize the production of synthetic NCII. By leveraging AI to generate, automate and scale violations, these malicious actors are scaling abuse for commercial gain, driving an unprecedented surge in the volume of synthetic intimate content saturating the digital landscape.

In particular, the proliferation of the synthetic NCII ecosystem is fueled by the emergence and misuse of AI tooling, and dedicated ‘nudify’ bots, apps and websites. By lowering the barrier to entry, often requiring nothing more than a single image, these tools have transformed the production of synthetic NCII into a highly lucrative and decentralized business model. This is a business model where all online actors are implicated - from synthetic NCII production, promotion, distribution, and monetization.

Combating the Deepfake Crisis - Proactive Solutions

The exponential growth of this harm area, coupled with landmark legislation lead to one conclusion: it’s time to take it down.

To meaningfully disrupt the synthetic NCII business model, we must adopt a 360-degree approach that combats generation and proliferation across all misused platforms and services. Fragmented, siloed efforts, where AI, trust, and safety teams operate in isolation, simply cannot keep pace with a self-sustaining ecosystem driven by commercial incentives and multi-platform infrastructure spanning multiple geographies.

To disrupt NCII, ensure compliance with the TAKE IT DOWN Act, and protect users, Alice deploys an enforcement-first suite of proactive solutions infused with deep subject-matter expertise designed to accelerate NCII mitigation, detection, and responsive action:

• Robust AI red-teaming and comprehensive platform stress-testing to identify vulnerabilities
• Scaled detection and collection of NCII content across the digital landscape
• High-fidelity identification of multi-modal textual, audio, and visual signals associated with harm
• Granular benchmarking and analysis to expose critical policy and enforcement gaps
• Pre-emptive mapping of offender networks, evolving tactics, and sophisticated evasion techniques.

If you’d like to learn more about AI nudification and the synthetic NCII ecosystem, read Kavya and Cassidy’s full report here, drawn from an analysis of 100 nudification tools.