On Tuesday, March 11, 2025, in the first Senate Judiciary subcommittee hearing of the 119th Congress, the Senate Subcommittee on Crime and Counterterrorism held a hearing entitled “Ending the Scourge: The Need for the STOP CSAM Act.”  Subcommittee Chair Senator Josh Hawley (R-MO), who convened the hearing, and Ranking Member Dick Durbin (D-IL) announced in February that they intended to reintroduce the Strengthening Transparency and Obligations to Protect Children Suffering from Abuse and Mistreatment Act orSTOP CSAM Act”, a comprehensive bill that seeks to combat the online sexual exploitation of children.  First introduced in 2023, the Act did not receive a vote on the Senate floor last Congress, despite being unanimously advanced by the Senate Judiciary Committee. 

The STOP CSAM Act, as written in 2023, contains multiple provisions that would impose new requirements on online platforms.  The Act would:

  • Remove Section 230 immunity for civil claims against online platforms for CSAM-related harms;
  • Create a private right of action for victims to file civil lawsuits against online platforms that fail to timely remove CSAM material;
  • Create a Child Online Protection Board at the Federal Trade Commission that would be responsible for enforcing the removal of CSAM material and related images and authorized to fine platforms that fail to comply;
  • Remove technology companies’ discretion as to whether to report planned or imminent child sexual exploitation offenses of which the provider has actual knowledge;
  • Require that online platforms include certain additional information in NCMEC CyberTipline reports; and
  • Mandate that certain online platforms issue annual transparency reports related to child protection efforts.

The Act would also expand privacy protections and restitution mechanisms for victims of online child sexual abuse.  It would:

  • Create a presumption of keeping protected information under seal when child victims testify in federal court; and
  • Provide the federal judiciary structure and funding to appoint trustees to manage restitution for victims of online sexual abuse.

Because the STOP CSAM Act has not yet been formally introduced, it is unknown if the new version of the bill will differ from the 2023 version. 

Witnesses at the subcommittee hearing included child safety advocates, lobbyists, and a survivor of online child sexual exploitation.  The witnesses expressed support for provisions of the STOP CSAM Act that would require technology companies to include specific information in CyberTipline reports, issue annual transparency reports, and report instances of apparent, planned, or imminent child sexual exploitation crimes.  They also spoke favorably about provisions of the bill concerning court-appointed trustees to manage restitution and the general expansion of civil remedies for victims of online child sexual exploitation. 

During the hearing, Senators Hawley and Durbin emphasized their shared perspective of the urgent need to pass the STOP CSAM Act, given, in their view, the proliferation of online CSAM, the need to give victims improved safeguards and access to the courts, and the lack of accountability from technology companies in preventing CSAM on their platforms.  A common theme of the hearing was the contention that technology companies can and should do more to combat CSAM, with senators and witnesses calling for increased civil liability for platforms and contending that platforms have a responsibility to detect, prevent, and timely report CSAM on their sites.

Online child protection remains a priority this Congress, with renewed interest in both the Kids Online Safety Act (KOSA) and the Children and Teens’ Online Privacy Protection Act (COPPA 2.0).  Last Congress, members from both sides of the aisle and in both chambers expressed concerns that KOSA, COPPA 2.0, and the STOP CSAM Act all had policy issues that still needed to be addressed.  Nonetheless, given renewed interest in the topic, and potential support from the Administration, these bills should continue to be watched closely.

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Photo of Nicholas Xenakis Nicholas Xenakis

Nick Xenakis draws on his Capitol Hill and legal experience to provide public policy and crisis management counsel to clients in a range of industries.

Nick assists clients in developing and implementing policy solutions to litigation and regulatory matters, including on issues involving…

Nick Xenakis draws on his Capitol Hill and legal experience to provide public policy and crisis management counsel to clients in a range of industries.

Nick assists clients in developing and implementing policy solutions to litigation and regulatory matters, including on issues involving antitrust, artificial intelligence, bankruptcy, criminal justice, financial services, immigration, intellectual property, life sciences, national security, and technology. He also represents companies and individuals in investigations before U.S. Senate and House Committees.

Nick previously served as General Counsel for the U.S. Senate Judiciary Committee, where he managed committee staff and directed legislative efforts. He also participated in key judicial and Cabinet confirmations, including of Attorneys General and Supreme Court Justices. Before his time on Capitol Hill, Nick served as an attorney with the Federal Public Defender’s Office for the Eastern District of Virginia.

Photo of Diana Lee Diana Lee

Diana Lee is an associate in the technology regulatory group. She counsels clients on a range of regulatory and litigation matters involving electronic surveillance, government demands for data, national security, and data privacy and cybersecurity issues, with a particular focus on cross-border and…

Diana Lee is an associate in the technology regulatory group. She counsels clients on a range of regulatory and litigation matters involving electronic surveillance, government demands for data, national security, and data privacy and cybersecurity issues, with a particular focus on cross-border and multi-jurisdictional concerns.

Before rejoining the firm, Diana clerked for the Honorable Victor A. Bolden on the U.S. District Court for the District of Connecticut.

Diana is a member of the Bars of New York and the District of Columbia.