INVESTIGATION
How Meta Platforms Ireland Ltd. May Have Violated EU Sanctions and Channeled Money to RT, Sputnik and Other EU-sanctioned Entities via Facebook’s Revenue Redistribution Programs
Facebook pages affiliated with RT, Sputnik and other EU sanctioned entities were among Meta’s active partner-publishers for months after being subject to EU financial sanctions. Some of these partnerships remain active as of June 2025.
Published: 20 June 2025
Over the years, Meta has introduced a variety of ways for content publishers to generate revenue from their Facebook activity. These include revenue redistribution programs such as Facebook Instant Articles (now discontinued), In-stream Video Ads, Ads on Reels, and, most recently, Content Monetization.
Facebook revenue redistribution programs are opt-in business partnerships, which grant participating content publishers a share of Facebook’s ad revenue, as determined by the platform based on various performance metrics.
Participation in revenue redistribution programs involves a page admin filling out an application and signing onto Meta’s monetization terms and policies, and Meta conducting business partner qualification and ongoing eligibility reviews.
Meta regularly discloses lists of its active partner-publishers. The lists are released on a per program basis and include accounts which Meta describes as “publishers that have signed up for monetization and follow our Partner Monetization Policies”.
WHAT TO FIX has been downloading Meta’s partner-publisher lists since October 2019, consolidating a 5 1/2 years archive.
Building on archived disclosures from Meta, we find that:
- Meta has engaged in revenue redistribution partnerships with Russia Today (RT) and Sputnik pages since 2020.
- Meta restricted all Russia Today (RT) and Sputnik Facebook pages from monetizing in the immediate aftermath of Russia’s full-scale invasion of Ukraine.
- Meta re-listed Sputnik pages for revenue redistribution starting in October 2022 and through to October 2023.
- Meta onboarded a whole new RT Arabic Facebook page for revenue redistribution in July 2023. The page remains listed as of June 2025.
- Meta engages in revenue redistribution partnerships with pages affiliated with other entities subject to EU financial sanctions.
- Meta engages in revenue redistribution partnerships with unverified accounts distributing content by Russian outlets subject to EU broadcasting sanctions.
If these revenue redistribution partnerships were found to be managed by Meta Platforms Ireland Ltd. (which we believe is responsible for most if not all partnerships outside North America), it could expose Meta to possible EU sanction violations, which may constitute a criminal offence.
Our findings call for urgent scrutiny into Meta’s revenue redistribution partnerships as well as more regulatory oversight of social media monetization systems and governance practices.
The data – consolidated from Meta’s own partner-publisher disclosures up to 31 May 2025 – can be accessed here.
WHAT TO FIX informed Meta of the report’s findings over a week prior to publication and solicited comments from the company.
Meta did not acknowledge or respond to WHAT TO FIX’s email.
Meta did not acknowledge or respond to WHAT TO FIX’s email.
About Russia Today (RT) And Sputnik
Russia Today (RT) and Sputnik are government-controlled media outlets, infamous for disseminating propaganda and facilitating disinformation campaigns in service of the Russian government’s geopolitical objectives.
In the wake of Russia’s full-scale invasion of Ukraine, the Council of the European Union designated RT and Sputnik as constituting a “significant and direct threat to the Union’s public order and security”.
They, and their respective parent entities – ANO TV-Novosti and MIA Rossiya Segodnya – were subject to broadcasting and financial sanctions.
The European Commission provides guidance on its interpretation of both sets of sanctions in its consolidated FAQs.
♦️ 1 March 2022Broadcasting sanctions were introduced by the EU against RT English, RT UK, RT Germany, RT France, RT Spanish, as well as Sputnik.The broadcasting sanctions mandate a prohibition for operators to “broadcast, or to enable, facilitate or otherwise contribute to broadcast, any content by the legal (...) entities (...), including through transmission or distribution by any means such as cable, satellite, IP-TV, internet service providers, internet video-sharing platforms or applications, whether new or pre-installed.” (Art. 2f.1), as well as a suspension of “any broadcasting licence or authorisation, transmission and distribution arrangement” (Art. 2f.2).♦️ 16 December 2022
ANO TV-Novosti, RT’s parent entity, was added to the list of entities (#158) subject to financial sanctions under EU Council Regulation 269/2014.The financial sanctions mandate the freezing of assets (Art. 2.1) and require that “no funds or economic resources shall be made available, directly or indirectly, to or for the benefit of natural or legal persons, entities or bodies” (Art 2.2).♦️ 25 February 2023
MIA Rossiya Segodnya, Sputnik’s parent entity, was added to the list of entities (#195) subject to financial sanctions under EU Council Regulation 269/2014.The broadcasting sanctions were expanded to RT Arabic and Sputnik Arabic
This investigation sought to answer the following questions:
- Does Meta have a history of redistributing revenue to RT and Sputnik?
- How did Meta adjust its revenue redistribution partnerships in response to the introduction of EU broadcasting and financial sanctions?
Meta has engaged in revenue redistribution partnerships with Russia Today (RT) and Sputnik pages since 2020.
We started our investigation by checking whether Meta had ever engaged in revenue redistribution partnerships with pages affiliated with RT or Sputnik.
We did so by running a combination of keywords and page ID queries into our consolidated archive of Meta’s active partner-publisher lists.
Our investigation uncovered that the following RT and Sputnik pages have a history of monetization on Facebook. Most pages were registered for revenue redistribution prior to Russia’s full-scale invasion of Ukraine and prior to the introduction of EU sanctions, with registrations starting from 2020.
We manually reviewed each of the pages to confirm their authenticity. With the exception of the ‘RT Arabic روسيا اليوم - مصر’ page, which was created after Russia’s full-scale invasion of Ukraine, all the pages were blue tick verified and referenced on official RT and Sputnik websites. All had also been labelled by Facebook as state-controlled media, a process involving additional validation by Facebook.
The authenticity of the pages and their affiliation with RT and Sputnik is further supported by their apparent inclusion under Meta’s global ban of RT and Sputnik. This ban was enacted immediately after the introduction of TV-Novosti and Rossiya Segodnya to the US Office of Foreign Assets Control (OFAC) Specially Designated Nationals List on 13 September 2024.
Meta restricted all RT and Sputnik pages from monetizing in the immediate aftermath of Russia’s full scale invasion of Ukraine.
Using our archive of Meta active partner-publisher disclosures, we recreated the monetization history of the above RT and Sputnik pages from the start of our data collection through to 31 May 2025 (see data → ).
Our review of Meta’s disclosures indicates that all the active RT and Sputnik pages were subject to a coordinated removal from active partner-publisher lists around the time of Russia’s full-scale invasion of Ukraine on 24 February 2022.
The ‘RT’ page was last added onto the Instant Articles partner-publisher list on 19 February 2022. It was removed from the list at some point between the file dated 19 February 2022 and the file dated 26 February 2022.
The ‘Sputnik’, ‘Sputnik France’, ‘Sputnik Italia’ and ‘SNA’ (Sputnik Deutschland) pages were added onto the In-stream video ads partner-publisher list on 16 and 30 November 2021 respectively. They were all removed from the list between the file dated 7 February 2022 and the file dated 26 February 2022.
While we cannot confirm the exact date of demonetization of each page, due to the lack of daily disclosures (see black dots marking the available files for each program), the data points to a coordinated intervention, likely enforced in the immediate aftermath of Russia’s invasion of Ukraine, on 24 or 25 February 2022.
The data further indicates that the pages were demonetized before RT and Sputnik were subject to EU broadcasting sanctions on 1 March 2022, as neither of the pages were listed in the partner-publisher lists for Instant Articles and In-stream video ads dated 26 February 2022 and 1 March 2022.
Meta re-listed Sputnik pages for revenue redistribution starting in October 2022 and through to October 2023.
Our review of Meta’s archived disclosures indicates the re-listing of all of the previously demonetized Sputnik pages starting in October 2022.
‘Sputnik France’ and ‘Sputnik Italia’ were the first pages to be re-listed, starting on 6 October 2022. They were followed by the ‘SNA’ page (Sputnik Deutschland) on 27 October 2022, and the main ‘Sputnik’ page on 10 March 2023.
It is unclear, from the data alone, what triggered the pages’ return to monetization.
The data nonetheless provides valuable insights:
The data nonetheless provides valuable insights:
- The re-listing of Sputnik pages did not take place on the same date for all pages, which suggests that the pages were not subject to an automated timed restriction.
- The Sputnik France, Sputnik Italia and SNA (Deutschland) pages all appeared in the ads-on-reels partner-publisher list, in addition to the in-stream video ad list, when they were first re-listed. This suggests that the re-listing of these pages was not the result of an automated error. Participation into a new program involves a formal onboarding procedure, which would have necessitated active decisions on the part of both a page admin (to apply and sign the monetization terms) and Meta (to review and validate eligibility).
- The Sputnik France, Sputnik Italia and SNA (Deutschland) pages experienced parallel listings and delistings on several occasions. This suggests some degree of admin or payout account overlaps and points to the possible introduction of a new admin or payout account as a factor facilitating the pages’ renewed access to monetization.
Of note is the fact that the revenue redistribution partnerships were restarted with these pages after EU broadcasting sanctions were introduced against Sputnik on 1 March 2022, and continued well after the introduction of EU financial sanctions against Rossiya Segodnya, Sputnik’s parent entity, on 25 February 2023.
Meta onboarded a whole new RT Arabic page for revenue redistribution in July 2023. The Page remains listed as of June 2025.
In addition to re-listing all of the previously demonetized Sputnik pages back into their old monetization programs — and in the cases of the Sputnik France, Italia and SNA (Deutschland) pages, into a new monetization program — our review of Meta’s archived disclosures indicates that Facebook onboarded a new RT page for monetization.
The ‘RT Arabic روسيا اليوم - مصر’ page was created in December 2022. Although it is not blue tick verified, the page was labelled by Facebook as a Russia state-controlled media, confirming Facebook’s awareness of the page’s existence and its affiliation.
The data indicates that the page first appeared in the in-stream video ads active partner-publisher list on 24 July 2023.
It was subsequently delisted and relisted on three different occasions. Although all RT pages have reportedly been restricted following the introduction of OFAC sanctions against TV-Novosti, the page continues to appear on Meta’s in-stream video ads active partner-publisher list as of 3 June 2025, suggesting that it may still be active in some geographies.
Of note is the fact that the revenue redistribution partnership with this page was entered into after TV-Novosti, RT’s parent entity, was placed under EU financial sanctions on 16 December 2022, and after the EU expanded its broadcasting sanctions to RT Arabic on 25 February 2023.
Per Meta’s ad library, ‘RT Arabic روسيا اليوم - مصر’ also paid Meta for ads through to at least March 2024.
Meta engages in revenue redistribution partnerships with pages affiliated with other entities under EU financial sanctions.
RT and Sputnik outlets are explicitly mentioned in relation to EU broadcasting sanctions. When it comes to financial sanctions, however, their parent entities – TV-Novosti and Rossiya Segodnya – are the legal entities listed. This means that RT and Sputnik are not explicitly named in the EU financial sanction list. This is in spite of the sanctions’ likely applicability, insofar as the outlets are referenced as “subordinate media outlet” in the statements of reason and may be deemed “owned” or “controlled” by the listed entities.
To better understand Meta’s application of EU sanctions, we expanded our research to look at how Meta has been reflecting EU financial sanctions against pages named directly after a listed entity.
We queried Meta’s archived partner-publisher disclosures for blue tick verified pages and cross-referenced the results against the EU sanction list. Using this method, we were able to identify at least two pages listed as Meta partner-publishers despite being under the declared responsibility of sanctioned entities. One of them is still listed as active, as of 3 June 2025.
Polina Gagarina is a singer, actress, song writer, and model. She was placed under EU sanctions on 24 June 2024 for her role in supporting actions undermining the territorial integrity of Ukraine.
The Facebook page ‘Polina Gagarina’ is blue tick verified. Polina Gagarina claimed responsibility for the page using Facebook’s ‘Claim Responsibility for a Page’ process. The page also links to her official website.
The page appears to be geo-fenced in Europe, further supporting its authenticity as well as Facebook’s awareness of its existence and affiliation.
As with RT and Sputnik pages, Meta’s archived disclosures indicate that the ‘Polina Gagarina’ page remained included in Facebook’s active partner-publisher lists well after Polina Gagarina’s inclusion into the EU sanction list on 24 June 2024.
The page first appeared on the in-stream video ads partner-publisher list on 1 May 2024. With the exception of a minor interruption, likely due to a community standards violation, it was listed as an active Meta partner-publisher through to the list dated 8 January 2025.
Sylvain Afoua (pseudonym: Egountchi Behanzin) is the founder of the pan-African group “Ligue de défense noire Africaine” (LDNA), a group dissolved by a French ministerial decree on 29 September 2021 for spreading an ideology calling for hatred, discrimination and violence.
Sylvain Afoua was placed under EU sanctions on 20 May 2025 for spreading Russian narratives and misinformation on the war of aggression against Ukraine on the African continent.
As with the ‘Polina Gagarina’ page, the page ‘Egountchi Behanzin’ is blue tick verified. Egountchi Behanzin (aka Sylvain Afoua) claimed responsibility for the page using Facebook’s ‘Claim Responsibility for a Page’ process. The page also links to his official website.
Unlike the ‘Polina Gagarina’ page, the page continues to be visible within the EU as of 1 June 2025.
As of Meta’s disclosure dated 3 June 2025, the page ‘Egountchi Behanzin’ continues to be listed as an active partner-publisher in the Facebook in-stream video ad program.
Ads also continue to be actively shown on his videos, including within the EU.
As of 20 June 2025, the page also retains access to Facebook’s subscriber hub.
Subscriber hub is a monetization feature designed to facilitate the transfer of funds between Facebook users and eligible content publishers. It is subject to Meta’s Fan Subscription Creator Terms.
In both of the above cases, the Facebook Ad Library identifies the pages as counting more than one page admin.
Notably, several of the page admins appear to be located within the European Union as of 1 June 2025, including in France and Sweden.
This suggests that Meta may have inadvertently been enabling EU residents to assist sanctioned entities by contributing to the administration of their Facebook page and potential revenue generating activities.
Meta engages in revenue redistribution partnerships with unverified accounts distributing content from Russian outlets subject to EU broadcasting sanctions.
As we reviewed Meta’s partner-publishers data for monetized accounts associated with sanctioned entities and individuals, we also came across several accounts whose authenticity we could not verify.
The pages ‘Russian Today’ and ‘Скабеев‘ (Olga Skabeyeva) are two such examples. The former is managed out of Peru, while the latter is managed out of Indonesia. Neither is blue tick verified.
Olga Skabeyeva is the host of ‘60 minutes’, one of Russia’s most popular talk shows. The show is broadcast on Rossiya-1, an entity subject to EU broadcasting sanctions since 16 December 2022. Olga Skabeyeva herself was placed under EU sanctions on 28 February 2022.
Russian Today appears to be an impersonator of Russia Today, carrying the brand’s logo and actively redistributing its content.
While the above pages may not be affiliated with the sanctioned entities or individuals they pertain to represent, their onboarding and continued inclusion as Meta partner-publishers is noteworthy for a couple of reasons.
Policy Violations
If these pages are managed by impersonators, they are in clear violation of Facebook’s Impersonation and intellectual property policies, which would constitute a violation of Facebook’s Partner Monetization Policies and should have rendered them ineligible for monetization.
Illegal Content
These pages are distributing content owned by RT and Rossiya-1, two of the Russian outlets subject to EU broadcasting sanctions since 1 March 2022 and 16 December 2022 respectively. This content is considered illegal in the EU, and may, by association, render the existence of a business partnership, as well as remuneration of the content, illegal.
Both pages continue to be listed by Meta as active partner-publishers as of 3 June 2025, irrespective of the above.
RESEARCH LIMITATIONS
Our findings are based on the data made available by Meta as part of its active partner-publisher disclosures. There are some notable limitations to this data.
Contracting Entity
We cannot confirm, on the basis of the data alone, that the revenue redistribution contracts referenced in this investigation were processed via a company incorporated under the laws of an EU member state.
This is because Meta does not specify in its disclosures which of its legal entities is the contracting party to the business partnership.
This being said, Meta does name both ‘Meta Platforms Inc.’ and ‘Meta Platforms Ireland Ltd.’ as possible contracting entities in its monetization terms.
Its Irish entity, ‘Meta Platforms Ireland Ltd.’ (register:462932), is the entity responsible for providing Facebook services within the European Union.
Based on remittance slips issued to partner-publishers based in France, it would appear that ‘Meta Platforms Ireland Ltd.’ also oversees EU-based revenue redistribution partnerships.
A review of remittance payments issued to partner-publishers located in diverse geographies also suggests that Meta may further be managing most of its non-US (or North American) revenue redistribution partnerships through Meta Platforms Ireland Ltd.
Contracted Entity
We cannot confirm, on the basis of the data alone, that RT, Sputnik, their parent entities, Polina Gagarina or Sylvain Afoua were named parties in the revenue redistribution contracts referenced in this investigation.
This is because Meta does not disclose the legal identity of its partner-publishers, only the name and handle of monetized accounts.
This being said, Meta specifies in its Monetization Terms that its contractual relationships are intended to be with “the person or entity that authors or owns the Content, or its authorized agent”.
In the case of RT, Sputnik, Polina Gagarina and Sylvain Afoua, Meta used various methods to confirm the pages’ authenticity and affiliation. While we cannot exclude that the monetization partnerships were entered into by a staff member or agent, Meta should have known the ultimate beneficiary of these contracts.
Fund Transfers
We cannot confirm, on the basis of the data alone, that there was a material exchange of funds between the parties.
This is because Meta does not disclose any fund transfer information as part of its partner-publisher disclosures.
The data does indicate, however, that the pages affiliated with RT, Sputnik, Polina Gagarina and Sylvain Afoua actively sought participation in revenue redistribution programs, both prior to and after the introduction of sanctions. This suggests that the owners of the pages found a material benefit to their participation.
Data Quality
We cannot independently confirm the accuracy of the partner-publisher lists made available to us by Meta.
Although Meta’s brand safety reporting and disclosures are certified by the Media Rating Council, an industry self-regulatory body established at the request of US Congress, our review of Meta’s partner-publisher lists revealed some notable issues with the data.
Inconsistent Releases
Despite its stated claim of daily disclosures, Meta does not consistently release partner-publisher lists for each of its programs on a daily basis. Meta also doesn’t provide an archive, enabling retroactive access to the files we may have missed as part of our own collection.
We accounted for the absence of daily files in our investigation by clearly identifying the files that our investigation relied on (black dots) as well as by distinguishing the confirmed periods of monetization (colored) from possible periods of monetization (grey). The latter represents the period between two files, when the page may still have been included in the program, despite our inability to confirm it.
Date_Added Errors
Meta’s disclosures include a date_added field, which Meta defines as “the date that the partner-publisher was added to the publisher list.” This is an important data point to retrace a page’s monetization history.
Some releases have included notably erroneous date_added, including dates mirroring the date_created field, the date_included field, or other erroneous dates, often predating previous sessions. Errors have been particularly recurrent since 9 November 2024. (see data →).
Such data inaccuracy can be observed on Meta’s own front-end tool.
The In-stream video ad view dated 3 June 2025, for instance, shows pages with date_added that far predate the official launch of the in-stream video ad program in 2018.
We accounted for missing date_added and date_added errors in our investigation by running a correction algorithm generating a date_added_corrected field based on available files and information.
An example of such correction is the page ‘RT Arabic روسيا اليوم - مصر’, for which Meta has been reflecting the page_created_date (2022-12-02) in lieu of its date_added starting from 9 November 2024. Our correction algorithm established a date_added_corrected of 2024-10-02, reflecting the page’s continuous monetization from that start date.
Inconsistencies between Meta’s CSV and front-end disclosures
Finally, we identified some notable discrepancies between Meta’s CSV and front-end disclosures, where some pages listed on the downloadable CSV files are not reflected on the front end.
The ‘RT Arabic روسيا اليوم - مصر’ and ‘Russian Today’ pages are such examples. They continue to be listed in the downloadable CSV files, as of 3 June 2025, but do not return any result on the partner-publisher front-end tool.
This is in contrast to the ‘Egountchi Behanzin’ and ‘Скабеев‘ pages, which continue to be listed across both the CSV files and front-end tool as of 3 June 2025.
These inconsistencies were independently reproduced by journalists from Le Monde and Süddeutsche Zeitung.
While we cannot confirm that this is the only cause for the inconsistencies, our research suggests that Meta may not be displaying ‘gated accounts’ on its front-end tool. These are accounts which are restricted to some geographies or audience groups. Account gating can be applied by Meta, which typically uses targeted restrictions to abide by local law requests, as well as by a page admin, who can choose to limit the visibility of a page to some countries or age groups. Meta’s now defunct transparency tool, CrowdTangle, similarly didn’t display posts subject to gating.
We accounted for these inconsistencies in our investigation by defaulting to the downloadable CSV files as our ultimate source of truth.
CONCLUSION
Building on Meta’s own partner-publisher disclosures, downloaded over 5 ½ years, our findings indicate that Meta has engaged in revenue redistribution partnerships with pages it should have known to be affiliated with entities under EU financial sanctions, as well as with pages redistributing content owned by entities subject to EU broadcasting sanctions.
Although many of the investigated partnerships predate the introduction of EU sanctions, we find that Meta continued – and in some cases entered into new – revenue redistribution partnerships after the introduction of sanctions.
According to Meta’s CSV disclosures, some of the partnerships referenced in this investigation – notably with the pages ‘RT Arabic روسيا اليوم - مصر’, ‘Egountchi Behanzin’, ‘Russian Today’ and ‘Скабеев‘ – are still active as of 3 June 2025.
Our findings raise important questions regarding Meta’s compliance with EU sanctions.
♦️ Financial sanctions
- Has Meta made any funds available, either directly or indirectly, to entities facing EU financial sanctions?
- Does Meta know it is selling ad placements on pages affiliated with sanctioned entities?
- Were sanctioned entities able to accrue funds through Facebook’s revenue redistribution partnerships —even if no funds were ultimately transferred? If so, what has Meta done with these funds?
- Were sanctioned actors able to access — or accrue — any funds through other monetization features provided by Meta?
- Did Meta know that it was enabling EU residents to administer the Facebook pages of sanctioned entities?
♦️ Broadcasting sanctions
- Has Meta made any funds available to actors distributing content by outlets subject to EU broadcasting sanctions?
Our findings also raise important questions regarding the adequacy of Meta’s monetization systems and governance.
♦️ Sanctions enforcement mechanisms
- What processes does Meta have in place to ensure compliance with EU sanctions?
♦️ Monetization Terms
- Why are Meta’s monetization terms (naming Meta Platforms Ireland Ltd.) referencing US sanctions but not EU sanctions?
♦️ Business partner qualification process
- What business due diligence review processes does Meta have in place to ensure that it does not enter into contractual relationships with - or transfer funds to - sanctioned entities or actors otherwise engaged in illegal activity?
- Which signals are used to trigger heightened due diligence reviews?
♦️ Onboarding eligibility review
- What processes does Meta have in place to validate the eligibility of Facebook accounts before prompting them to register for monetization services?
- How automated are these review processes?
- Which signals are taken into consideration as part of these reviews?
♦️ Ongoing eligibility review
- What processes does Meta have in place to review the monetization eligibility of published content?
- How automated are these review processes?
- Which signals may trigger additional account, payout account or partner-level reviews?
♦️ Demonetization Actions
- What determines whether a publisher is demonetized at a content, monetization service, account, payout account or partner level?
- To what extent are demonetization and remonetization decisions linked to content moderation decisions?
- To what extent are these decisions automated?
♦️ Appeal Process
- Which demonetization decisions are open to appeal?
- Are appeals systemically subject to human review?
- To what extent are appeal reviews outsourced?
♦️ Transparency and Oversight
- Are Meta’s monetization systems and processes audited? By whom? How regularly?
- Are Meta’s partner-publisher disclosures audited? By whom? How regularly?
- What internal processes does Meta have in place to ensure the accuracy of its partner-publisher disclosures?
- Does Meta keep a running log of identified errors and applied corrections?
- Does Meta exclude gated accounts from its public facing disclosures? What other factors may result in some accounts not showing up in disclosures?
Ultimately, our findings emphasize the need for much greater transparency and oversight of social media monetization partnerships.
The only reason we were able to conduct this investigation is because Meta discloses lists of its active partner-publishers, which we painstakingly downloaded over a period of several years. We are not in a position to conduct similar analysis for other social media platforms, due to the absence of such disclosures.
As of June 2025, however, all major social media platforms – including Facebook, Instagram, YouTube, TikTok, Snapchat, X and, as of May 2025, Linkedin – offer monetization services. Besides revenue redistribution programs, monetization services can include subscription tools (such as Facebook’s subscriber hub), digital tips and creator marketplaces.
Besides Meta platforms, other platforms such as YouTube, TikTok and X have all been found to violate EU broadcasting sanctions. This points to weaknesses with their sanction compliance processes, which may also apply to monetization partnerships.
RECOMMENDATIONS
♦️ TO SOCIAL MEDIA PLATFORMS
- Immediately cease any monetization partnerships benefiting directly or indirectly any EU sanctioned entity.
- Identify, assess and mitigate the risks stemming from the design, functioning and use of monetization services.
♦️ TO THE EU
- Request information from all social media platforms on their monetization partnerships with, or indirectly benefiting any EU sanctioned entity.
- Ensure adequate regulatory oversight of social media platforms’ monetization services, systems and governance, including through the enforcement of existing and – as necessary – complementary regulations.
- Mandate public disclosures to allow the public and regulators to effectively scrutinize social media platforms’ monetization policies, enforcement practices and monetization partnerships. Partnership disclosures should be made available as a running archive and include references to the contracting entity, the contracted entity, and whether fund transfers were made.
♦️ TO EU MEMBER STATES
- Investigate potential sanction violations by Meta Platform Ireland Ltd and other social media companies.
- Initiate infringement proceedings against social media companies found to be in violation of EU sanctions.
You can access the data underlying this investigation here.
WHAT TO FIX informed Meta of the report’s findings over a week prior to publication and sought comments from the company.
Meta did not acknowledge or respond to WHAT TO FIX’s email.
Meta did not acknowledge or respond to WHAT TO FIX’s email.
In response to inquiries from the Süddeutsche Zeitung, Le Monde, and Politico, who received an advanced copy of the report, Meta stated that inclusion in their partner-publisher list is not in itself evidence that an account has received payouts, and that any party on the list is still subject to its sanctions controls. It further stated that it is committed to complying with applicable sanctions laws including EU sanctions.
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