EU-Sanctioned Entities Monetizing on Facebook, YouTube, TikTok and X

 
 
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EU-Sanctioned Entities Monetizing on Facebook, YouTube, TikTok and X

All four major platforms granted EU-sanctioned individuals and entities under their control access to monetization services—raising EU sanctions compliance and DSA systemic risk concerns. Most monetization arrangements remained active as of April 2026.

Published: 29 April 2026
 
We previously revealed how Meta engaged in revenue redistribution agreements with various accounts affiliated with EU-sanctioned entities, including Russia Today, Sputnik, and various influencers engaged in foreign information manipulation interference (FIMI) activities.
In this investigation, we expanded our research to YouTube, TikTok and X, and found that:
  • Facebook, YouTube, TikTok and X all granted access to monetization services to accounts affiliated with EU‑sanctioned entities and entities under their direct control.
  • Between January and April 2026, only X ended its monetization agreement; Other companies’ monetization agreements remained active as of April 2026.
 

WHY IT MATTERS

 
Monetization services are designed to enable creators and publishers to obtain funds and may constitute an “economic resource”. Where these services continue to be made available to accounts affiliated with EU-sanctioned entities:
  • Platforms may be in breach of EU sanctions (potentially a criminal offense under applicable national law)
  • Platforms may be financially supporting the dissemination of illegal content, which is a systemic risk identified by the EU Digital Services Act (DSA)
  • Beyond sanctions, platforms may be financially supporting FIMI activities, which can contribute negative effects on civic discourse, electoral processes and public security, another systemic risk concern under the DSA
 
More generally, if platforms cannot screen out sanctioned actors through their existing reviews, this raises broader concerns about the adequacy of their monetization review systems and processes, which can be a risk factor across all other systemic risks.

METHODOLOGY

 
Review Sample: we identified 21 accounts affiliated with individuals sanctioned by the EU for their involvement in pro‑Russia foreign information manipulation and interference (FIMI). Accounts included official accounts and accounts of entities named in EU sanctions filings as being under their direct control. Collectively, these accounts have over 4.3 million followers.
Monetization indicators: For each platform, we checked for indicators that the accounts had access to monetization services that require a platform agreement and eligibility review, including:
- Partner‑publisher list (Facebook only)
- On‑platform checks for publicly visible access to fan-funded monetization services
Verification over time: We conducted checks at two points in time (January and April 2026) to identify whether platforms’ approaches changed during the reporting period.
Limitations: Platforms do not publicly disclose payouts or payment flows associated with their monetization services. We looked for access to monetization services as an indicator of underlying monetization agreements and eligibility decisions by platforms. Our findings indicate eligibility and access, not necessarily access to funds.
 

RECOMMENDATIONS

 
EU sanctions authorities (including in Ireland and France) shall open investigations into potential sanctions compliance failures relating to platform monetization services.
The European Commission and Digital Services Coordinators shall require platforms to share information about their sanctions screening, identify and mitigate monetization-related systemic risks, and make relevant data available to researchers for independent oversight.
Platforms shall audit their monetization eligibility and payout account reviews and to transparently report on the enforcement of their monetization policies.
 

PLATFORMS’ RESPONSE TO OUR FINDINGS

 
We shared our detailed findings with platforms and solicited information on their monetization reviews and sanctions screening practices.
Meta declined to comment on the specific allegations made in this report. The company emphasized that it is committed to complying with EU and other applicable sanctions laws and continuously takes steps to meet its legal obligations. It declined to provide additional information about its review processes.
TikTok declined to comment on the specific allegations made in this report. The company emphasized that it takes the issue very seriously and dedicates considerable resources to ensuring compliance with both its sanctions obligations and its obligations to assess and mitigate systemic risks in the EU. It notified us of its global ban of the ‘Egountchi Behanzin’ account for violation of its Terms of Service. It declined to provide additional information about its review processes, citing data protection and other compliance and business confidentiality reasons.
YouTube declined to comment.
X did not acknowledge our request for comment by the time of publication.
We also shared our findings with the European Commission, as well as sanctions authorities in Ireland and France.
 
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