PRESS RELEASE
EU-Sanctioned Entities Monetizing on Facebook, YouTube, TikTok and X
New research by WHAT TO FIX documents EU-sanctioned entities accessing monetization services across Facebook, YouTube, TikTok and X — raising EU sanctions compliance and DSA systemic risk concerns. Most monetization agreements were still in force as of April 2026
29 April 2026
| Media Inquiries: press@whattofix.tech
Risks: possible revenue flows to sanctioned actors; financing of illegal content; financing of FIMI activities
Platforms under review: Facebook, Instagram, YouTube, TikTok, X
Accounts Examined: 21 accounts linked to sanctioned individuals and controlled entities
Review period: January & April 2026
Platforms under review: Facebook, Instagram, YouTube, TikTok, X
Accounts Examined: 21 accounts linked to sanctioned individuals and controlled entities
Review period: January & April 2026
WHAT TO FIX today releases “Sanctioned Entities Monetizing on Facebook, YouTube, TikTok and X”, its third investigation into the effectiveness of platforms’ monetization reviews and sanctions screening.
The tech policy and accountability non-profit had previously revealed how Meta engaged in monetization agreements with accounts affiliated with EU-sanctioned entities, including the accounts of Russia Today, Sputnik, and various pro-Russia influencers (read associated coverage in Le Monde, Süddeutsche Zeitung and Politico).
For this investigation, the organization expanded its research into YouTube, TikTok and X.
KEY FINDINGS
WHAT TO FIX found evidence of Facebook, YouTube, TikTok and X granting access to monetization services to accounts affiliated with EU‑sanctioned entities and entities under their direct control.
Between January and April 2026, 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
- 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.
WHAT TO FIX Executive Director Victoire Rio said:
Sanctions screening is the 101 of business due diligence. The fact that platforms continue to grant access to their monetization services to accounts benefiting individuals under EU sanctions is not just a sanctions enforcement concern. It calls into question the very adequacy of their monetization review processes. Platforms’ monetization services should not be a source of revenue for FIMI actors, sanctioned or otherwise. The burden should be on platforms to apply better screening over who they get into business with. We’re not just talking about content anymore. We’re talking about money. There are substantial risks associated with platforms offering monetization services. Platforms should acknowledge these risks in their DSA risk assessments and adopt pro-active mitigations. At present, X is the only platform to acknowledge the risk of financing sanctioned entities in its risk assessment.WHAT TO FIX RECOMMENDATIONS
EU sanctions authorities (including in Ireland and France) to open investigations into potential sanctions compliance failures relating to platform monetization services.
The European Commission and Digital Services Coordinators to require platforms to share information about their sanctions screening process, identify and mitigate monetization-related systemic risks, and make relevant data available to researchers for independent oversight.
Platforms to audit their monetization eligibility and payout account reviews, strengthen sanctions screening, and transparently report on the enforcement of their monetization policies.
PLATFORMS’ RESPONSE TO THE FINDINGS
WHAT TO FIX shared 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 any 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 any information about its review processes citing data protection and other compliance and business confidentiality reasons.
YouTube did not acknowledge our request for comment by the time of publication.
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 with sanctions authorities in Ireland and France.
READ THE REPORT
WHAT TO FIX’s detailed investigation can be accessed here.
Media inquiries: press@whattofix.tech