WASHINGTON – Today, U.S. Sen. Mark R. Warner (D-VA), Chairman of the Senate Select Committee on Intelligence and Banking, Housing, and Urban Affairs National Security and International Trade and Finance Subcomittee, wrote to Janet Yellen, Secretary of the Treasury, questioning the Department’s failure to implement appropriate sanctions enforcement as major technology firms such as Alphabet and Meta repeatedly flout U.S. sanctions rules through provision of digital advertising services. In his letter, Sen. Warner highlighted reports that tech companies continue to provide adtech services to sanctioned companies that have deep ties to our foreign adversaries, including Russia and Iran.

“[P]ublic reports in November 2023 indicated that Google served ads – and provided publisher monetization and search solutions – to a range of sanctioned Iranian and Russian companies,” Sen. Warner wrote. “Even if, as Google has claimed, these relationships did not result in ad payments to sanctioned entities, Google’s provision of web services to these sanctioned companies suggests a troubling inattention to compliance, particularly given the company’s long track record of ignoring fraud within the online ad ecosystem and of accusations of skirting U.S. sanctions laws.”

As Chairman of the Intelligence Committee, Sen. Warner outlined the negative impact that these transactions have on U.S. national security and foreign policy interests, and the need for the Treasury Department to enforce the sanctions in place.

“[R]eports suggest that Meta (parent of Facebook) flaunts U.S. sanctions rules, with recent reporting suggesting that the sanctioned Russian oligarch, Ilan Shor, has continued to use Facebook advertising for malign influence activity targeting Moldovan elections,” Sen. Warner continued. “My staff first inquired of the Department about apparent violations by Facebook in February 2023, when prior reports of Shor’s Facebook activity surfaced. This example is especially concerning  given the Senate Select Committee on Intelligence’s extensive efforts to publicize the ways in which Russian influence actors exploited social media platforms like Facebook to target U.S. elections. Nearly one year later, Facebook has continued to ignore U.S. sanctions laws – reportedly running hundreds of thousands of dollars in advertisements that, on their face (and in the recorded payment information), clearly indicated connection to the sanctioned oligarch.”

 As the 2024 elections ramp up, Sen. Warner stressed the need to combat efforts of foreign malign actors to influence and subvert elections.

He concluded, “This year, the world’s democracies will hold an unprecedented number of elections. In the wake of Russian efforts to influence U.S. elections in 2016, malign actors worldwide have increasingly embraced social media and online advertising tools as vectors for election influence. Given the centrality of U.S. firms to online advertising and social media markets worldwide, it is vital that the Department enforce American technology company compliance with U.S. sanctions.”  

A copy of the letter is available here and below:

Dear Secretary Yellen,

I write with concern over the Department of Treasury’s (the Department) failure to ensure sanctions compliance in digital advertising markets. In multiple instances in the previous two years, my staff has alerted the Department of instances of apparent sanctions violations by U.S. technology firms. Despite these repeated notifications, United States firms such as Alphabet and Meta continue to flout U.S. sanctions rules.

Various sanctions issued by the U.S. government bar corporations from certain transactions with sanctioned entities. Treasury already gives significant latitude to U.S. technology firms through the issuance of general licenses exempting “internet-based communications.” These exemptions ensure that internet users in foreign countries can continue to access certain basic communications services, particularly in the context of repressive regimes under U.S. sanction. However, these exemptions are not meant to continue facilitation of sanctioned activity, or financially benefit sanctioned entities, and in response to inquiries from my staff the Department acknowledged that online advertising services are not covered by these general licenses. Notwithstanding this acknowledgement, however, the Department has continued to ignore repeated instances of non-compliance by U.S. technology firms.

For instance, public reports in November 2023 indicated that Google served ads – and provided publisher monetization and search solutions – to a range of sanctioned Iranian and Russian companies.  Even if, as Google has claimed, these relationships did not result in ad payments to sanctioned entities, Google’s provision of web services to these sanctioned companies suggests a troubling inattention to compliance, particularly given the company’s long track-record of ignoring fraud within the online ad ecosystem and of accusations of skirting U.S. sanctions laws.  Notably, Google’s facilitation of ad delivery in countries under U.S. sanctions regimes has been a longstanding concern. In 2019, Wired reported that Google appeared to be exposing advertising clients to ad waste and potential sanctions violations.  Similarly, ProPublica has reported on instances of Google ostensibly ignoring U.S. sanctions by monetizing a Serbian media outlet that has sought to promote separatist violence.  ProPublica has also noted that Google’s provision of ad services to sanctioned companies has enabled them to harvest user data  – potentially enabling Russian surveillance and influence activity.

Even more recently, reports suggest that Meta (parent of Facebook) flaunts U.S. sanctions rules, with recent reporting suggesting that the sanctioned Russian oligarch, Ilan Shor, has continued to use Facebook advertising for malign influence activity targeting Moldovan elections.  My staff first inquired of the Department about apparent violations by Facebook in February 2023, when prior reports of Shor’s Facebook activity surfaced. This example is especially concerning given the Senate Select Committee on Intelligence’s extensive efforts to publicize the ways in which Russian influence actors exploited social media platforms like Facebook to target U.S. elections. Nearly one year later, Facebook has continued to ignore U.S. sanctions laws – reportedly running hundreds of thousands of dollars in advertisements that, on their face (and in the recorded payment information), clearly indicated connection to the sanctioned oligarch. And, notably, this is not the only instance in which Facebook has been accused of profiting from sanctions non-compliance. A pair of whistleblower complaints in 2022 similarly accused the company of enabling influence activity by Russian-linked, sanctioned separatist leaders. 

This year, the world’s democracies will hold an unprecedented number of elections. In the wake of Russian efforts to influence U.S. elections in 2016, malign actors worldwide have increasingly embraced social media and online advertising tools as vectors for election influence. Given the centrality of U.S. firms to online advertising and social media markets worldwide, it is vital that the Department enforce compliance with U.S. sanctions.

Thank you for your attention to this matter.

Sincerely, 

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