"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", June 202, 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.

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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.

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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.

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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.

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