Additionally, Google has failed to perform due diligence in identifying businesses that conduct illegal activity using its products. The website in question does not publicly disclose its ownership. We have seen previous instances where Google’s apparent failure to perform due diligence of the customers monetizing their websites via Google’s advertising products have resulted in advertising revenue inadvertently funding OFAC-sanctioned websites.
Further, Google executives recently testified in the United States District Court for the Eastern District of Virginia about the company’s extensive investment in vetting publishers and advertisers who use their products. Yet, as Google appears to be funding a website that does not declare its ownership, and has been known to host CSAM, these statements are irreconcilable with the indisputable evidence we have seen.
Just as troubling, reporting also indicates that advertisers—including the federal government— that use Google products cannot comprehensively track what businesses and content their ad dollars fund. Many advertisers reportedly cannot readily access page URL-level reporting that would allow them to identify which pages their ads have appeared on, including if they had appeared on imgbb.com. Imgbb.com is an anonymous photo sharing website that hosts user-generated content. Without access to the URLs on which their ads appeared, advertisers have no ability to understand whether their ads have appeared on content that violates Google’s policies, their own policies, or federal law.
It is imperative that your company take immediate and comprehensive action to address this issue and ensure that you are not funding these heinous crimes against children. To better understand how this occurred and to determine appropriate corrective actions, please answer the following questions by February 14, 2025:
- What steps does Google take to perform due diligence on the entities that monetize their websites or content using Google’s advertising technologies?
- Since becoming aware that advertising was placed via Google’s products on a website known to host CSAM, what actions have you taken to address or remedy this issue? Please include details on any refunds to advertisers, account suspensions, or broader policy changes implemented in response, including exact figures of how much you have refunded companies or the United States government for all ads served on imgbb.com and ibb.co and when the refunds were issued.
- Why are advertisers unable to readily view the exact URLs of the pages where their advertisements appear through each of Google’s different advertising technologies? If such capability exists, please include documentation for how advertisers can do this across Google products, including DV360, Google Ads, and Google’s Performance Max.
- How much advertising revenue has been derived by Google annually in relation to advertising served on websites that are identified by NCMEC as having hosted CSAM?
- How much revenue has Google paid to companies that own or operate sites that host CSAM?
- How often do you review NCMEC’s transparency reports to ensure that you are not monetizing websites that host CSAM?
- Was Google aware in this particular instance that imgbb.com was hosting CSAM? If so, what processes did Google implement to stop the placements of advertisements on that site?
- How many websites which are known to host CSAM according to NCMEC is Google currently monetizing? Please include details on the process that Google uses to confirm this figure.
- What additional steps will your company take to ensure that advertising dollars do not fund illegal content in the future? Please include a specific timeline for implementing these measures.