Additionally, TAG has failed to enforce its standards and investigate non-compliance, resulting in the continued funding of CSAM and other criminal activity for years. While this is not the first instance where TAG-certified vendors have reportedly participated in delivery or measurement of advertising on websites engaged in illegal activity, these vendors have remained in good standing.
Further, while TAG publicly states that it has “worked closely” with the United States government on several of its efforts to combat digital threats, TAG-certified companies failed to prevent the government’s own advertising from appearing on a website known to host CSAM.
You have personally referred to TAG as being “like the Good Housekeeping seal of approval for digital advertising.” But, to the contrary, recent witness testimony in the United States District Court for the Eastern District of Virginia identified TAG as “the minimum bar” and points to its “lax standards.” Whether TAG holds itself out as the ceiling or the floor, the failure of TAGcertified entities to prevent advertising from appearing on and funding a website known to host illegal CSAM is unacceptable.
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 is TAG’s plan to review the certification status of vendors that have participated in delivery or measurement of advertising on CSAM-hosting websites?
- What is TAG’s standard for reviewing or revoking an entity’s certification for “brand safety” where such a company fails to identify or prevent ads from appearing on known CSAM or otherwise unlawful websites? Please outline any immediate corrective actions, including reviews of certified companies and potential revocation of certifications.
- Have TAG-certified vendors have reported URLs containing CSAM to NCMEC? How many URLs have been reported since 2021?
- How many vendors’ certification statuses has TAG suspended or revoked for noncompliance with standards? Please outline any such enforcement actions or remediations resulting from TAG’s inquiries or certification standing reviews.
- Has TAG received complaints related to any of the entities identified as having participated in the delivery or measurement of advertising on imgbb.com since 2021?
- What specific audits, monitoring, or oversight mechanisms does TAG employ to ensure certified companies comply with these standards?
- Why does advertising continue to be served on CSAM-hosting and other illicit websites despite the use of TAG-certified vendors?
- TAG’s Brand Safety guidelines specifically identify certain “content” that is prohibited from monetization, including illegal pirated content. Yet, the guidelines make no mention of standards relating to the monetization of websites engaged in illegal activity, as is the case with imgbb.com.
- Please explain TAG’s position as it relates to websites that distribute CSAM or engage in other illegal activity.
- Is TAG’s position that it is acceptable for Brand Safety certified members to participate in the delivery of advertising, and thus advertising revenue, to websites engaged in illegal activity, as long as the advertising does not appear next to “content” that is prohibited?
- Do TAG standards address whether certified vendors are permitted to maintain their revenue share or fees when they measure advertisements served on CSAM or other illegal websites?
- What additional measures is TAG considering to strengthen its certification and enforcement process and prevent similar failures in the future?