By Noah Arjomand

In May 2018, A Washington Post fact-check of the US government’s reasons for withdrawing from the Joint Comprehensive Plan of Action with Iran included a discussion of the claim that Iranian military spending had increased because of the agreement. The fact-checkers wrote:

Iran’s current budget is funded largely through “oil, taxes, increasing bonds, [and] eliminating cash handouts or subsidies” for Iranians, according to an article by a Forbes contributor, Heshmat Alavi, sent to us by a White House official.

The problem with this information, accurate or not, was that Heshmat Alavi is not a real person.

An investigation by The Intercept revealed that Alavi was actually a cloaked online persona run out of Albania by the Mojahedin-e Khalq (MEK), an Iranian opposition group with a violent history whose social media operations seek to influence policies toward Iran. By leveraging the large social media following they gathered to accounts purportedly authored by Alavi, MEK placed opinion pieces in news outlets that included The Diplomat, The Hill, and The Federalist. The article “How Iranian regime sinks deeper into isolation” in Saudi-owned al-Arabiya English credited to Alavi is not even classified as opinion, but is listed as a special analysis feature.

A Forbes representative confirmed that Alavi is no longer a contributor and that the publication has removed articles that had been published under that name. You can, however, still find writings attributed to Alavi in outlets like The Hill and The Federalist, where the author is still described as an activist. As of September 2019, there had been no updates acknowledging the true sourcing of the articles’ information.

In all of these cases, including the Washington Post’s fact-check, if readers had known that the information about Iran’s budget was sourced from the MEK, they very well could have interpreted the information quite differently. Yet the placement of that information in Forbes and its subsequent layering through the White House and then The Washington Post obscured that origin.

In Part I of this post, I argued that attempts to hide the illegitimate true sourcing of news can be classified as information laundering. This entails “placement” of disinformation in the news media ecosystem, “layering” it through a series of news organizations to obscure its origins, and finally “integration,” which occurs when the information is presented as legitimate and can therefore be used to accomplish a specific goal, be it political or economic.

In this post, I will discuss efforts to combat money laundering and the lessons they could offer the media development and governance community to fight information laundering. I then discuss possible interventions against information laundering at the placement, layering, and integration stages. None of the proposals are totally new ideas, however thinking of them collectively as a response to information laundering helps us develop a holistic approach to what is a multi-faceted problem.

The United States passed its first anti-money laundering legislation in 1970, and many other countries followed suit. In recognition that moving money across borders allowed launderers to evade scrutiny the G7 created the Financial Action Task Force to combat international money laundering in 1989. Countries that do not join this effort are “named and shamed,” making legitimate international businesses wary of operating in them.

A major element of anti-money laundering efforts has been to require banks and other businesses to look for and report suspicious transactions. Such regulation has shifted responsibility so that rather than resting solely with the original perpetrator of the crime, it is also distributed among organizations involved in the successive stages of laundering. Anti-money laundering laws have forced organizations to step up their own internal regulation of illegal behavior since in many cases it is corrupt individuals within otherwise legitimate organizations who serve as accomplices.

A major criticism of the anti-money laundering regime has been the failure to enforce high standards of transparency in ownership. Current US laws and laws in many other countries allow the easy creation of shell companies and accounts that obscure true ownership. This makes it difficult to track money through the financial system. Recently a draft bill was introduced in the US Congress would strengthen ownership disclosure requirements.

We might draw three broad lessons from the case of anti-money laundering efforts for how to combat information laundering:

• Conceptualize the problem as a transnational one demanding response not limited to the national level.
• Hold responsible not only the original sources of dirty information, but also the organizations enabling laundering.
• Promote transparency in media organizations to make it easier to evaluate their outputs and track the flow of information.

Recognition is growing that the global interconnectedness of media provides opportunities both for greater freedom of expression and for bad actors to spread disinformation covertly. Initiatives such as the Global Disinformation Index already use the “naming and shaming” of media organizations to promote reform and educate news consumers about which outlets to trust and distrust. The discussion around how to deal with misinformation could usefully taking into consideration how an anti-money laundering system was built.

Anti-money laundering regulations aim to reduce the space for plausible deniability among organizations involved in the layering stage of laundering. By requiring banks, high-end businesses, and other organizations to monitor and report suspicious transactions and holding them accountable if they are found to be complicit in money laundering schemes, regulators have forced them to be more careful about whom they do business with and how they keep track of the money that flows through them.

When it comes to dirty information, publishers are generally held accountable for the information they disseminate, though the level of accountability varies across national legal systems. There is nonetheless a great deal of opacity in the sourcing of information or even the identification of authors. Sometimes this is defensible as necessary protection for journalists’ sources, but in many cases even information recycled from other media outlets or social media is not properly sourced. This makes it difficult for observers to follow the trail of information layering.

Addressing the sourcing problem is not necessary the place for legal regulation. On this front, the institutionalization of journalistic ethics and norms can be quite effective. The long-standing journalistic norm of identifying sources by name whenever possible is itself an anti-information laundering measure, even if not typically thought of as such. Other effective measures can be as simple as institutionalizing the increasingly common practice of providing hyperlinks to sources. Ideally these should be permanent links created with tools like the Internet Archive’s Wayback Machine that will continue to work even if original content is deleted at a later date to cover tracks or simply due to “link rot” as websites change or shut down. This will allow news consumers to more easy trace the flow of information. The Internet Archive has developed an automated tool to systematically replace millions of dead links on Wikipedia with links to archived versions of those pages. News organizations would be wise to adopt similar tools.

As the case of Heshmat Alavi illustrates, even within news organizations, there can be little oversight in terms of where information comes from or even of who is producing news content. Information laundering is facilitated by the global nature of editors’ relationships with freelancers and opinion writers, whom they may never meet in person and only know through their social media presence and online correspondence. News organizations’ reliance on business models that depend on maximizing the volume of content can also make it difficult for editors to keep close track of all the stories and contributors they manage. Preventing the next Heshmat Alavi-style information operation may require more comprehensive reforms to the media economy to help news organizations have the time and staff resources to properly vet their contributors.

When it comes to the information circulating on social media platforms, the picture is very different. Although in Europe social media platforms like Facebook are increasingly being held accountable for the content they host, they enjoy a lack of accountability under American law when it comes to many forms of disinformation. Laws holding platforms responsible for the dissemination of harmful materials such as child pornography and terrorist propaganda have been effective in reducing their presence in the mainstream, yet when it comes to disinformation and hate speech, lawmakers have been hesitant to hold platforms accountable, in part out of justifiable concerns about the blurry boundaries among disinformation, malinformation, and legitimate free speech. It is also important to acknowledge how the existing US legal framework has facilitated the proliferation of free expression on sites hosting user-generated content and made possible the creation of online communities that, among other things, hold news organizations and their own members accountable for laundering dirty information.

Short of banning content, though, measures could be taken to at least increase the transparency of information sources. Recently, YouTube responded to criticism of the role of social media in spreading political disinformation by instituting a policy (implemented thus far only in a limited number of countries) of adding disclaimer labels to videos posted by state-funded broadcasters. For example all videos published by RT on YouTube now include a label that states, “RT is funded in whole or in part by the Russian government.” In August 2019, in response to a Chinese state-directed propaganda campaign on social media aimed at discrediting protests in Hong Kong, YouTube made the feature available within Hong Kong. This policy is a step toward preventing at least the simplest form of cloaking in the placement and integration stages. Demanding that publishers and platforms make information sources as transparent as possible—whether through legal regulation or through normative pressure from readers—would help reduce the overall problem.

As in the case of YouTube disclaimers, promoting transparency of media ownership and funding is also an important measure against information laundering. Initiatives like the European Centre for Press and Media Freedom’s Media Ownership Project focused on Eastern Europe, Reporters Without Borders Media Ownership Monitor and the Center for Media, Data, and Society’s Media Influence Matrix seek to illuminate what are essentially borderline cases of cloaking: media outlets that present themselves as legitimate news consumers but, due to ownership or other financial pressure, are prone to be used as intermediaries to clean dirty information sourced from or in the interest of their patrons.

Transparency as a solution fits even better with information laundering than with money laundering. In the latter case, we would not want the public to have detailed data on all financial transactions. In contrast, there are few if any problems with public access to data about the flow of information through the media. This level of transparency would enable the crowd-sourcing of laundering enforcement. Readers would be able to track down the sourcing of information about issues important to them.

Furthermore, in the case of money laundering, the definition of dirtiness is based we have a clear-cut definition of dirtiness: was the money acquired through the commission of crime? By contrast, dirtiness in the case of information should be measured according to the degree to which audiences’ interpretations of the information would change if they knew its true sourcing. Dirtiness is not quite the same as opacity. For example, a journalist might make it difficult to track the origin of information by granting a source anonymity out of necessity, but that does not in and of itself make the information dirty. It would only be dirty if readers would find the information less credible were that source to be identified.  The same information and sourcing could look dirtier to one reader than to another. Not everyone minds if their information comes from a government or a corporate-owned news outlet. Information from such sources is not necessarily unreliable. The important point is that readers should be able to make their own independent judgements about sourcing standards.

If there is not a single, agreed-upon criterion for the dirtiness of information or legitimacy of its producer, the best solution may be simply to give media audiences and monitors the tools to better assess the news they consume and investigate by understanding its true sourcing. Consumers should be able to recognize public diplomacy as public diplomacy, advertising as advertising, and political campaigning as political campaigning. Even if the average news consumer does not have time for a follow the chain of hyperlinks that trace the flow of information across the globe for every story they read, transparency can empower both professionals and amateurs who do want to dig deep into the information on whose basis policies are made and public opinion is shaped.

Noah Arjomand is Mark Helmke Postdoctoral Scholar in Global Media, Development, and Democracy at the Center for International Media Assistance and Indiana University’s Hamilton Lugar School of Global and International Studies. He studied sociology (MA, PhD) at Columbia University and, before that, public and international affairs (AB) at Princeton University.