Written evidence submitted by Twitter


Thank you for your letter on online advertising and economic crime. We welcome the opportunity to respond to your questions and to provide you with an overview of our approach to fraudulent activity on Twitter.


Ensuring Twitter is a safe space for all users, including from fraud and scams, is a priority. We are always alert to potential gaps in our policies and enforcement, which are reviewed on an ongoing basis. We look forward to continuing to update the Committee in the new year.


Policies, including advertising policies for financial services


Our financial scams policy states that one may not use Twitter’s services in a manner intended to artificially amplify or suppress information, or engage in behavior that manipulates or disrupts people’s experience on Twitter. For this reason, you may not use Twitter’s services to deceive others into sending you money or personal financial information via scam tactics, phishing, or otherwise fraudulent or deceptive methods.


We have a number of other policies that strive to address the wider ecosystem of scams, such as:

        Private Information. Threatening to expose or share private information (including financial info like credit card/bank account details) in exchange for a financial reward (bounty) is a violation of our Private Information policy.

        Hacked materials. Tweets are flagging the sale of information that may have been acquired through hacking i.e. personal data ("dumps"), banking logins, identity profiles ("fullz" and "proof").

        Impersonation. Accounts that pose as bank customer service accounts are also actionable under impersonation, but we generally need a report from the bank itself in order to take action under that policy.


As with all our rules, we use a mixture of proactive and reactive approaches to enforce these.

Advertisers on Twitter are responsible for their Twitter Ads. This means following all applicable laws and regulations, creating honest ads, and advertising safely and respectfully. They must also follow Twitter Ads Policies. Certain industries and trade associations have their own self-regulatory codes for advertising and marketing. Advertisers on Twitter who are members of these associations should refer to these codes, in addition to Twitter's policies, for guidance on appropriate advertising practices.

Advertising policies for Illegal Products and Services

Twitter prohibits the promotion of unacceptable business practices globally. Our Unacceptable Business Practices Policy covers a range of different types of financial scams. If there is a specific type of content the Committee is concerned is not currently being covered, we would be very happy to follow up.

Furthermore, as outlined in our Illegal Products and Services Policy, Twitter prohibits the advertising or promotion of products, services, or activities considered illegal in a given jurisdiction. As we note on our website, advertisers in the UK should be aware of additional marketing regulations that may apply. Further information that may be found useful is available in the CAP Code and the resources provided by the Advertising Standards Authority.

Collaboration with government and partners


The UK Public Policy team at Twitter meet with government departments on a regular basis.


We have met with a range of stakeholders and government departments on economic crime over the past 3 years in order to ensure our policy and approach on financial scams is as robust as it can be.


In April 2021, we joined the Online Fraud Steering Group (OFSG), a joint public-private initiative co-chaired by techUK, the NECC and UK Finance and, as such, we have scaled up our engagement on this issue. The OFSG brings together senior representatives from the tech sector, financial services and law enforcement to collaborate and take collective action to disrupt fraudsters. Supporting the Home Office’s upcoming 2022 - 2025 Fraud Action Plan the group aims to:

        render the UK the least attractive place for online fraudsters to operate;

        involve all relevant sectors as required to collaborate and form targeted responses to prevent different types of fraud;

        share information and best practices to ensure a shared understanding around online fraud and its complexities;

        bring improve coordination between law enforcement and the tech and banking sectors;

        and enhance public communication around the complexities of financial fraud and promote consumer awareness.


Since its formation, the group has agreed on a delivery infrastructure, operational principles, and governance, including how it will engage with the Home Office’s Joint Fraud Taskforce. Four key work streams have begun work to cut across different fraud typologies, taking a 'fraud agnostic approach' to account for how the situation is constantly shifting: 1) online advertising, 2) developing a threat assessment 3) enhancing communications and education and 4) striving for innovative and preventative solutions.


As part of our work with the OFSG, we, along with other tech companies, have donated pro-bono advertising credit to Citizen’s Advice to support the work of the Take 5 to Stop Fraud campaign, with the aim to enable Take 5 messages to reach a significant proportion of the online population.


We understand the stress that being the victim of a scam can bring onto people's lives. Our focus continues to be helping people find accurate information on Twitter and feel informed about the way in which to report potential scams.


In June 2020, we launched an on-service tool to help people find supportive information if they are the victim of an online, phone or text message scam. The prompt, developed in conjunction with Citizens Advice, directs people to verified information and encourages people to report scams when they become aware of them. Our work with Citizens Advice has been integral in helping surface credible information and advice about scams to those on Twitter, further developing our work and partnerships in this space.


Expenditure by the Financial Conduct Authority (FCA) and other public bodies on your

platform to protect consumers


Details of advertisers and advertising campaigns, including ad spend, are confidential. However, the FCA may be willing to provide this information to the Committee directly. As noted above, we have provided pro-bono advertising credits to Citizens Advice to promote the Take Five campaign hosted by UK Finance.


Data transfer to identify and prevent fraud and other economic crime


We receive reports from users and partners about accounts that may be breaking the Twitter Rules on financial scams, alongside our own detection. More recently we have been looking at wider questions of information sharing as part of the Online Fraud Steering Group and look forward to continuing these cross industry discussions.


The FCA can make legal requests to Twitter through our Law Enforcement Portal. Furthermore, the FCA is an authorised reporter whereby their reports are escalated directly to the relevant team to review compliance with Twitter Ads Policies.


As with all information sharing, there are challenges relating to both GDPR and ensuring we protect the privacy of our users. However, we have been pleased to substantially deepen our partnership with the NECC, UK Finance and members of the Online Fraud Steering Group throughout 2021 to ensure that we are collaborating effectively on combating online fraud across the industry.


Revenue from unauthorised advertising of regulated products


Ensuring Twitter is a safe space for all users, including from fraud and scams, is a priority.

The Twitter Rules, including our Financial Scams and Ads Policy, are in place to ensure bad actors are not allowed on the platform - only when everyone feels safe to share their voice, can great conversations happen.


While we don't have the data available to share now, we are reviewing internally and continuing to explore information-sharing with the OFSG.


Compensation of customers for financial fraud


Ensuring all users remain safe is a priority across the company. We do not tolerate illegal, fraudulent content on our platform - we are aware of the dangerous implications this can have on people’s lives and remain vigilant in our approach to tackling this issue.


Responsibility for the content, placement and targeting of online advertising lies with the advertiser as set out in the UK’s non-broadcast advertising Code. As we note clearly on our website, advertisers in the UK should be aware of additional marketing regulations that may apply. Further information that may be found useful is available in the CAP Code and the resources provided by the Advertising Standards Authority.


Furthermore, the FCA regulates advertising for most financial services. Unlike law enforcement and other legal authorities, we are generally not in a position to ascertain what happens off-platform, where a fraudulent transaction would likely take place and thus, we would not be in a position to confirm a clear connection to a user having been involved with a scam as a result of their on platform experience.


Thank you for the opportunity to respond to these questions. Please do not hesitate to be in touch if you require further information.


Kind regards,




Katy Minshall, Head of UK Government, Public Policy & Philanthropy


December 2021