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Unlike Silicon Valley giants such as Facebook and Twitter, which run very public anti-disinformation programs, Brooking said: "Telegram is famously lax or absent in its content moderation policy." This provided opportunity to their linked entities to offload their shares at higher prices and make significant profits at the cost of unsuspecting retail investors. Emerson Brooking, a disinformation expert at the Atlantic Council's Digital Forensic Research Lab, said: "Back in the Wild West period of content moderation, like 2014 or 2015, maybe they could have gotten away with it, but it stands in marked contrast with how other companies run themselves today." At the start of 2018, the company attempted to launch an Initial Coin Offering (ICO) which would enable it to enable payments (and earn the cash that comes from doing so). The initial signals were promising, especially given Telegram’s user base is already fairly crypto-savvy. It raised an initial tranche of cash – worth more than a billion dollars – to help develop the coin before opening sales to the public. Unfortunately, third-party sales of coins bought in those initial fundraising rounds raised the ire of the SEC, which brought the hammer down on the whole operation. In 2020, officials ordered Telegram to pay a fine of $18.5 million and hand back much of the cash that it had raised. Oleksandra Matviichuk, a Kyiv-based lawyer and head of the Center for Civil Liberties, called Durov’s position "very weak," and urged concrete improvements.
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