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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." Additionally, investors are often instructed to deposit monies into personal bank accounts of individuals who claim to represent a legitimate entity, and/or into an unrelated corporate account. To lend credence and to lure unsuspecting victims, perpetrators usually claim that their entity and/or the investment schemes are approved by financial authorities. Oleksandra Matviichuk, a Kyiv-based lawyer and head of the Center for Civil Liberties, called Durov’s position "very weak," and urged concrete improvements. "There are several million Russians who can lift their head up from propaganda and try to look for other sources, and I'd say that most look for it on Telegram," he said. 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.
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