Select Subcommittee Seeks Information from Apple and Google on Telegram’s Role in Pandemic Fraud 

Mar 24, 2022
Press Release
Clyburn asks companies to explain Telegram’s apparent violation of terms of service barring facilitation of illegal activity

Washington, D.C. (March 24, 2022) – Yesterday, Rep. James E. Clyburn, Chairman of the Select Subcommittee on the Coronavirus Crisis, sent letters Alphabet Inc., the parent company of Google, and Apple Inc. requesting information relevant to the Select Subcommittee’s ongoing investigation of fraud against pandemic relief programs being facilitated on Telegram, a popular social media and messaging application.

“Telegram has served as a platform for extensive and widespread dissemination of instructions for evading fraud controls for the Paycheck Protection Program (PPP), Economic Injury Disaster Loan (EIDL) program, unemployment insurance, and the Restaurant Revitalization Fund (RRF).  The availability of these instructions on Telegram may have enabled bad actors to commit large-scale fraud,” wrote Chairman Clyburn in the letters to the companies. “Troublingly, such facilitation of widespread fraud appears to be consistent with Telegram’s terms of service.  This activity is not consistent, however, with [Alphabet’s and Apple’s] publicly available standards and terms of service for application developers, which explicitly prohibit applications from being used to facilitate the commission of unlawful conduct.”

The Select Subcommittee previously sent a letter to Telegram requesting documents and information related to its prevention and monitoring of illegal activity and/or content.  With over a billion downloads, 500 million active users, and a potential $30 billion valuation, Telegram is among the most downloaded applications in the world with access to substantial resources.

Telegram’s channels have included advertisements on the sale of stolen identities, and featured discussions on how to use stolen identities to aid in the commission of pandemic relief fraud. Chairman Clyburn noted in the letters:  “This is particularly concerning because people whose stolen identities have been used to apply for pandemic aid, like unemployment insurance, will subsequently face great difficulty in lawfully obtaining such aid for themselves.

The only prohibitions in Telegram’s terms of service are “scam[ming]” other Telegram users anywhere in the application and promoting violence and posting illegal pornographic content on “publicly viewable” channels alone (violence promotion and illegal pornography are apparently allowed on so-called “private” Telegram channels, which permit up to 200,000 users).  With these lax standards, Telegram has served as a hub for the dissemination of detailed instructions for evading pandemic relief fraud controls and for sharing information to aid those seeking to perpetrate fraud against pandemic programs and American taxpayers.

Both Google Play’s Developer Program Policies and the Apple Developer Program License Agreement prohibit apps from being used to “facilitate” illegal activities.  Even with multiple public reports detailing the use of Telegram by bad actors to facilitate fraud, it is unclear whether Alphabet and Apple have taken any actions to require Telegram to prevent its platform from being used to aid large-scale fraud.

Chairman Clyburn requested documents and information from Alphabet and Apple regarding their relationship and communications with Telegram and their policies and practices related to applications on their platforms that facilitate fraud or spread coronavirus misinformation, another dangerous activity widespread on Telegram that is the subject of a separate Select Subcommittee investigation.  The letters seek responses by April 7, 2022.

Click here to read Chairman Clyburn’s letter to Alphabet Inc.

Click here to read Chairman Clyburn’s letter to Apple Inc.

117th Congress