Time for Self-Serve Ad Platforms to Circle the Wagons?


ADOTAS – You’ve probably read about Google socking away $500 million to cover a settlement with the Justice Department over illegal online pharmacies’ use of Google advertising, presumably on a self-serve basis via Google AdWords.

Everyone, including Google (which has taken measures to curtail their activity), was well aware of these “rogue advertisers.” The question is whether Google could be accused of being complicit in or willfully ignorant of the activity… or something worse. Who knows. If you’re setting aside $500 million, it’s pretty bad.

Beyond Google, are self-serve platforms now exposed to the risk that lawmen could, at any time, unleash a volley of lawsuits and fines as punishment for the actions of a few bad apples?

If your software enables bad people to do bad things that you also profit from, you might as well assume that someone, somewhere could hold you partially liable, no matter how ignorant you claim to be of your advertisers’ misdeeds.

But given the inherently anonymous, hands-off nature of self-serve advertising, how can platforms mitigate the risk?

Fortunately for self-serve platforms, everything is automated (theoretically), which means everything is transactional, standardized and documented. If you’re turning a blind eye to illegal activity, this data trail represents a massive (i.e., $500 million) liability, but you can turn it to your advantage by establishing systematic policies, standards and audits to root out misbehavior.

What follows are a few ideas on how to go about this. Got more ideas? Already doing some of this stuff? Post a comment!

First, identify populations of “high risk” advertisers. Illegal activity can occur in any industry, but Google isn’t setting aside $500 million because of a few random, isolated scumbags. This pertains to systematic, widespread abuses by “rogue pharmacies” dating back years.

Do a little homework and start building your High Risk list. Gambling sites. Predatory lenders. The makers of “Johnny Space Commander Mask.” Anyone who might attract the attention of the government and get you in trouble.

Apply a stricter standard of due diligence to these groups. A more in-depth sign-up form, a quick call with an account rep or a keyword-based analysis of their ads and landing pages. Build simple, repeatable mechanisms that will allow red flags to bubble to the surface for closer examination.

Establish standardized “checkpoints” for advertisers. In many cases, these checkpoints could remain completely behind the scenes.

For example, a checkpoint could be linked to ad spend—if an advertiser wants to increase their spend to “X” daily/weekly/monthly budget, ask them to fill out a quick online questionnaire. If they lie about what they’re up to, you’ll be just a little less culpable. Go ahead and be clear that the questionnaire is meant to keep your platform free of baddies. Your legitimate advertisers will appreciate your efforts to take their unscrupulous competitors out of the picture.

You could tie checkpoints to other advertiser behaviors, such as constantly changing landing page URLs and domains. Basically, define your “normal” advertisers and then eyeball the advertisers whose behavior takes them outside those bounds.

Just make sure your team uses these checkpoint events as an excuse to look in on the advertiser’s activity. But don’t leave the detective work up to commission-based staff. When sales incentives conflict with business objectives, people are forced to choose between their paychecks and doing the right thing. You’re asking for problems to be ignored or swept under the rug.

Does extra due diligence necessitate additional overhead and hassle for a self-serve platform? Yes, unfortunately it does (insert Unregulated Free Market rejoinder here). But the alternative involves a) profiting from illegal activity and b) risking investigations and lawsuits from the gub’mint. Not to mention that relying on profits from illegal online advertisers is a short-sighted strategy.

So whether or not your moral scruples can get the best of your greed or ambivalence, if the government has decided that self-serve advertising isn’t a free-for-all, then this all just becomes an exercise in covering your ass.


  1. Automated due diligence on web sites is quite possible. We’ve been doing it for years. Now it’s necessary.

    First filter: is the actual name and address of the business on the web site? If not, and the site is selling something, the owner of the site is committing a criminal offense in many jurisdictions. (California B&P code §17538, European Electronic Commerce Directive (2000/31/EC)).

    Second filter: now that we have the name and address of the business, is it legit? Can we find it in corporate registrations? BBBonline? Dun and Bradstreet? SEC filings? Companies House in the UK? Provincial registries in China? If not, it’s not legit.

    Once we have that info, we can do a proper due diligence on the company. The data is available for most countries, and for major companies in all countries.

    If you’re not doing this, you’re doing it wrong.

    John Nagle / SiteTruth


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