Russia’s Adaptability: How FIMI Systems and Telegram Loopholes Circumvent EU Sanctions

Russian Propaganda Finds New Ways to Evade EU Sanctions on Telegram

Despite Telegram’s December 2024 restrictions on EU-sanctioned Russian propaganda channels, a new study reveals an alarming array of tactics being used to circumvent these bans. Research by the Centre for Democracy and Rule of Law has uncovered sophisticated evasion methods that continue to allow Russian information manipulation to reach European audiences.

The persistence of Russian Foreign Information Manipulation and Interference (FIMI) within the EU stems from two critical factors: the remarkable adaptability of Russian propagandists following sanctions and significant technical gaps in Telegram’s platform architecture.

Russian state-affiliated media outlets began migrating to Telegram well before EU sanctions took effect. The Institute for Strategic Dialogue noted in a 2022 report that RT and Sputnik France actively promoted their Telegram channels in early 2022, with “Telegram” being their most frequently used term on Twitter during that period.

The Centre for Democracy and Rule of Law’s research identified several sophisticated evasion tactics. Sanctioned channels often operate under alternative names to avoid detection while continuing to function as components of banned propaganda networks. Russian actors also create duplicate channels that mirror sanctioned ones, with content carefully synchronized but selectively published to avoid obvious connections.

“A single sanctioned entity may maintain ‘unofficial’ copies, allowing it to expand reach and bypass restrictions,” the study states, noting that researchers found parallel RT channels with identical names and imagery.

Russian embassies across Europe have emerged as particularly problematic vectors. Their diplomatic status provides legal cover for disseminating content from sanctioned outlets, effectively turning official diplomatic channels into propaganda distribution networks. According to the Institute for Strategic Dialogue, the Russian Embassy in France essentially replaced the blocked RT France and Sputnik operations, becoming the main conduit for Kremlin narratives since March 2022.

Another concerning trend is the cross-language dissemination of Russian propaganda. Content originally created in Russian is systematically translated and spread via Telegram channels in multiple European languages, dramatically expanding potential audience reach beyond Russian-speaking communities.

Researchers also identified a new strategy: Russian propaganda channels are now encouraging users to transition to Max, a Russian messenger released in 2025 by VK (the company behind Vkontakte, Russia’s Facebook equivalent). This suggests Russian actors are already preparing contingency platforms should Telegram face stricter regulations.

Telegram’s technical infrastructure appears particularly vulnerable to exploitation. The platform’s enforcement of EU sanctions remains inconsistent and selective. The Centre for Democracy and Rule of Law found that while the EU suspended 27 Kremlin-backed propaganda resources, Telegram has only blocked channels for 16 of these entities. Nine sanctioned organizations maintain fully accessible channels without restrictions.

Telegra.ph, an anonymous publishing service developed by Telegram itself, provides another backdoor for sanctioned content. This platform allows actors to bypass both sanctions-related restrictions and additional checks that might apply to official state-affiliated domains. The Russian Embassy in France, for example, uses Telegra.ph to publish full translations of content, even when the same material is available on official Russian government websites.

Telegram’s forwarding function presents yet another vulnerability. Even when a channel is blocked, its content can be instantaneously forwarded to non-restricted channels, giving users complete access to sanctioned material including text, images, videos, and audio.

Compounding these issues is Telegram’s ambiguous regulatory status within the European Union. The platform has not been designated as a Very Large Online Platform (VLOP) under the Digital Services Act (DSA), which would subject it to more stringent oversight. This classification hinges on user numbers, which Telegram has provided only in rounded form, complicating regulatory assessment.

In August 2024, the European Commission’s Joint Research Centre launched a technical investigation into Telegram’s user numbers, citing Article 24 of the DSA. Additionally, Telegram is not a signatory to the enhanced Code of Practice on Disinformation, and its internal policy on misinformation provides no specific mechanism for users to report false information.

Experts recommend a multi-faceted approach to address these challenges. The EU needs more coordinated, granular monitoring of information environments to rapidly identify masked distribution channels. Member States must invest in media literacy programs to empower citizens to critically assess content from propagandists.

As the report concludes, “Only a strategy that simultaneously strengthens regulation, ensures platform accountability, and builds cognitive resistance among its citizens can effectively counter this threat.”