The Ofcom consultation on Call for evidence: Third phase of online safety regulation - Which? response

Which? welcomes this opportunity to respond to Ofcom’s call for evidence. It is crucial that online services put in place strong protections to prevent fraudsters from using online advertising to reach consumers. Our evidence shows that: 

• Fraudsters use advertising as a mechanism to reach consumers at scale.
• Fraudsters are flexible and use different types of advertising to attract consumers and evade restrictions on specific advertising areas.

In order for online services to protect consumers from fraudulent advertising they must introduce effective onboarding Know Your Customer checks. 

• KYC checks are an established element of fraud prevention in financial services and would be a useful addition to online services.
• Checks should be used to establish that there is valid identity associated with the individual or business seeking to advertise and check that they are not associated with previous fraudulent activity.

There are proactive technologies that are useful in detecting fraudulent advertising: 

• URL detection techniques can take advantage of a wide range of public sector and private sector data on suspected fraudulent URLs.
• Machine learning and generative AI can be useful technologies for detecting potentially fraudulent advertising.