Policy Report



Gulizar Haciyakupoglu, Jennifer Yang Hui, V. S. Suguna,
Dymples Leong, and Muhammad Faizal Bin Abdul Rahman
March 2018


Table of Contents
Introduction……………………………………………………………………………………………………………….. 2
Legislating Fake News: Global Case Studies………………………………………………………………….. 3
Legislative Proposals…………………………………………………………………………………………………… 3
Accountable Party: Technology companies………………………………………………………………….. .3
Accountable Party: Individuals ……………………………………………………………………………….. ….5
New Technological Dynamics ………………………………………………………………………………… …..6
Extraterritorial Legal Application……………………………………………………………………………….. 6
Non-Legislative Measures …………………………………………………………………………………………. 6
Recommendations …………………………………………………………………………………………………….. 8
Pre-Emptive Measures ………………………………………………………………………………………………. 9
Collaborative Engagements ………………………………………………………………………………………. .9
Immediate Measures ………………………………………………………………………………………………. 11
Long-Term Measures: Media Literacy and Social Norms ……………………………………………..12
Legislating Fake News: A Silver Bullet?………………………………………………………………………12
Appendix A ……………………………………………………………………………………………………………..14
Appendix B ……………………………………………………………………………………………………………..19
About the Authors ……………………………………………………………………………………………………21
About the Centre of Excellence for National Security …………………………………………………….22
About the S. Rajaratnam School of International Studies ……………………………………………….22


Executive Summary Governments worldwide are taking various steps to counter the scourge of fake news, which may be driven by different motivations, but most onerous are those that serve as a tool for disinformation; i.e. to undermine national security. Key among these steps is the introduction of new legislation:

  • New laws that are being proposed or have been passed would give governments more powers to hold technology companies (e.g., Facebook, Twitter and Google) and individuals accountable for the spread of fake news.
  • Laws would also seek to counter the impact of automated social media accounts (bots). In response, technology companies have intensified efforts to defend themselves and are enhancing capabilities to detect and remove fake news.
  • At present, it is too early the gauge the impact of legislation

Legislation however would face certain challenges and thus should be complemented by a continuum of non-legislative measures including:

  • Pre-emptive measures that are focused on an issue (i.e., elections) and supplemented by continuous collaborative engagements with the industry, non-governmental sector and regional fora;
  • Immediate measures that comprise an agile crisis communications plan and fact-checking initiatives; and
  • Long-term measures that strengthen social resilience through media literacy, inculcation of social norms on responsible information sharing, and defining the responsibilities of technology companies.

Going forward, a multi-pronged strategy that comprises both legislation and non-legislative measures — given that each have their challenges — would form a more sustainable bulwark against fake news.



Fake news, while not a novel phenomenon,1 has seized global attention in the wake of the US
presidential election in 2016. Fake news in the digital era span a spectrum of categories, with varied but
at times overlapping motivations: political, subversive, financial and entertainment.2 The impact of fake
news is amplified through: (i) internet platforms, which publish content with significantly lower cost, wider
reach and rapid circulation; (ii) social media, which enables more people and groups of various
persuasions to interact even as they consume, produce and re-circulate content; and (iii) artificial
intelligence (AI) agents that automate the work of human propagators. The term “fake news” is also used
by parties to denigrate content or points of view at odds with their own beliefs.3
Fake news becomes a national security issue when it undermines the foundations (e.g., social cohesion,
public institutions, peace and order) of the nation state. In this regard, fake news could serve as a tool for
disinformation campaigns: the intentional dissemination of false information for influencing opinions or
policies of the receiving audience.4 An example is the revelation that Russian operatives have uploaded
socially and politically divisive social media content to influence the outcome of the 2016 US Presidential
election.5 A notable case in Singapore is the conviction of a couple in 2016 for operating a seditious
website (The Real Singapore) that generated advertising revenue by propagating falsehoods that fuelled
xenophobia.6 Unsurprisingly, researchers and policymakers worldwide have sought not just to understand
the phenomenon, but also to develop strategies, including new laws, to curb its spread.


  1. 1 Before the advent of the Internet, the phenomenon was seen as propaganda in which the mass media had been a vehicle for propaganda that was exploited by both state and non-state actors to push messages that distort the opinions and emotions of people largely for the promotion of certain political agenda or ideology.
  2. 2 “Infographic: Beyond Fake News — 10 Types of Misleading News,” European Association for Viewers Interest (EAVI), accessed November 7, 2017, https://eavi.eu/beyond-fake-news-10-types-misleading-info/.
  3. 3 James Carson, “What is fake news? Its origins and how it grew in 2016,” The Telegraph, March 16, 2017, http://www.telegraph.co.uk/technology/0/fake-news-origins-grew-2016/.
  4. 4 Naja Bentzen, “Understanding disinformation and fake news,” European Parliament Think Tank, accessed November 7, 2017, http://www.europarl.europa.eu/RegData/etudes/ATAG/2017/599408/EPRS_ATA (2017)599408_EN.pdf.
  5. 5 “Russia-linked posts reached 126m Facebook users in US,” BBC, October 31, 2017, http://www.bbc.com/news/world-us-canada-41812369.
  6. 6 Pearl Lee, “TRS co-founder Yang Kaiheng jailed 8 months for sedition,” The Straits Times, June 28, 2016, http://www.straitstimes.com/singapore/courts-crime/trs-co-founder-yang-kaiheng-jailed-8-months-for-sedition.

Legislating Fake News: Global Case Studies 7

Some countries see legislation as being the best approach to counter fake news. In the legislation
proposals, accountability is mostly placed on technology companies, but also individuals. New
technological dynamics are also taken into account by the proposals.

Legislative Proposals

Accountable Party: Technology companies
Several proposed legislation hold technology companies accountable for the dissemination of fake news,
call for faster removal of offending content, recommend steep fines and imprisonment for failure to
contain fake news dissemination. The German Network Enforcement Act, for instance, imposes fines as
much as 50 million euros (US$53 million) on social media companies if they fail to remove “obviously
illegal” content within 24 hours upon receiving a complaint.8 For offensive online material that requires
further assessment, the Act compels companies to block the offending content within seven days, failing
which a fine will be imposed.

Responses from Technology companies
Technology companies have been intensifying efforts to combat fake news. Facebook, in addition to
enhancing machine learning and increasing its efforts to remove accounts,9 pledged to add more than
1,000 people to its global ads review teams over the next year to inspect political ad purchases. Twitter


7,See Appendix A.
8.Illegal content includes hate speech, defamation and incitements to violence. See Hillary Grigonis, “Delete hate speech or lose millions, the German Network Enforcement Act says,” Digital Trends, June 30, 2017, accessed 10 November 2017, https://www.digitaltrends.com/social-media/network-enforcement-act-germany/.
9. Colin Stretch, “Hearing before the United States Senate Committee on the Judiciary Subcommittee on Crime and Terrorism — Testimony of Colin Stretch, General Counsel, Facebook,” Committee on the Judiciary, October 31, 2017, https://www.judiciary.senate.gov/imo/media/doc/10-31-17%20Watts%20Testimony.pdf.


has vowed to increase the precision of algorithmic tools to combat disinformation.10 The micro-blogging
platform has also promised to update its community guidelines.11 Under the new measures, Twitter users
will be able to see details such as the types of ads targeted, ad duration, ad spend, the identity of
organisations and the demographics targeted by the ads. Google planned to release its election ad
transparency report in 2018, and provide its database to public for future research. Facebook, Google
and Twitter appeared in court on October 31 and November 1, 2017 to defend their role during the 2016
US presidential election.

US Congressional Hearing: Testimonies by Technology Companies

During the Senate hearings in November 2017, Facebook, Twitter and Google responded to questions on
the role of technology companies during the 2016 election. Investigations revealed that Russian-linked
entities such as the Internet Research Agency (IRA) used fake social media accounts to create content,
which undermined the election process. Fake accounts were used to purchase ads and post politically
divisive content in attempts to sow discord online. Facebook, for instance, has since estimated that
Russian content had reached about 126 million Americans on its platform.12
Intense scrutiny has been directed at technology companies for their failure to identify Russian-linked
fake accounts. In response, Twitter explained the steps taken during its internal investigations at
identifying and removing Russian-linked accounts.
13 While Google found activities associated with
suspected government-backed accounts of Russian origin, it stated that these activities had been
minimal. Due to the limited capability to target audiences on a micro-level, the company argued that there
were fewer cases of interference than alleged.14
Technology companies have also taken pains to emphasise their efforts in countering fake news. For
example, Twitter announced on 26 October 2017 — prior to the US Congressional hearings — its
decision to ban Russian news outlets such as Russia Today (RT) from advertising on its platform.15
Following the Senate hearings, the US government compelled RT to register with the Foreign Agents
Registration Act (FARA) of 1938, which required individuals acting as agents of foreign influence with the
capability to influence the government or public to “make periodic public disclosure of their relationship
with the foreign principal, as well as activities, receipts and disbursements in support of those activities.”16


10. Kent Walker, “House Permanent Select Committee on Intelligence Russia Investigative Task Force Hearing with Social Media Companies,” United States House of Representatives Permanent Select Committee, November 01, 2017, https://intelligence.house.gov/uploadedfiles/prepared_testimony_of_kent_walker_from_google.pdf.
11. Sean Edgett, “U.S. Senate Committee on the Judiciary: Opening Remarks,” Twitter Blog, October 31, 2017. https://blog.twitter.com/official/en_us/topics/company/2017/opening_remarks.html.
12.Mike Isaac and Daisuke Wakabayashi, “Russian influence reached 126 million through Facebook alone,” The New York Times, October 30, 2017, https://www.nytimes.com/2017/10/30/technology/facebook-google-russia.html.
13.Twitter had removed Russian-linked accounts that were active between 1 September and 15 November 2016 if they met any of the following criteria: (i) the accounts utilised Russian email addresses, mobile numbers or credit cards; (ii) Russia was the declared country on the account; or (iii) Russian language or Cyrillic characters appeared in the account information or name. See Sean Edgett, “United States House of Representatives Permanent Select Committee on Intelligence — Testimony of Sean J. Edgett, Acting General Counsel, Twitter, Inc.,” United States House of Representatives Permanent Select Committee, November 1, 2017, accessed November 16, 2017, https://intelligence.house.gov/uploadedfiles/prepared_testimony_of_sean_j._edgett_from_twitter.pdf.
14.Kent Walker. “House Permanent Select Committee on Intelligence Russia Investigative Task Force Hearing with Social Media Companies,” United States House of Representatives Permanent Select Committee, November 1, 2017, https://intelligence.house.gov/uploadedfiles/prepared_testimony_of_kent_walker_from_google.pdf
15.Dominic Rushe, “Twitter bans ads from RT and Sputnik over election interference,” The Guardian, October 26, 2017.
16.“Foreign Agents Registration Act (FARA),” The US Department of Justice, accessed November 28, 2017, https://www.fara.gov/

In a measure similar to FARA, Russia recently announced that it would require all foreign news agencies

Honest Ads Act

Technology companies are troubled over the proposed Honest Ads Act, a bipartisan US Senate bill
aiming to regulate online political advertising. The bill, if passed, will compel companies to disclose details
such as advertising spending, targeting strategies, buyers and funding. It would also require online
political campaigns to adhere to stringent disclosure conditions for advertising on traditional media.
Proponents claim such disclosures would result in added transparency towards online political
advertising. Technology companies have highlighted their efforts towards self-regulation such as the
voluntary contributions as well as the commitment towards fighting foreign interference and disinformation
on their platforms.

National Defense Authorisation Act (NDAA)

The US NDAA of 2017 approved the establishment of Global Engagement Center to “lead, synchronise,
and coordinate” Federal Government’s efforts to “counter foreign state and non-state propaganda and
disinformation efforts aimed at undermining United States national security interests.”18 The Center has
been instrumental in responding to the Islamic State of Iraq and the Levant’s (ISIL) “messaging.”

The 2018 version of NDAA, which was passed by Congress in July 2017, has gone a step further and
proposed several actions that specifically target Russian disinformation operations. Some of its proposed
actions include “joint, regional, and combined information operations and strategic communication
strategies to counter Russian Federation information warfare,” instalment of interagency measures to
manage and implement strategies against disinformation operations of Russia and further collaboration
with NATO Strategic Communications Center of Excellence (NATO StratCom COE).20
The NATO StratCom COE, established in 2014, regards strategic communication as an important
apparatus in realising military and political aims, and aspires to support friendly-forces’ strategic
communication processes through offering analysis, “timely advice”, and practical aid.21 Through the
declaration of its interest to further engage with NATO Stratcom COE, the US has signalled its
acknowledgement of the importance of international collaboration in countering disinformation operations.


Accountable Party: Individuals

Some legislation proposals recommend tough penalties for individuals found responsible for
disseminating false content. In the Philippines, for instance, the proposed Senate Bill No. 1492 threaten
those guilty of creating or distributing fake news with a fine ranging from P100, 000 (US$1,950) to P5
million (US$97,587) and 1 to 5 years of imprisonment.22 If the offender is a public official, fine and period
of imprisonment will be doubled. Offenders will be disqualified from holding any public office.


17.Thomas M. Hill, “Is the U.S. serious about countering Russia’s information war on democracies?” Brookings, November 21, 2017, https://www.brookings.edu/blog/order-from-chaos/2017/11/21/is-the-u-s-serious-aboutcountering-russias-information-war-on-democracies/.
18 “S.2943 — National Defense Authorization Act for Fiscal Year 2017,” Congress.Gov, accessed November 27, 2017, https://www.congress.gov/bill/114th-congress/senate-bill/2943/text.
19 “Global Engagement Center”, US Department of State: Diplomacy in Action, accessed November 29, 2017, https://www.state.gov/r/gec/.
20 “H.R.2810 – National Defense Authorization Act for Fiscal Year 2018,” Congres.Gov, accessed November 27, 2017, https://www.congress.gov/bill/115th-congress/house-bill/2810/text
21 “About us”, NATO StratCom Centre of Excellence, accessed November 29, 2017, https://www.stratcomcoe.org/about-us.
22 “Senate Bill 1492: Anti Fake News Act of 2017,” Senate of the Philippines 17th Congress, accessed November 10, 2017 at https://www.senate.gov.ph/lis/bill_res.aspx?congress=17&q=SBN-1492.

Other recommended actions include regulatory measures such as identity management in registration of
online domains. A legislative bill submitted to the Italian Senate in February 2017 require individuals who
wish to open “an online platform aimed at publishing or disseminating information to the public” to notify
the territorial tribunal via certified email, and provide the name of the platform, URL, name and surname
of the administrator and tax number.23

New Technological Dynamics

New dynamics brought about by technological advancements is a concern for governments looking to
legislation to combat fake news. Justice Ministers in three German states, for example, have proposed
anti-botnet legislation to reduce the impact of automated social media accounts in disseminating fake
news. Botnets — networks comprising of remotely controlled computers — are suspected to have
engineered voter sentiments during recent events such as the United Kingdom European Union
membership referendum and the 2016 US elections.

Jenna Abrams, a popular Twitter account that attracted up to 70,000 followers through its support for US
President Donald J. Trump and advocacy of far-right views, for example, is believed to have been run by
the Russian propaganda machine to discredit the Democrats.24 The role of automated accounts in
influencing elections was raised during the US Senate hearings as well.

Extraterritorial Legal Application

To date, most proposed legislation against fake news does not directly address the issue of extraterritorial
application. However, some proposed bills do have extraterritorial implications. Germany’s Network
Enforcement Act mandated the establishment of a local point of contact for transnational technology
companies to cooperate with local law enforcement authorities on takedown requests. The proposed
Honest Ads Act, although framed generally in terms of protecting US domestic order, targets the role of
foreign nationals and seeks to prevent “contributions, expenditures, and disbursements for electioneering
communications… in the form of online advertising.”25

Non-Legislative Measures

Legislation alone is insufficient in countering fake news and would expectedly be an on-going subject of
study. Some countries prefer to beef up existing legislations instead of introducing new ones.

In Indonesia, online smear campaigns had affected electoral candidates’ standing in elections since 2012.
There are evidence that some of these politically-motivated smear campaigns have been aided by wellorganised
“fake news factories” such as the Saracen Cyber Team, an online syndicate that created many
social media accounts to spread hate speech for clients willing to pay for them.26 Online sectarian
narratives had polarised public opinion in the lead-up to the Jakarta gubernatorial elections in 2017 that
saw the defeat of former governor, Basuki Tjahaja Purnama, a Chinese Christian.27 The Indonesian


23.Francesca Fanucci, “How Italy wants to slam fake news: Use fines and prisons,” Media Power Monitor, 13 March 2017, http://mediapowermonitor.com/content/how-italy-wants-slam-fake-news-use-fines-and-prison.
24Caroline Mortimer, “Jenna Abram: Popular Far Right US Twitter account revealed as a Russian Propaganda Outlet,” The Independent, November 03, 2017, http://www.independent.co.uk/life-style/gadgets-andtech/news/jenna-abrams-twitter-account-russia-propaganda-far-right-voice-alt-tweet-blog-xenophobic-donalda8035411.html.
25.“S.1989 — Honest Ads Act: 115th Congress (2017-2018),” Congress.gov, accessed November 23, 2017, https://www.congress.gov/bill/115th-congress/senate-bill/1989.
26.Wahyudi Soeriaatmadja, “Indonesian police probe alleged fake news factory’s protest links,” The Straits Times, August 26, 2017, http://www.straitstimes.com/asia/se-asia/indonesian-police-probe-alleged-fake-news-factorysprotest-links.
27.Merlyna Lim, “Beyond fake news: social media and market-driven political campaigns,” The Conversation, September 05, 2017, https://theconversation.com/beyond-fake-news-social-media-and-market-driven-politicalcampaigns-78346


government hence has beefed up existing legislations not only by introducing new provisions28 but also
by issuing guidelines to aid their implementation29 and stepping up enforcement30 such as forming the
Police Multimedia Bureau in 2017. 31 This Bureau may be similar to the Centre against Terrorism and
Hybrid Threats in Czech Republic, which also aims to counter disinformation campaigns.32

Some countries prefer to implement non-legislative measures such as fact-checking and counter fake
news websites. 33 Malaysia had introduced an information verification website (sebenarnya.my) to counter
fake news34 while Qatar had launched the “Lift the Blockade” website to fight disinformation campaigns
and provide its own perspective.35

Non-legislative measures may also inculcate media literacy and critical thinking. Countries such as
Canada, Italy and Taiwan are introducing school curriculum that teaches children to discern between
false and credible information.36 In recognising the role of online opinion leaders, some country leaders
such as Indonesian President Joko Widodo had encouraged social media influencers to fight fake news
by promoting unity.37

Governments are also funding research into using technology such as artificial intelligence (AI) and
machine learning (ML) to counter fake news. The US National Science Foundation has supported
projects such as ClaimBuster, which uses national language processing techniques to spot factual claims
within texts.38 ClaimBuster has been used to check facts during the US 2016 presidential election.39 The
software has also checked Hansard, the report of the proceedings of the Australian parliament and its
committees, for possible false claims on a wide variety of issues of national interest such as budget and


28.Kristo Molina, “Indonesian Electronic Information and Transactions Law Amended,” White & Case, December 15, 2016, https://www.whitecase.com/publications/alert/indonesian-electronic-information-and-transactions-lawamended
29.In 2015, the Indonesian National Police issued Circular SE/06/X/2015 to guide law enforcement in implementing existing legislation against hate speech. See Azyumardi Azra, “Hate Speech and Freedom,” Republika, November 05, 2015, http://www.republika.co.id/berita/en/resonance/15/11/05/nxc6o1317-hate-speech-and-freedom. See also Abubakar, “Managing hate speech or muzzling freedom of expression?”
30. The Indonesian government has enforced existing legislation such as Article 156 and 156(a) of the Criminal Code
(KUHP). See Irfan Abubakar, “Managing hate speech or muzzling freedom of expression?” Indonesia at Melbourne,
November 20, 2015, http://indonesiaatmelbourne.unimelb.edu.au/surat-edaran-hate-speech-freedom-expression/.
31.Farouk Arnaz, “National Police Form New Unit to Tackle ‘Fake News’ on Social Media,” Jakarta Globe, February
22, 2017, http://jakartaglobe.id/news/national-police-form-new-unit-to-tackle-fake-news-on-social-media/. See also Margareth S. Aritonang, “National Police to enlarge institution focusing on cybercrimes,” The Jakarta Post,
32. Robert Tait, “Czech Republic to fight ‘fake news’ with specialist unit,” The Guardian, December 28, 2016,
33.  See Appendix B.
34.  Fairuz Mohd Shahar, “Communications Ministry launches sebenarnya.my to quash fake news, information,” New
Straits Times, March 14, 2017, https://www.nst.com.my/news/2017/03/220604/communications-ministry-launchessebenarnyamy-quash-fake-news-information.
35. Victoria Scott, “Qatar launches new website to counter ‘fake news’,” Doha News, September 19, 2017,
https://dohanews.co/qatar-launches-new-website-to-counter-fake-news/. See also “Overview,” Lift the Blockage,
accessed November 22, 2017, https://lifttheblockade.com/overview/.
36 See Appendix B.
37 “Jokowi tells social media influencers to step up fight against fake news”, The Jakarta Post, August 24, 2017,
38. ClaimBuster website, accessed November 23, 2017 at http://idir-server2.uta.edu/claimbuster/.
39. “UTA researchers are refining their automated fact-checking system”, EurekAlert!, August 24, 2017, accessed
40. Naeemul Hassan, et al, “ClaimBuster: The First-ever End-to-end Fact-checking System,” Proceedings of the VLDB Endowment 10, No. 12 (2017): 1945-1948.

                                 Figure 1: CENS multi-pronged framework for combatting fake news

Attempts to legislate fake news inevitably face challenges. Due to the speed and wide reach of
information dissemination, as well as the ambiguity of what exactly constitutes fake news, using
legislation to combat fake news is challenging.

Legal measures to target fake news may result in unexpected scenarios. First, removing fake news may
give rise to the so-called “Streisand effect”, whereby deleting content increases audience attention on it.
In China, for example, aggressive efforts to censor social media posts that are not in line with the
government’s narrative reinforced some netizens’ belief that the censored posts represent the true state
of matter, while dismissing officially sanctioned newspapers as government propaganda.41 In this state,
netizens are more likely to seek and trust news from alternative sources than before. Second, with the
prospect of hefty fines looming over them, social media companies are likely to err on the side of caution
by aggressively removing posts, driving healthy discourse underground.


41.Jing Zeng, Chung-Hong Chan, King-Wah Fu and David Sutcliffe, “Censorship or rumour management? How Weibo
constructs “truth” around crisis events,” The Policy and Internet blog, October 03, 2017,


Given the aforementioned challenges, a multi-pronged approach will provide a more thorough means to
combat fake news. This approach combines pre-emptive, immediate as well as long-term measures as
part of a broad framework in countering fake news.

Pre-emptive Measures

Pre-emptive measures that are conducted in a collaborative manner to target the issue at hand should be
taken against fake news. An issue-focused approach to combat fake news is formed for particular
purposes such as elections. This allows targeted definition of fake news in a particular context thus
expedites the identification of related fictitious information. Collaboration on the other hand: (i) facilitates
the exchange of knowledge and skills; (ii) narrows the gap between local and global; (iii) helps identify
overlapping concerns between different issues and contexts; and (iv) allows the transmission of a
consistent message. Issue-focused, collaborative measures aimed at preventing the spread of fake news
would facilitate a prompt and lasting response, and they would yield better results than isolated efforts
that lack focus.

In the recent French and German elections, collaborative efforts focused on the issue of elections helped
raise awareness on the danger of fake news. The measures taken also obstructed the circulation of
fictitious information to some extent. Before the German elections, Facebook had been assisting the
government through cooperation with the German Federal Office for Information Security, educating
political candidates on online security concerns, and launching a channel dedicated to the “reports of
election security and integrity issues.”42 The social media giant also terminated 30,000 accounts in
France43 and provided its users with various online tools such as a guide for spotting fake news and
finding out and comparing candidates’ “campaign promises” in the lead-up to the French elections.44 The
First Draft-led fact-checking initiatives of CrossCheck (France) and WahlCheck17 (Germany) were other
examples of pre-emptive collaborative actions that focused on a particular issue: elections.45

Collaborative Engagements

Collaborations to combat fake news may comprise: (i) regional engagements; (ii) non-governmental
collaborative efforts; and (iii) government-industry partnerships. The cooperating entities should agree on
the rules of engagement, actions that have to be taken in a given timeline, and the responsibilities of each
party. In the course of the perpetual collaborations, rules of engagement have to be revised in light of the
analysis of the changing conditions and the outcomes of implemented policies.

Regional Collaborations: Combating Fake News in ASEAN

Fake news should be countered through concurrent efforts at the regional and international fora to share
experiences and collaborate in mutually acceptable areas. For Southeast Asian states (AMS), the
roundtable in September 2017 by the ASEAN Ministers Responsible for Information (AMRI) has set the
stage for regional collaboration.46


42.Josh Constine, “11 ways Facebook tried to thwart election interference in Germany,” TechCrunch, September 27,
2017, https://techcrunch.com/2017/09/27/facebook-election-interference/.
43 Eric Auchard and Joseph Menn, “Facebook cracks down on 30,000 fake accounts in France,” Reuters, April 14,
2017, https://www.reuters.com/article/us-france-security-facebook/facebook-cracks-down-on-30000-fake-accountsin-france-idUSKBN17F25G.
44 Marie Mawad, “French Election is Facebook’s Fake News Litmus Test,” Bloomberg Technology, April 27, 2017,
45 See section on Extra-Governmental Collaborations.
46 “ASEAN to cooperate on fighting fake news in the region”, Association of Southeast Asian Nations (ASEAN),
September 13, 2017, http://asean.org/asean-to-cooperate-on-fighting-fake-news-in-the-region/.


As the ASEAN Chair in 2018, Singapore will be well positioned to promote concrete efforts. It is important
for these efforts to facilitate joint research in the fake news phenomenon in order to develop effective
countermeasures that consider not only what the message said, but also its presentation, author, format
as well as context.47

Going forward, AMS could study the experiences of other regional blocs particularly the European Union
(EU), which formed the EU East StratCom Taskforce in 2015 to counter Russia’s disinformation
campaigns.48 The task force serves as a regional mechanism that enables collaboration with a wide
network of government officials, experts, journalists and think tanks.49 The task force’s activities dovetail
with the strategic communications activities of NATO (North Atlantic Treaty Organisation), which include
countering the use of disinformation campaigns by Russia for its geopolitical goals (e.g., in Ukraine).50
While the EU’s and NATO’s models center on a specific concern (i.e. Russia), there are nonetheless
merits in studying these models with the view of introducing similar strategies customised to Southeast
Asia’s cultural and political landscape. To avoid over-securitisation of fake news and in line with the AMRI
meeting in September 2017, regional efforts to counter fake news could be subsumed under the actions
plan of the ASEAN Socio-Cultural Community.

Extra-Governmental Collaborations

Extra-governmental alliances should form part of the framework for countering fake news. “StopFake,” for
instance, is a multi-pronged initiative created by Kyiv Mohyla Journalism School and the KMA Digital
Future of Journalism project in 2014 in Ukraine. It is also supported by the efforts of IT professionals,
translators, journalists, and others concerned about inaccurate information.51 Its main goal is to counter
Russian disinformation operations and assess the impact of fake news in Ukraine and other countries.
52 “StopFake” offers opinion pieces, detailed outlook on Russian disinformation operations, access to
researches on the issue, guidance on verifying fake information, and videos debunking fake news, which
are broadcasted on their site and in local TVs.53

First Draft is another initiative that brings together a “non-profit coalition” against disinformation. The
coalition comprises: (i) technology companies (e.g., Google News Lab, Facebook and Twitter); (ii)
academic and research institutions (e.g., University of Southern California Annenberg School of
Communication and Journalism, Tufts Fletcher School and Public Data Lab); (iii) newsrooms (e.g., The
Washington Post, Reuters and The Guardian); and (iv) other similar-minded organisations (e.g.,
FactCheck Initiative Japan and Now This).54 First Draft helped counter fake news during the French
elections with its CrossCheck initiative, which congregated 37 newsrooms in France and UK to identify
and debunk election-related fake news.55 During the German elections, First Draft, in cooperation with


47. Victoria L. Rubin, “Deception Detection and Rumor Debunking for Social Media,” The SAGE Handbook of Social
Media Research Methods, London (2017): 21, https://uk.sagepub.com/en-gb/eur/the-sage-handbook-ofsocialmedia-research-methods/book245370.
48 “Questions and Answers about the East StratCom Task Force,” European Union External Action, November 8,
2017, https://eeas.europa.eu/headquarters/headquartershomepage_en/2116/%20Questions%20and%20Answers%20about%20the%20East%20StratCom%20Task%20For
49 “EU strategic communications with a view to counteracting propaganda,” European Parliament, DirectorateGeneral
for External Policies, Policy Department, (May 2016): 16,
http://www.europarl.europa.eu/thinktank/en/document.html?reference=EXPO_IDA (2016)578008.
50 “Digital Hydra: Security Implications of False Information Online,” NATO Strategic Communications Centre of
Excellence Riga, Latvia, November 8, 2017, https://www.stratcomcoe.org/digital-hydra-security-implications-falseinformation-online.
51 “About us,” StopFake.org, accessed November 28, 2017, https://www.stopfake.org/en/about-us/.
52 Ibid.
53 StopFake.org, accessed November 28, 2017, http://test.stopfake.org/en/.
54 “About,” First Draft, accessed January 8, 2018, https://firstdraftnews.com/about/.
55 “Our Projects — CROSSCHECK,” First Draft, accessed November 28, 2017,


CORRECTIV, a “non-profit investigative newsroom” for German speakers,56 spearheaded a similar
initiative called WahlCheck 17.57 Yet another initiative, the International Fact Checking Network, has been
coordinating and training fact-checkers around the world.58

A multi-pronged framework against fake news can tap on extra-governmental initiatives’ vast networks.
The diversity of participants’ skills and knowledge will aid in building credible narratives against fake
news. Collaboration with extra-governmental initiatives will also provide quick response to disinformation
campaigns as these initiatives will not be encumbered by bureaucratic demands.

Government-Industry Partnerships

Striking the right balance between data security and countering fake news is an on-going challenge. This
is because any attempt to compel technology companies to provide access to customer data (via legal or
alternative means) will invariably be perceived negatively. This might dissuade technology companies
from establishing subsidiaries in Singapore. Singapore, like Denmark,59 could create a digital ambassador
to engage with technology companies to determine how best to increase collaboration and minimise

Immediate Measures

Immediate measures comprise transparent, timely and accurate communication carried out in tandem
with affected bodies to dispel confusing information. An agile crisis communication plan should be put in
place to provide an immediate response to disinformation operations. Inter-agency scenario planning and
mock crisis exercises must be conducted on a regular basis to ensure crisis communication plans stay

Other immediate measures include fake news flagging initiatives and fact-checking websites. Fake news
flagging allow social media users and companies to tag fictitious information in order to alert other
readers, while fact-checking websites debunk deceptive information. Both measures have proven timely
and effective in signalling false content to others.

An environment of trust is necessary for immediate measures to be effective. Governments need to retain
public trust through continuous, transparent communication with the public but this can be challenging
especially during times of conflicting information. NGOs, comprising of experts in the issues of interest,
can play a part due to their impartiality. For example, the Ukraine Crisis Media Center conducts “daily
briefings”, “roundtables” and “discussions” to unpack complex information on Ukraine and beyond.60


80.“About Correctiv,” Correctiv, accessed January 8, 2017, https://correctiv.org/en/correctiv/.
57 .Claire Wardle, “#WahlCheck17: Monitoring the German election,” First Draft, September 1, 2017,
58. International Fact Checking Network has gathered and trained fact-checkers around the globe. It offers analysis on the impact of fact checking since its establishment in 2015. See “Poynter is a Thought Leader,” Poynter, accessed
November 6, 2017, https://www.poynter.org/about-us/poynter-thought-leader.
59 Robbie Gramer, “Denmark Creates the World’s First Ever Digital Ambassador,” Foreign Policy, 27 January 2017,
accessed 27 March 2017, http://foreignpolicy.com/2017/01/27/denmark-creates-the-worlds-first-ever-digitalambassador-technology-europe-diplomacy/.
60 “About Press Center”, Ukraine Crisis Media Center, accessed November 28, 2017, http://uacrisis.org/about


Long-term Measures: Media Literacy and Social Norms

Long-term measures to counter fake news include: (i) initiatives to inculcate media literacy in schools that
the elderly may also find useful;61 (ii) encouraging social norms62 against fake news such as responsible
information sharing practices;63 and (iii) defining the responsibilities of technology companies in
countering fake news within the spectrum of collaborative engagements.

Legislating Fake News: A Silver Bullet?

It is currently too early to assess the negative and positive impacts of legislative initiatives against fake
news. However, any attempt to legislate against fake news would inevitably meet with difficulties given: (i)
issues on the definition of fake news; (ii) global dimension of the cyberspace vis-à-vis the territorial
boundaries of legislation; (iii) challenges in identifying the actual perpetrator of fake news; and (iv)
sophistication of disinformation campaigns. Content-related regulations in cyberspace would also face

First, it is important, yet difficult to “reconcile” online regulations with offline regime.64 For instance, while
pornography is illegal in many Asian countries, it is challenging to regulate such content in cyberspace.65
Second, variation in terms of what is legal and illegal in different countries66 meant that “foreign
undesirable materials”67 might continue to be available in other countries despite one nation’s efforts to
outlaw it. It is therefore difficult to harmonise conflicting cultural values embedded in digital information
content.68 For example, hate sites blocked by Germany, may still be accessible in neighbouring European
countries. These contents may also be accessible via virtual private network (VPN) despite Germany’s
efforts to restrict access to them.

Singapore has the necessary resources to adopt a comprehensive approach that incorporates the
abovementioned pre-emptive, immediate and long-term remedies to counter fake news. Moving forward,
Singapore could consider establishing an organisation — possibly non-governmental — that uses
grassroots participation to counter fake news. This organisation could carry out research and factchecking
initiatives, congregate various experts under its, and provide support for crisis communication
specific to disinformation operations. Akin to the StopFake initiative in Ukraine, this institution could: (i)
produce content for broadcast, print and social media to inform audience; (ii) offer trainings to media
professionals and other relevant parties; and (iii) educate digital information consumers through
alternative means such as incorporating gamification into fake news identification.

This organisation could collaborate with various government bodies to implement immediate and longterm
solutions. These solutions may include expanding policies on media literacy and critical thinking,
devising initiatives to establish healthy media consumption behaviours (e.g., information verification,
reading the entire piece, etc.) as social norms, as well as assist in the implementation of the aforementioned measures. The benefit of establishing such an organisation is that it can help to win the trust of citizens given its impartial stance, and integrate citizens in the fight against fake news. An extragovernmental entity can thus serve as a bridge that facilitate public-private partnership, establishing trust that result in constructive actions benefitting the government, industry and society as a whole.


61 The Italian government has collaborated with technology companies such as Facebook to train students in
recognising fake news. Taiwan schools are also planning to introduce curriculum to teach school children to
develop critical thinking online.
62 Social norms are one of the measures suggested for the regulation of the Internet. One example provided by Ang
Peng Hwa (2007) is the exclusion of people who do not adhere to the group norms from online chat groups. See
Ang Peng Hwa, “Framework for Regulating the Internet,” in The Internet and Governance in Asia: A Critical Reader,
ed. Indrajit Banjee (Asian Media Information and Communication Centre (AMIC) and Wee Kim Wee School of
Communication and Information Nanyang Technological University (WKWSCI-NTU):2007, 328, 329, 330.
63 Responsible information sharing practices include crosschecking, authenticating the source and the author as well as reading the information in full before sharing.
64 Hwa, “Framework,” 335.
65 Ibid
66 Ibid.
67 Ibid, 338.
68 Ibid.

trust of citizens given its impartial stance, and integrate citizens in the fight against fake news. An extragovernmental
entity can thus serve as a bridge that facilitate public-private partnership, establishing trust
that result in constructive actions benefitting the government, industry and society as a whole.


Moves worldwide to enact legislation against fake news are generally at a nascent stage, with it being too
early to attempt any holistic impact assessment. However, it is already clear that legislation must be
contemplated only as one part of a multi-pronged strategy. Such a strategy should incorporate preemptive
issue-focused measures, including collaborations with a wide variety of actors and organisations
(e.g., regional organisations, NGOs and technology companies), and it should encompass immediate
responses such as crisis communication and fact-checking measures, and long-term remedies such as
media literacy and fostering appropriate social norms.

Appendix A

Global Overview of Fake News Legislation (as at January 2018)


Appendix B

Government-Initiated Measures against Fake News (as at January 2018)

About the Authors

Gulizar Haciyakupoglu is a Research Fellow at the Centre of Excellence for National Security (CENS),
S. Rajaratnam School of International Studies (RSIS), Nanyang Technological University (NTU). Her
research interests include disinformation campaigns in cyberspace; online trust; the interplay between
Internet, communication and authority; gender equality advocacy in cyberspace; and feminism in Islam.
She holds a Ph.D. from the National University of Singapore (NUS), Communications and New Media
Department (CNM), and a MA on Political Communication from the University of Sheffield. She received
her bachelor’s degree on Global and International Affairs from the Dual-Diploma Program of the State
University of New York (SUNY) Binghamton and Bogazici University Turkey. Before embarking on an
academic career, she worked as a Channel Sales Manager at IBM Turkey.

Jennifer Yang Hui is an Associate Research Fellow at the Centre of Excellence for National Security
(CENS), a constituent unit of the S. Rajaratnam School of International Studies (RSIS), Nanyang
Technological University (NTU). Jennifer has an Honours degree in History from the National University of
Singapore (NUS). In 2010, she graduated as a Tun Dato Sir Cheng Lock Tan Master of Arts (M.A.)
scholar in Southeast Asian Studies, also from NUS. Prior to joining CENS, Jennifer had worked at the
National Archives of Singapore and the Institute of South East Asian Studies (ISEAS). While in CENS,
Jennifer is responsible for research in Social Media Analytics. Her other research interests are security
sector reform, ethno-religious relations and the role of the social media in contemporary Indonesia,
epistemology, knowledge making and their implications on digital maturity.

V. S. Suguna is an Associate Research Fellow with the Centre of Excellence for National Security
(CENS) at the S. Rajaratnam School of International Studies (RSIS). She holds a Master of Strategic
Studies from RSIS with a Certificate in Terrorism Studies and a Bachelor of Computing (Computer
Engineering) from the National University of Singapore. Prior to joining RSIS, Suguna has served as a
Staff Officer (Technology Branch) with the Singapore Prison Service (SPS) and was a Senior Executive in
the Crisis Preparedness Directorate of the Joint Operations Group (JOG) at the Singapore Ministry of
Home Affairs (MHA) where she helped coordinate inter-agency crisis exercises and facilitated
international engagements for sharing of best practices in crisis management. She is also a recipient of
the Commissioner of Prisons Team award in 2015 recognising her efforts in the implementation of the
Electronic Letters and other projects for SPS. Her research interests are in understanding the
psychological drivers of cybercrime and studying the dynamics of social resilience.

Dymples Leong is a Senior Analyst with Centre of Excellence for National Security (CENS) at the S.
Rajaratnam School of International Studies (RSIS), Nanyang Technological University, Singapore. She
attained her Bachelor of Business majoring in Marketing and Management from the University of
Newcastle Australia. Her research interests revolves around strategic communications, social media,
communication and global studies. She currently researches in the areas of behavioural insights and
policymaking, digital activism, and civic engagement online. Her commentaries have been published in
newspapers such as The Straits Times and the New Straits Times.

Muhammad Faizal is a Research Fellow with the Centre of Excellence for National Security (CENS), at
the S. Rajaratnam School of International Studies (RSIS). He holds a Bachelor of Business
Administration (with Merit), from the National University of Singapore. Prior to joining RSIS, Faizal served
with the Singapore Ministry of Home Affairs where he was a deputy director and had facilitated
international engagements with foreign security counterparts. He also had postings in the Singapore
Police Force where he supervised and performed intelligence analysis, achieving several commendation
awards including the Minister for Home Affairs National Day Award (2009), for operational and analysis
efficiency; and in the National Security Research Centre (NSRC), at the National Security Coordination
Secretariat (NSCS), where he led a team to research emergent trends in domestic security and monitor
terrorism-related developments. Faizal also has certifications in Counter-Terrorism, Crime Prevention and
Business Continuity Planning.

About the Centre of Excellence for National Security

The Centre of Excellence for National Security (CENS) is a research unit of the S. Rajaratnam School
of International Studies (RSIS) at the Nanyang Technological University, Singapore.

Established on 1 April 2006, CENS raison d’être is to raise the intellectual capital invested in strategising
national security. To do so, CENS is devoted to rigorous policy-relevant analysis across a range of
national security issues.

CENS is multinational in composition, comprising both Singaporeans and foreign analysts who are
specialists in various aspects of national and homeland security affairs. Besides fulltime analysts, CENS
further boosts its research capacity and keeps abreast of cutting-edge global trends in national security
research by maintaining and encouraging a steady stream of Visiting Fellows.

For more information about CENS, please visit https://www.rsis.edu.sg/research/cens/.

About the S. Rajaratnam School of International Studies

The S. Rajaratnam School of International Studies (RSIS) is a professional graduate school of
international affairs at the Nanyang Technological University, Singapore. RSIS’ mission is to develop a
community of scholars and policy analysts at the forefront of security studies and international affairs. Its
core functions are research, graduate education and networking. It produces cutting-edge research on
Asia Pacific Security, Multilateralism and Regionalism, Conflict Studies, Non-traditional Security,
International Political Economy, and Country and Region Studies. RSIS’ activities are aimed at assisting
policymakers to develop comprehensive approaches to strategic thinking on issues related to security
and stability in the Asia Pacific.
For more information about RSIS, please visit  www.rsis.edu.sg