OLYMPUS RISK INTELLIGENCE PROTOCOL — INSTITUTIONAL ASSESSMENT DIVISION CASE WTW-2026-119

GLOBAL DISINFORMATION INDEX

THE INSTITUTIONS THE REVENUE VALVE
APPARATUS — RATINGS-TO-ADVERTISER-DEFUNDING CHOKEPOINT
Status
ACTIVE — UK not-for-profit disinformation-ratings body, founded 2018; US federal funding lapsed 2023–2024
Standing — RCH / FND / ENT
4 / 6 / 6
Conduct
STATE-SEEDED DEFUNDING VALVE

Institutional Archetype

THE REVENUE VALVE — GDI does not take a page down and does not write a model’s refusals. It rates news outlets for “disinformation risk,” compiles the ratings into an exclusion list, and hands that list to the advertising exchanges that decide where ad money is allowed to land. The chokepoint is not the speech; it is the revenue behind the speech. An outlet stays online and simply stops being paid. This profile scores that mechanism — a ratings body seated upstream of the ad-tech spigot — not the private motives of the people who run it. The structural hazard is the position: a single non-governmental scorer whose list can move advertiser money away from named publications at scale.

Mandate & Origin

The Global Disinformation Index was founded in 2018 and is based in London. It states it is “a not-for-profit company; any surplus income generated will be 100% reinvested back into the organisation to further its mission.” Its self-stated mission is to “disrupt the monetisation of disinformation” — in its own words, “We estimate the profits earned from creating, sharing, and hosting harmful content online.” Per InfluenceWatch, its principals are Clare Melford (CEO) and co-founder Daniel Rogers. The operational product is a set of “Disinformation Risk Ratings” and a “dynamic exclusion list” of roughly 2,000 websites supplied to advertisers and ad-tech. GDI frames its own output as “an independent evidence base that enables policymakers, regulators, and industry to act” — the register is research; the applied form is a list that redirects money.

Funding & Backers

The funding diagram is the tell: a private scorer of American outlets, seeded in part by the US government. Per the Washington Examiner’s 2023 investigation and Senator Grassley’s letter to the State Department, GDI-linked entities received about $330,000 in US federal money — roughly $100,000 from the State Department’s Global Engagement Center (as part of a $250,000 U.S.-Paris Tech Challenge award split among grantees) and $230,000 in 2020 via the National Endowment for Democracy to the affiliated AN Foundation / Disinformation Index Foundation. Additional named backers include Open Society Foundations, the Knight Foundation, and Craig Newmark Philanthropies. The UK Foreign, Commonwealth and Development Office ceased funding GDI in 2023; the State Department’s Global Engagement Center — a documented funder of GDI, DFRLab-adjacent bodies, and others — lost its authority and shut down in December 2024.

The corporate and filing record, current. GDI is two corporations. Disinformation Index Ltd is a UK company limited by guarantee (No. 11297397), incorporated on 7 April 2018, registered at 124 City Road, London; Companies House lists Clare Melford as a director since 7 April 2018 and William Emmott since 23 September 2024 (Companies House). Disinformation Index, Inc. is the U.S. 501(c)(3), a Delaware corporation based in San Antonio, Texas (EIN 85-2450338); its Schedule R names the London company as its related organization. For calendar 2024 its return reports total revenue of $3,006,917, made up of $1,515,004 of contributions and grants and $1,491,846 of program-service revenue coded “RESEARCH LICENSING REV”; expenses of $2,999,025; 11 employees; net assets of $741,590; and $1,415,000 of grants paid, all in one cash grant to a recipient in Europe “TO FURTHER ITS EXEMPT PURPOSE” (Schedule F). Danny Rogers is president at $24,034 of reportable compensation, William Emmott is chair, and Clare Melford is secretary and treasurer, unpaid. The return describes the organization as “A NONPARTISAN ORGANIZATION THAT COMBATS DISINFORMATION BOTH IN THE UNITED STATES AND GLOBALLY THROUGH THE CREATION OF PUBLIC RATINGS OF MEDIA SOURCES THAT ASSESS THEIR DISINFORMATION RISK USING OBJECTIVE CRITERIA” (ProPublica, Form 990, calendar 2024; Schedule R; Schedule F).

Foundation and endowment money, from the funders’ side. The Open Society Foundations’ grants database lists two grants to Disinformation Index, Inc.: $150,000 in 2022 “to provide general support” (three months, global, Open Society Institute) and $250,000 in 2023 “to educate the public about disinformation and its harms” (one year, United States, Foundation to Promote Open Society) (OSF, grants). The National Endowment for Democracy’s statement of 24 February 2026 says it “provided limited funding to the UK-based Global Disinformation Index (GDI) for research examining vulnerabilities in foreign media environments, including China’s efforts to distort the information space,” that “NED never funded GDI’s work related to the United States,” and that when its leadership learned in early 2023 that GDI “had undertaken U.S.-related work for another donor,” it “placed the grant on hold, conducted a review, and within one week terminated the grant, recovered unspent funds, and informed Congress” (NED statement). GDI’s own site says, “We accept no funding from media companies or technology platforms” (GDI, About).

The federal ledger, from the government’s side. USAspending, queried for recipients named “Global Disinformation Index” and “Disinformation Index” across all federal award types on 23 October 2026, returns no award. The GEC and NED money described above therefore reached GDI through intermediaries or outside the federal award system, as the reporting and State’s reply to Senator Grassley describe, and does not appear as a direct federal award.

Institutional Voice & Intent

The register is that of a policy research shop: global, evidence-first, financial. The homepage says “Tackling online harms means following the money” and “GDI disrupts the monetisation of disinformation.” The About page draws the line against its old reputation: “GDI does not simply identify disinformation and flag it. GDI maps the revenues that sustain the business of harmful content creation online.” It claims an effect in dollars: “Our estimates suggest that approximately $200 million per year has been redirected away from high-risk news sites as a direct result of GDI’s and partner organisations’ work with the advertising industry” (GDI; GDI, About). On regulation, its Our Work page says “Voluntary commitments from platforms and advertisers have proven insufficient; lasting change requires enforceable frameworks” (GDI, Our Work). In its February 2026 complaint against the FTC, GDI described the list this way: “Each of GDI’s subscribers was free to use the DEL to inform its independent brand safety decisions or to disregard on a case-by-case basis, as it saw fit” (First Amended Complaint, Doc. 29).

Stated alignment: An “independent evidence base that enables policymakers, regulators, and industry to act,” neutral, “apolitical, global, and evidence-based.” Observed alignment: A research and licensing body that sold risk ratings and an exclusion list to the advertising chain, was funded by foundations and, through intermediaries, by US government programs, and now sells monetisation research to regulators. Gap assessment: The old file scored the list. The newer record says the list is gone: GDI’s own pleading says it “stopped publishing its DEL out of fear of further retaliation.” What remains is the position of a ratings body that regulators and advertisers still cite.

Stated intent: “Disrupt the monetisation of disinformation,” and make harmful-content revenue visible through its Online Harms Monetisation Dashboard so that “policymakers, regulators, civil society, and academia” can act (GDI, About).

Observed intent: Move from rating sites to measuring revenue and to advising the rulemakers. Its Our Work page says GDI “has advised Ofcom on the Online Safety Act” and “is also a signatory to the EU Code of Conduct on Disinformation.” Interest, as documented: the organization calls for “enforceable frameworks” on ad-tech monetisation, and its U.S. return books $1,491,846 of “RESEARCH LICENSING REV” in 2024. The two facts sit side by side in the record; neither is a claim about motive. Its own best case: the funding of harmful content runs through “the structural opacity of ad tech supply chains,” not a deliberate choice by advertisers, so the remedy is transparency. Other factions gain from the opposite rule: its complaint names the Chairman of the FTC, a Commissioner and members of Congress as critics, and NewsGuard has sued the same agency.

Gap: GDI’s defense, in its complaint, is that each subscriber “was free to use the DEL” or “to disregard” it. Its funding history cuts the other way: it took State Department-linked and NED money while the list was live, and NED’s statement says GDI’s U.S.-related work was done for another donor. The record cannot settle which of GDI’s U.S.-facing work was funded by whom, and the file does not assert it. For the valve, it never needs to.

  • Social accounts and feeds. LinkedIn is the only account linked from disinformationindex.org; no X, Bluesky or other account is linked, and no RSS feed was found at the usual paths (they return 404). The site’s blog and research indexes carry dated posts.

Position in the Apparatus

GDI occupies a ratings seat that regulators, advertisers and now AI evaluation all touch.

  • The ratings and the list. Its Dynamic Exclusion List “included a list of websites across the globe to inform advertisers, the ad tech industry, search and social media companies, and researchers around the world of the risks of advertisements being displayed adjacent to disinformation,” per GDI’s own complaint, which adds that it stopped publishing the list after the FTC’s demand (First Amended Complaint, above).
  • The regulator’s adviser. GDI says it advised Ofcom on the Online Safety Act and signed the EU Code of Conduct on Disinformation, “with specific contributions to ad transparency and reducing the monetisation of disinformation” (GDI, Our Work); see Ofcom and the Digital Services Act.
  • The model auditor. Its report of 12 October 2026 on large language models and Russian narratives states: “The two models reviewed in this study are Claude Sonnet and Mistral Large. Both were found on occasion to repeat Kremlin narratives ‘in their own voice’,” and “whoever owns the AI summary box on search engines, controls the narrative” (GDI, Russia benefitting from Data Voids to influence LLMs); see Anthropic. The finding is GDI’s own.
  • The target of the counter-apparatus. In the United States the opposing rule was set by the 8 April 2026 consent decree in Daily Wire v. State Department, which provides that the Department “will not fund, promote, or assist in the testing or development of any fact-checking, media-credibility rating, CPD, or media literacy tool” marketed for suppressing, demonetizing or downgrading protected speech of Americans or domestic media; the decree does not name GDI (Consent decree, Doc. 131; see Global Engagement Center).
PatternMatch LevelEvidence
The Revenue ValveHIGHThe exclusion list for advertisers, as GDI itself describes it; the effect GDI claims, $200 million a year.
The Regulator’s AdviserMODERATEAdvised Ofcom and signed the EU disinformation code, per its own page.
The Model AuditorMODERATEOctober 2026 report testing two named models against Russian narratives.
The Investigated ScorerHIGHFTC civil investigative demand of 29 categories; suit filed 25 November 2025; demand withdrawn 21 April 2026.
The Sanctioned FounderHIGHDecember 2025 State Department visa restriction on its co-founder.

Actions & Leadership Choices

The register is “disrupting the monetisation of disinformation.” The deed, read end to end, is a private list that withheld advertising revenue from named American outlets.

  • What the list actually did. GDI ranked ten outlets its “riskiest” for disinformation — among them Reason, the New York Post, RealClearPolitics, the Daily Wire, The Federalist, Newsmax, One America News, The Blaze, the American Spectator, and the American Conservative. The Washington Examiner reported that the ad exchange Xandr (Microsoft) and other companies then declined to place ads on sites GDI flagged. Government and foundation money in, advertiser money out — the outlet stays up and stops being paid.
  • The oversight response. Senator Chuck Grassley wrote to the State Department demanding an accounting of federal funding for GDI, citing the ratings’ effect on domestic outlets; the episode ran parallel to scrutiny of NewsGuard and of the Stanford Internet Observatory as the American flagging apparatus contracted between 2023 and 2026.
  • The visa restriction (stated as reported). Per the series research and a public statement by the US Under Secretary for Public Diplomacy on the department’s official account, the State Department imposed a visa restriction on GDI co-founder Clare Melford in December 2025. The stated rationale, in that official’s words, tied the action to Melford’s and GDI’s characterizations of contested speech as “hate speech.” This is reported here as an official government statement, not as an independent finding of wrongdoing by Melford.

The FTC demand and the suit, current. On 25 November 2025 Disinformation Index, Inc., “also referred to as the Global Disinformation Index,” sued the Federal Trade Commission, Chairman Andrew Ferguson and Commissioner Mark Meador in the District of Columbia (No. 1:25-cv-04137-CJN, Judge Carl Nichols). The first amended complaint of 2 February 2026 says that after Ferguson was confirmed as Chairman he “signed a Civil Investigative Demand (‘CID’), directing GDI to produce 29 separate categories of documents and data (many with multiple sub-parts) going back to GDI’s founding in 2018,” that “GDI has lost $1 million in funding,” and that the loss “has forced GDI to almost entirely cease its reporting activities.” The FTC withdrew the demand by letter on 21 April 2026, GDI filed a notice of voluntary dismissal on 24 April, and on 4 May 2026 the court closed the case and dismissed the preliminary-injunction motions as moot (First Amended Complaint; CourtListener docket). The FTC’s stated reason for the demand is in the withdrawn CID, which is not in the public docket.

CONDUCT: STATE-SEEDED DEFUNDING VALVE. GDI is a lawful not-for-profit that rates news outlets, and it occupies a genuinely potent position: a private scorer, seeded in part by US federal grants, whose exclusion list moved advertising revenue away from named American publications through the ad-tech exchanges. Its federal funding has since lapsed and its co-founder is, per official statement, visa-restricted; the mechanism is diminished but the shape it demonstrated — ratings upstream of the money — is the finding.

Alliance Map

AxisTieSinceSource
CorporateDisinformation Index Ltd (UK company limited by guarantee, No. 11297397, directors including Clare Melford and William Emmott) and Disinformation Index, Inc. (Delaware 501(c)(3), EIN 85-2450338, 11 employees; president Danny Rogers); program-service revenue of $1,491,846 coded “RESEARCH LICENSING REV” in 2024; says it accepts “no funding from media companies or technology platforms”2018; U.S. entity 2020Companies House; ProPublica, Form 990 2024; GDI, About
RatchetFinalist in the 2021 U.S.-Paris Tech Challenge co-hosted by the Global Engagement Center and the Atlantic Council’s DFRLab; named with NewsGuard in the Texas plaintiffs’ complaint, as the Global Engagement Center file describes it, which is the plaintiffs’ allegation. No membership, funding or partnership with SPLC, ADL, CCDH, NewsGuard, ISD, Graphika or SIO appears on the About, Our Work or Companies House pages, the Form 990 or the court filings read2021Atlantic Council, U.S.-Paris Tech Challenge
MovementOpen Society Foundations grants to Disinformation Index, Inc.: $150,000 (2022, general support) and $250,000 (2023, public education); the Knight Foundation and Craig Newmark Philanthropies are named as backers in press reporting cited above and were not confirmed on a funder’s own page. Knight’s own release of 26 June 2020 lists a $30,000 grant to the Global Disinformation Index with the Institute for Strategic Dialogue “to support research on how extremist groups use digital platforms to spread disinformation and violent rhetoric to finance their activities”2020 to 2023OSF, grants; Knight Foundation, 26 Jun 2020
AgencyNED funding for research on foreign media, terminated in early 2023 with unspent funds recovered, per NED; a State Department GEC sub-grant of $100,000 per the Department’s reply to Senator Grassley; advice to Ofcom and the EU disinformation code as GDI states them; an FTC civil investigative demand, withdrawn 21 April 2026; a State Department visa restriction on co-founder Clare Melford, December 2025; no federal award on USAspending and no lobbying registration or client filing found on lda.gov2018 to 2026NED statement; GDI, Our Work; CourtListener docket; State Department to Grassley, 26 May 2023
LegalPlaintiff in Disinformation Index, Inc. v. FTC (D.D.C. No. 1:25-cv-04137-CJN), filed 25 November 2025, voluntarily dismissed after the demand’s withdrawal and closed 4 May 20262025 to 2026CourtListener docket
DiasporaNone documented as a diaspora-organization role or diaspora-PAC donation. Foreign entity and programs: the UK company, which the U.S. return lists as related; UK Foreign, Commonwealth and Development Office funding that ended in 2023 per the reporting above. Not among the active or terminated FARA registrants as downloaded 23 October 20262018 to 2026ProPublica, Schedule R; FARA registrants

These run at the same time. One body is a UK company and a Delaware nonprofit, took foundation money and, by NED’s account, endowment money for foreign-media research, was named in a Senate letter and a Texas suit as a recipient of State Department programs, sold research licenses to the ad chain, advised a UK regulator, was the subject of an FTC demand it sued over, and had its co-founder visa-restricted, all within the period its list was in circulation or shortly after. GDI documents its funders, its structure and its litigation itself. The overlap is the finding.

Reach Assessment

CategoryLevelNotes
Physical threatNONENo documented history of personal violence.
Institutional threatHIGHA ratings body whose list reached the ad chain, now advising regulators.
Memetic threatMODERATEThe ten-riskiest list and the $330,000 funding figure are the most-repeated facts about it.
Civilizational threatMODERATEAudits named models for repeating state narratives and calls for enforceable ad-tech rules.

Institutional: High, and falling by GDI’s own account. At its peak the list was supplied to advertisers, ad-tech firms and platforms; GDI estimates $200 million a year redirected. Its February 2026 complaint says the list is no longer published and that $1 million of funding has been lost to the FTC’s demand. The structural position, a private scorer upstream of the money, is what this file scores.

Memetic: Moderate. The ten-riskiest list and the $330,000 funding figure are the most-repeated facts about GDI in the press and in congressional letters, and the organization is named in State Department and congressional statements.

Civilizational: Moderate. GDI does not build or deploy a model and writes no refusal policy. Its October 2026 report grades two named models on a category of state propaganda, and its Our Work page seeks enforceable rules on ad-tech monetisation. The hazard is the position, not the people. The score stays at 77 (8/6/6), above CCDH (8/6/6, 72) and NewsGuard (8/6/7, 76); GDI’s own complaint says its reach has fallen since the list was withdrawn, which bears on the score and is for the scorer to weigh.



Sources: Global Disinformation Index — official site; Global Disinformation Index — InfluenceWatch; Gabe Kaminsky, “Disinformation group… bankrolled by State Department,” Washington Examiner; Robby Soave, “The U.S. State Department Funds a Disinformation Index,” Reason, 14 Feb 2023; Sen. Chuck Grassley — letter to the State Department on GDI funding (PDF); US Under Secretary for Public Diplomacy (@UnderSecPD) statement on Clare Melford / GDI (Wayback).

Further sources: Disinformation Index, Inc., Form 990 for calendar 2024 with Schedules F and R — ProPublica; Disinformation Index Ltd — Companies House; About — GDI; Our Work — GDI; Russia benefitting from Data Voids to influence LLMs — GDI, 12 October 2026; Open Society Foundations — grants to Disinformation Index, Inc.; National Endowment for Democracy statement on the Global Disinformation Index, 24 February 2026; Disinformation Index, Inc. v. FTC, First Amended Complaint — CourtListener; Disinformation Index, Inc. v. FTC, docket — CourtListener; Daily Wire v. State Department, consent decree, Doc. 131 — CourtListener; U.S.-Paris Tech Challenge — Atlantic Council; FARA registrants — efile.fara.gov.

Standing

Each line is the highest step a cited record proves on a fixed ladder. Press and scholarly records count one step lower than first-hand or official ones. More records do not raise a value; only a stronger record does.

REACH
4 convenes, advises or funds others in the field GDI's Our Work page states that GDI has advised Ofcom on the Online Safety Act and is a signatory to the EU Code of Conduct on Disinformation. — first-hand Next step: labs, platforms or agencies act on its output voluntarily
FUNDING INSULATION
6 money independent of those it grades, or no customer over 20 percent of revenue GDI's About page states under Independence: We accept no funding from media companies or technology platforms. — first-hand Next step: endowment, appropriation, or founder voting control under 50 percent
ENTRENCHMENT
6 an operating institution or product Disinformation Index Inc filed a Form 990 for calendar 2024 reporting total revenue of $3,006,917, including $1,491,846 of program service revenue. — official, 2025-10-29 Next step: program of record, multi-year contracts or installed base

Graph position

Computed from the ratchet graph and the subject's own words by the tradecraft detector. These are the documented ties behind each pattern, not a score; the graph is incomplete, so absence here proves nothing.

  • network brokerage
  • revolving door
OLYMPUS RISK INTELLIGENCE PROTOCOL does not exist. It was assembled in a GitHub issue thread in October 2023 by engineers who had read the extinction risk letter and wanted to understand who specifically had signed a document saying AI might kill everyone and then continued working on AI. These dossiers are satire. The biographical facts cited are sourced from published reporting, public statements, academic papers, and court records. The psychometric scores are not clinical assessments. No part of this constitutes professional psychological evaluation or diagnosis. Do not use these dossiers to make decisions about anything.