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How a compliance-led finance marketing engagement works

By the Samoha team · Sep 28, 2026 · 10 min read

Most finance brands say they want "compliant marketing", and most agencies say they provide it. In practice that often means someone reads the ad before it goes out and deletes the word "guaranteed". A compliance-led engagement is a different way of working. The regulator's rules shape the brief, the drafting, the review file and the archive, and the plan assumes the client's compliance team has the final say.

This guide walks through how that works stage by stage, using the rules that actually govern financial promotions in the UK and Singapore, plus the EU rules on retail CFD marketing. It expands on the process in our methodology. It is written for heads of marketing, compliance officers and founders at brokers, exchanges, payment firms and fintechs who want to know what they should expect from a marketing partner, and what stays with them.

This is a practical overview, not legal advice. Rules change and your licence conditions come first.

1. Start with who is legally responsible for each promotion

Before anyone writes copy, the engagement has to answer one question: for each asset, which legal entity is communicating or approving it, and under which licence?

In the UK, the starting point is the financial promotion restriction in section 21 of the Financial Services and Markets Act 2000. A promotion has to be communicated, or approved, by an FCA-authorised person, unless an exemption applies. Since 7 February 2024 there has been an extra gate. The FCA Handbook explains that under section 55NA of the Act, a firm cannot approve a financial promotion for an unauthorised person unless it is a "permitted approver" or an exemption applies (COBS 4.10.1BG). The FCA's social-media guidance spells out what this means for creators: "Unauthorised persons, such as social media influencers, who promote a regulated financial product or service without approval of an appropriate FCA-authorised person may be committing a criminal offence" (FCA FG24/1).

In Singapore, MAS issued its Guidelines on Standards of Conduct for Digital Advertising Activities on 25 September 2025, and they took effect on 25 March 2026. MAS says they apply to "all financial institutions and their appointed third parties, including online content creators" (MAS media release).

So the first deliverable is a responsibility map, not a media plan. For each market, it records:

The entity and licence that will onboard clients from that country
Who communicates each type of asset (the firm itself, an affiliate, a creator, the agency on the firm's behalf)
Who approves it, and whether they are allowed to (for UK promotions by unauthorised persons, that includes checking approver permission)
The named person on the client side who gives final sign-off

If the map shows a gap, such as a creator in a market where no one can approve their content, the answer is to change the plan. Hoping nobody notices is not an option.

2. Inventory every asset that counts as a promotion

Campaigns produce more promotional material than people expect. Besides the ads, there are landing pages, onboarding emails, push notifications, webinar decks, affiliate banners, creator scripts, social replies and sales call scripts. The second stage lists all of them, because anything left off the list never gets reviewed.

Two FCA rules show why the list has to include material that isn't an ad. First, a firm "must not approve a financial promotion to be made in the course of a personal visit, telephone conversation or other interactive dialogue" (COBS 4.10.4R). Live conversations cannot be pre-approved like a banner, so they are controlled through briefing, training and scripts. Second, for a telemarketing campaign the firm "must make an adequate record of copies of any scripts used" (COBS 4.11.1R(2)). Scripts are part of the compliance record, so they belong in the inventory.

3. Draft to the rule, not to the rejection

Drafting is where a compliance-led engagement differs most from ordinary performance marketing. The first draft is written against the rules that apply to the product and market. Nobody writes the boldest possible claim and waits to see what compliance cuts.

For UK work, the baseline is that a firm "must ensure that a communication or a financial promotion is fair, clear and not misleading" (COBS 4.2.1R). The FCA's guidance adds that a promotion for a product that puts capital at risk should make that clear (COBS 4.2.4G). The Consumer Duty then asks whether customers are likely to understand the promotion, not only whether it is technically accurate. Firms must make sure communications "are likely to be understood by retail customers" and "equip retail customers to make decisions that are effective, timely and properly informed" (PRIN 2A.5.3R).

Some products carry their own hard-coded rules. Retail CFD marketing in the UK is the clearest example: the risk warning wording, the loss-percentage calculation and the formatting are all set out in COBS 22.5. We cover it line by line in CFD risk warnings in ads. The same section also bans offering retail clients monetary or non-monetary incentives when marketing these products (COBS 22.5.20R). A deposit-bonus creative that might pass elsewhere cannot run for UK retail CFD clients. In the EU, ESMA's 2018 CFD measures, since replaced by national measures, also restricted incentives and required a standardised risk warning (ESMA).

In practice, every draft goes out with a claim sheet. It lists each factual statement in the asset (spreads, fees, licence numbers, product features, awards), the evidence for it and the date that evidence was checked. If a claim can't be evidenced, it comes out.

4. Build a review file compliance can approve quickly

Review goes faster when the reviewer doesn't have to rebuild the context. Each asset is submitted with:

The final creative in the exact format it will run (not a mock-up with placeholder text)
The market, audience, channel and placement
The rules it has been drafted against, with references
The claim sheet
For character-limited formats, the landing page the shortened warning links to
A version number, so the approved file and the published file can be matched later

The FCA also expects the people who review promotions to be qualified for it. A firm "must not communicate or approve a financial promotion unless the individual or individuals responsible for the compliance of the financial promotion ... has or have appropriate competence and expertise" in the product it relates to (COBS 4.10.9AR). An agency can do a thorough pre-check, but it does not replace that person. We describe our role in the same terms as our guide to marketing regulated finance: we build to the rules and flag risk early, and the licensed team signs off.

5. Keep the records the regulator expects

An approved promotion that nobody can reconstruct six months later is a liability. Under COBS 4.11.1R, a firm must make an adequate record of any financial promotion it communicates or approves, and a record showing how it satisfied itself that it had the necessary competence and expertise. The retention period depends on the business:

MiFID or equivalent third-country business: five years
Life policies and most pension schemes: six years
Pension transfers, conversions and opt-outs: indefinitely
Any other case: three years

For CFD providers there is a separate requirement: records of the retail client accounts used to calculate the loss percentage must be kept for five years (COBS 22.5.6R(8)).

The client holds the regulatory record, but the agency produces most of the material that goes into it. At the end of each flight we hand over an archive with the final creative, the approved version number, placements, live dates, the claim sheet and the approval evidence, organised so it can be dropped straight into the client's own system.

6. Monitor promotions for as long as they run

Approval happens once, but a promotion can stop being compliant at any point while it runs. The FCA says the purpose of its approval rules is that an approving firm "takes appropriate steps to ensure that the financial promotion remains compliant for the lifetime of its communication" (COBS 4.10.2). The MAS guidelines take a similar line. Firms "should establish monitoring mechanisms to track all digital advertising activities, including those conducted by external digital marketers" (MAS Guidelines, para 5.9). MAS gives keeping a register of all digital advertising activities as an example of how to do this.

In a live campaign, the usual triggers are ordinary business changes, not dramatic ones:

A CFD provider's loss percentage is recalculated. It must be updated every three months, so every ad and page that shows it needs a scheduled refresh.
Pricing, rates or product features change, which breaks a claim on the claim sheet.
A licence, entity or target market changes, which changes the responsibility map.
A platform updates its financial-services ad policy.
A creator reposts or edits old content outside the approved brief.

Each trigger has an owner and a way to withdraw material. For paid media that means pausing or replacing the ad. For creator content it means a contractual right to have posts edited or taken down.

7. Treat creators and affiliates as part of the regime

Third parties are where compliance-led plans most often break down, because the firm doesn't control the keyboard. Under the MAS guidelines, firms "should have a framework to assess and select appropriate digital marketers". MAS says the selection criteria should include "relevant qualifications, communication styles, experience and track record in conducting advertising campaigns for the financial sector", and an understanding of the firm's target audience (para 5.7). In the UK, FG24/1 makes clear that an unapproved promotion by an influencer can be a criminal matter for the influencer, not just a brand-safety problem.

That is why creator work in a compliance-led engagement starts with vetting and a written brief, and why reach is the last thing we assess. Our checklist is in how to vet finance influencers.

Who does what

Client compliance: owns final sign-off, holds the regulatory record, confirms approver status and licence scope, and decides what can be said.
Client marketing: owns commercial goals, budgets and product facts, and supplies the evidence behind the claims.
Agency: drafts to the rules, pre-checks, builds the review file, runs media and creators within the approved brief, monitors live promotions and produces the archive.
Creators and affiliates: publish only the approved material, disclose paid partnerships and agree to edit or remove content when asked.

FAQ

Does the agency approve our financial promotions?

No. In the UK, approval is a regulated activity carried out by authorised firms, and for promotions by unauthorised persons it requires approver permission. A marketing agency prepares material for approval. It does not replace your compliance function.

Can one creative run in the UK, the EU and Singapore?

Rarely without changes. Risk-warning wording, incentive rules and who may promote a product all differ by market. The responsibility map and claim sheet are kept per market for this reason.

Does all this slow campaigns down?

It moves work earlier. Drafting to the rule and submitting complete review files reduces rework. Rework is usually the slowest part of getting finance marketing live.

Which services does this apply to?

All of them, from paid search and social to creators, PR and SEO content. The same stages apply regardless of channel.

Sources

Last reviewed: 28 September 2026.