Financial Promotions – evolving challenges and novel solutions

Welcome to the CI/SI podcast. If you're a CI/SI member and listening outside the CI/SI learning platform, please remember to record your CPD manually. Not a CI/SI member? If you're interested in joining our global community of financial services professionals, visit CI/SI.org to learn more. Hello and welcome to another episode of Operations Unpacked, the podcast series that shines a spotlight on the people, systems and processes that keep business in business. I'm your co-host Victoria Senna and today I'm joined by the CI/SI's very own Collin Anderson. Hi Victoria, I'm back, yes. This is my good diving into a hot topic of financial promotions. And we're going to be covering the evolving landscapes of financial promotion rules, cross-duress, digital complexities to the operational challenges and what you do to manage in that scale. But we're not going to do most of the talking. Today we're going to look at two experts to come and talk to us about it. And that's Phil Clements and Stacey, what do you do? Stacey Phil, thanks for joining us today. It would be great if you could give our listeners a quick canter through your career paths and how they cross. Let's start with you Stacey. Cool, I'm going to make Phil talk about how we cross, but my career path has revolved around making sure financial promotions as the content is properly done and viewed, read in a way that people actually understand. I started in traditional financial services where I focused on financial promotions and other retail communications and that's where a lot of my kind of my rape knowledge comes from. That's where my knowledge and love and hate of the handbook comes from. It's where I did my CC exams. My diploma in investment compliance was back in 2017 and kind of fast forward today, like I've gone through FinTech and crypto spaces but very different, but making sure that firms that I've worked in communicate in a way that's accurate, fair clear, not misleading, supporting customer outcomes. Just a bit about now, like I've I lead global financial promotions, I work across multiple regions, multiple assets, stocks, ISSs, ETFs and multiple channels and I absolutely love what I do. I get to take policy, governance, I get to partner with marketing teams, product teams, in obviously influencers, affiliates and just like all of these crazy emerging channels. Amazing, incredible career and we're definitely talking to the right person to say I can't wait to dive in. Over to you Phil. Yeah sure, thank you Tori. So my career actually started in FinTech, so just a decade ago now when I decided to leave my life as a secondary school physics teacher, which is probably a podcast for another time, enjoying the big bad industry of financial services. I started out a firm called Breckle Currency Management which a lot of people haven't heard of but they're actually the world's largest independent currency overlay manager and I was selling a lot of their products and services, particularly to institutional clients in the UK, the US, Switzerland, other parts of continental Europe. I think that's my first exposed to this concept of creating a financial promotion and I remember those are compliance officer at the firm at the time, a lovely chap called Grady Laurie who I'll always have to go to, bring my checklist of things I'd have to make sure, including my pitch deck, this disclaimer here, just perform with the commentary, go back to certain number of years, tick tick tick and get him through a viewer monitor it. I actually remember as well, Grady at the time made me do one of the exams, the CISI certificate in Captain Markets exam because at the time I was what was called a CF-30 function, I think it's now called the CITIP Senior Management Certification Regime, one of the controlled functions under the FCA that would allow me to be a marketer and promoter of the firm's products and services within the UK. And it's funny, I actually managed to dig out my old CISI book, Swiss 16. Oh, nice true down there Elaine. There was only about nine pages on financial promotion to the books, so maybe things have moved on a little bit since then. How times have changed? I think Collins had a big hand in writing, see, I guess I find that tribulations work, so I think he can testify that it's a little more than nine pages now. I love it when you can really point to just one person that was just a bit of a pivotal change, so that's lovely. But in record, I was also really fortunate that I was relocated to their New York office, I had a little bit of experience in work with the SEC, Finra, I remember doing the equivalent exams under Finra, you know, the Series 7, the 63, 32, all these different exams you have to do to make sure that you can put promotions out within that market that are safe and compliant. And then after leaving New York, I actually joined Bloomberg's index business with other regulated business, the alt-barquets, Lehman franchise, specifically marketing a lot of their benchmark regulated products to UK and Swiss clients. So then I was transported into the Swiss financial market, Supervisor Authority, Finra rules, and it was really at that point after this exposure worked out, a lot for different jurisdictions, lots of different sort of regulatory bodies I realised there's actually quite a big problem that exists between content creators and content reviewers, and that led me to think about how can we better the way that people monitor review and flag financial promotions risks at scale in this world where content formats are changing, and that led me to Fin Inspector, but I'll go on to that later on and make the pause there for now. Brilliant, you've both had fascinating careers so far, and they definitely demonstrate exactly why we've got you on the podcast, so our listeners are in for a treat. Let's kick off with the basics first. Stacy, I'll come to you. What is a financial promotion? So a financial promotion is basically any communication that encourages someone to buy, sell, subscribe, or otherwise engage with a financial product or service. It doesn't need to be like a glossy advert. It can be a social media post, it can be a message in a WhatsApp group, an email, or even like a comment in like long form content you see on the website. It's just something that nudges someone to make an investment decision. I always tell teams, you know, it doesn't have to be like buy now, sign up now like a large, shiny button. If it's got, you know, it could be a hyperlink within the text. If it's got the effect of persuading or influencing someone to do those actions, then it's called by the rules and it is a financial promotion. So much broader definition than people perhaps would appreciate. Yeah, and Stacy, just on that point, you know, you've got so many different avenues on this. You know, what does it really mean for your compliance operations to actually deal with this? Must be quite complex for them to actually consider. No, it is, you know, within my role, I work with overlifting different marketing channels and there's different types of content there. It's not just texts. We've got visual, we've got audio, we've got animation, voice-overs, and sometimes all in one thing of a like a like a, a TikTok ad where we might have the captions, it might have charts, music, transitions, and everything's happening at the same time. And from kind of a compliance my view, it's a challenge because every, every aspect carries risks and we need to make sure all of those components are compliant. Brilliant, we're going to come on to social media later, but first, I'd love a history lesson from you Phil. How have financial promotions changed over time? Oh, this is a great question. I think it's changed dramatically, right? I was reading a couple, but maybe there's a few stats that I can give you that I was reading ahead of this. I thought we're really, really interesting. So the FCA financial live survey said that now over 80% of adults consume financial promotions through digital channels. That's very, very different if you go back a decade where written form content, you know, in-person was maybe the main way in which things were solicited. The FCA regulatory roadmap also does a study where they found over 60% of promotions reviewed by the FCA in 2023 and 2024 were digital first and then equally the advertising standard authority did some joint research with the FCA where they found that one in seven UK consumers said they'd made a financial decision based on influence of content. So I think I've shrenned has been it historically was static written form materials and now we're seeing much more dynamic digital influence are read real time content across a variety of different platforms. I think back to Stacy's point of sitting in the compliance seat. That means that when you're dealing with multi-modal content, it's really, really complicated. So if you think about it, if you have a, for example, the TikTok video that Stacy mentioned, there's lots of different risks embedded within that. The spoke of message has to be balanced, right? But then the video thumbnail may have an implied guaranteed profit that maybe the script doesn't actually say in terms of the tone. The chart that maybe is displayed, maybe misleading or distorted or the scales may be wrong and also it might not have mandatory risk warnings. So now it's really, really difficult sitting in that compliance seat because you no longer are just looking at say rhythm form line by line. You've got to look at the transcript, you know, go look at the locket, go look at the imagery, you've got to look at all these different contextual bits of data that means that promotions have changed dramatically from over a decade ago. Interesting. And you just mentioned there a term real time. What's the distinction between real time and non real time promotions? That's a really good follow and great. And maybe I let Stacy add to this as well. The real time really is when communications that occur in that moment and typically they're interactive, typically it's with a specific individual or a one to few type approach. So it's really hard for someone, for example, in Stacy's seat to pre-approved that type of content because it might be say a salesperson doing a sales call over the phone, maybe with a small group round table where there's an amazing number of individuals. Anag yw ' minister ar dei osblwyr o f fuego'r ein am mwy ann dibジ ddai o'r coping Does ondy am Shure Gwyrddau Modwyr ar ddyddiad i fynych yn wahanir bethau datennu ein systems dyd sut centres y mae chi fy rondri réd reithim無iad o'r proiad yn edryd y bywyd chi'n pervers ar ydi oss? Guardi lle loti��atarfysdwkroysdynow ar mae neTFartol maffノ llwy Prindal a executors. Dyn o'rchdy, yn rhyod ö gypleg. 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I've worked a lot with like data specialists just to you know, is someone that came in via an influencer? Are they in harm somewhere along their journey? So you know, there's just so much reports now that I'm producing. So it's more than just reviewing the content. It's that extra piece that we are now doing. Yeah. I would just add to that as well. So what's they saying? There's actually a lot of non-regulated or say not directly regulated associated entities. They're putting out rules and standards and guidelines. For example, I asko. For example, whichever of 30 members of one of which is the FCO in the UK, they pull out report this year on influences. And within that report, they talked about some standards and frameworks you can think about when it comes to influencer promotions. And there's people like the advertising standards authority which have a rules overlay marketing standards that covers digital and influencer advertising. There's lots of different places that people can look for rules and regulations. I'm sure there's no end to the list. It's an end. But interestingly, there's also another dynamic which I tend to see a lot when working with some of the entities that we work with at Fin Spectre. And that is a lot of people have their own internal policies as well. And these won't necessarily be written in or reflected in some sort of regulatory standard within whatever jurisdiction that they operate in. So for example, we were speaking with a Middle East in Prospect recently and they were talking about how if any of their sales team promote on social media online, they don't want any alcohol pictured in the background of their photos. And you won't necessarily see that written in their local regulatory handbook, but it's definitely key for them in terms of their regulatory or internal policies. >> Other one might be for example. >> Yeah, you know, you know what influence, for example, on a video, right? I don't want young people positioned in a video that maybe an AI is created. And so there are these things that are standards that live within the world of regulatory standard sectors. But there are things also outside that I think go amidst that are still equally important to those firms that are working in those regulatory jurisdictions. >> Good, great. >> So you're talking about the types of firms. Can I write a saying that any authorized firm in Yandere was to use the textbook part 4A? I think it's registered. Are they the ones that actually tied up with financial promotions rules or other firms as well, like the cryptos or the cryptobusages? Are they tied up as well? >> Yeah, maybe I can tackle that. So I think it puts you importantly, I think it's any business that's communicating a corporation that's going to have an effect or capable of having an effect in the UK consumer market is the impact you could be deemed as requiring to or needing to apply the rules, right? There's obviously there's things within the standard you mentioned part 4A permissions, you know, these are firms that carry out regulatory activities, deposit taking, investment services, consumer credit, mortgage. You know, those, it's very clear for those firms, right, they're listed within the regulation. But it also lists within the rules, unregulated firms, right? So just because you're unregulated doesn't mean the rules don't apply to you. They of course do. It just means that you're not falling in the catch of your having to do FCA reporting, et cetera, et cetera. Back to your crypto question, there is an, they called the Money Laundering Regulations, I think it's MLR 2017, and that's for cryptorastic activities, and certainly if you're a crypto asset firm, then that falls within that remit. But also there's a lot of people beyond that. For example, under the FCA you could be directly authorized or you could be an authorised representative. And if you're an authorised representative, then you're typically working with a principal firm and piggybacking on their regulatory license and getting there approval for your internal or external financial promotions. And then there's obviously trading platforms, there's fintechs, there's brokerages, there's investment firms, there's a lot of people in between as well. So basically what you're saying there, really, anybody can fall onto these rules. You know, really, even, you know, if I wasn't, I'm not regulated, you know, individual, I'm not authorized, and if I'm a financial promotion, and I could be held liable, it wasn't correct. Yeah. Yeah. Yeah, I mean, look, I think, and this is what we're seeing now, right? We talked about this a little bit earlier. The world of the attention mechanism in the world is changing. You know, when I went on the train, I commutant to London now, you know, I sit down and no longer do I see people with their, you know, CISI regulations, but really, I'm there commuting you. It's because they turn more into digital PDFs. Yeah, I mean, their attention is, is harnessed by seven second clips. Right. Really, and, you know, people that met her and much more intelligent than we have decided or figured out 20 years ago that we can hack people's dopamine their brain by giving these second, seven second inducements, right? And so the way people consume content is changing, but it also means that a number of people that can create content is changing too. So before, you know, if you were going to put out a promotion for, I don't know, a trading scheme, you know, you go back 20 years, it probably would have just peen people who were working in regulated sectors, who'd be the one sort of promoting that type of activity. A number of years ago, now or two years ago, you now got some love island stars getting charged for promoting trading schemes. So the world and the way to attention is harnessed is changing and the number of people that can access that attention mechanism as changing as well. So it does mean unfortunately, now you get a lot of more unregulated people promoting things that they actually shouldn't be. Yeah, completely. The regulatory remit has certainly extended. But are there any clients that the rules don't apply to? I think there's a couple of, I mean, when I was working with very large institutional clients, and times of their identifications, sophisticated investors, there's certain exemptions that apply for certain type of products, right? One off promotions, another one, not making the course of the business, but you know, that could be a promotion just outside of your normal business activity. And then obviously overseas promotions, genuinely not targeting UK promotions, you could argue for outside of that. But I think that's becoming increasingly difficult to make that argument, particularly where most promotions in the digital world where you can have someone creating a promotion in Singapore, but actually it's impacting or going to people all around the world. So it's really hard to sort of see how that one, maybe in the past, that would apply, but maybe not so much in the future. You are really kind of talking about, if it's going to hit Granny, as I always say, then it's got to be under the rules. And if Granny doesn't understand it, then you should be doing it. Colin, I use that term a lot as well. Yeah. I mean, I always talk about, if it's right for you, Granny, I mean, that's going to be okay. Or if it's going to be somebody like Warren Buffett, you're going to be talking to him in the slightly different language. That's really what I sort of is about knowing your clients, knowing your customers, as equally as important as actually the financial promotion that's actually going to be forward, isn't it? I'd love to move on now to the operational challenges that firms face. So I've got a little fat that I'll throw in, which is that in 2024, nearly 20,000 financial promotions were withdrawn or amended following intervention from the FCA. Almost half of those were from claims management companies with the FCA removing 9,197 of their efforts exactly. So what do you think the biggest operational challenges are for firms when it comes to creating financial promotions? There's so many. The main challenges for me are balancing that speed with creativity. We've spoken a lot about compliance, regulations, marketing teams have got so much speed these days and so many different tools, so many different platforms that are able to create things in seconds. And especially where I'm setting this multi-channel world, we have to ensure that all prescribed rescorings from the regulator, the sclaimers and all that information is applied across all formats, where it's video, social email, affiliates and affiliates, influencers. That's another challenge. Working with them, staying ahead of the regulatory expectation, educating them, I spoke about reoccupying, maintaining audit trails. One thing I'm a big advocate for is making sure we embed to compliance very early on in whatever lifecycle, rather than a final check. And yeah, those are just some of my challenges. Phil, do you have anything to add particularly on how you approach the challenge? Yeah, look, I think just adding to the challenge a little bit first, I think it's about to start 20,000 financial promotions amended or drawn in 2024. I think it was 17 times higher than compared to 2021. The Lyra Furnber rightly, that FCA report said that despite, because mainly digital channels, the social media paid online ads, so you can see sort of the trend, right? I think when I think about operational challenges, I tend to split up into content reviewers and content creators, so marketing and compliance, and you can kind of think about some of the challenges between those two entities or distinct functions with a business and the intercept. And then you can also think about, which is what Stacy talked about, this kind of internally generated content by those internal teams versus content now that is largely getting created by affiliates or by AI, so by third parties, whether that be a platform, whether that be an individual themselves kind of on tip-talk or whatever that might be. And I think for the content creator, there's just more, there's more formats that you're disposal, right, and you have to do more. I think now when you talk about sailor cycles need to talk about marketing and sales teams, they want to create many touch pointers they can with their target audience, which means they want to use every single digital and in-person channel available to them to target those particular consumers. So if they're consumers or on Facebook, they're on TikTok, they're on Instagram, they're attending certain conferences, they know they're going to be attending certain events in their local area, you know, for example, they're going to target advertisement promotions in all of those different formats. And so that one means that there's more for them to do, but then that creates a challenge on the other side, where Stacey sits, which means the content reviewers and monitors have got to review all this at scale. And for example, this podcast we're recording now is fantastic, you'll be 45 minutes to an hour, but imagine if you're the compliance officer that has to watch that whole thing and then say to the person, "Actually at minute 25 and 14 seconds, do you mind making this amendment?" And then you make the amendment and you have to watch it all again. That's a huge amount of time that is spent reviewing and monitoring that content. And that's just content that's kind of getting pre-approved before going out in the world. We're not talking about ongoing monitoring, which is a whole other activity. And so I think now the challenge is really how do you work in a world where the number of content formats is increasing and content creators can do more. And how do you work in a world where content reviewers and monitors need to monitor all these different formats at scale. And we can talk a little bit about later about how AI and some different tools are doing that. But I think fortunately now we did it in a world where there are lots of solutions out that can definitely support the intersect between those teams and those activities. So I think there's probably a perfect moment. Actually let's delve into the AI. Because you can't have a podcast on operations or compliance or financial planning or investments or anything at all unless you're talking about AI. So is AI? You mentioned it there. How can you creation side of compliance side use the AI to help because you know AI can make mistakes. Yeah. So how can you really get to grips with this? That's a way that AI can help in this. I think there's different facets. There's both on the creation side. There's on the compliance side. There's on the governance side. I'll talk a little bit about more the compliance side because I think shameless plug here if it's inspected but this is kind of what we do a little bit. And I'll maybe let Stacy talk a little bit about the creation side, the governance side where I think she's got a lot of expertise. So I think one of the things has happened now is that since those eight Google scientists wrote that paper in 2017, the tension is all you need and talked about transformer architecture and that was the advent of some of the language models. There's now a way in which you can speed up or you can make certain processes much more productive and efficient within this intercept to marking compliance. For example, I remember back in the day when I created a pitch deck when I was at record, I used to have to print off that Excel sheet. There was a little check this that I'd have to go through. I would check it. I'd hand it to the mouse. They would check it. You would then get go to the compliance officer. He or she would check it. That was a simpler day. He's here. Yeah, there's a lot of checking going on. But now what you can do is you can take those checks and rules. You can embed them as prompts within an AI framework, for example, an agentic AI on AI agent. That agent you can then feed content regardless of format. It doesn't just have to be written form because you can tokenize a video to a large amount of language model. You can tokenize an audio podcast for a large language model and then very, very quickly have the potential risk flag back to its scale. That's not to say that the AI should replace someone like Stacy. You know, Stacy's going to be gone. No, not at all. I think you need still the human in the loop to review the risks that have been flagged by that particular system. But particularly for that type of activity where you're reviewing and monitoring financial promotions at scale, there are now solutions out there that allow you to be much more productive both in the compliance see on the sign-off and monitoring side. But on the marketing side as well because now markers can check content for certain risks before sending it to compliance. I'll let Stacy talk a bit about this because this is something that I think a lot of people overlook is that, well, I think sometimes don't know the rules that apply to them in advance. No, they don't. They don't matter how much training you give them. But, you know, on their side just really quickly and we're talking about scale, I've seen ads, you know, I've seen, you know, we always talk about like to market, time to market. And I've seen ads created in literally three minutes, like whole complete ads, you know, something that would previously take months because it needs to go to design, you know, it goes from ideation to design to translation to, you know, different teams internal and external costing thousands, thousands of pounds sometimes, three minutes, you know. So my additional challenge is now I've gone from, you know, 10 tasks a week to 100 a week that I need to review and approve, which is where those solutions come to come to help. But yeah, on the creation side it does support in drafting their copy, producing templates and localisation. I think one of the other areas I'm seeing is financial promotion is one part of the whole compliance framework. I've certainly seen now, for example, policy docs, right, let's see if new regulation comes in, it impacts and multitude of policies, be able to quickly see which policies would be hit by that particularly change. That's a really good use case of where AI and certain forms of sort of large language model architecture can also help within streamlining and make those processes much more productive. But I go back to my original point, I think you need a human in the loop. Wow, I do. You need a human in the loop. Always. Also, I'd like to have somebody, somebody having a job somewhere. What about the FCA sandbox? Have either of you had any experience in using that sort of followed with financial promotions? We were very lucky, we're calling pain at the FCA, we're part of the AI innovation spotlight, which is fantastic. Which is nice. Which is nice. Which is nice when they're sandbox. And what it does is that, if you think about the technology we're employing, it's still quite nascent, right? Agente.AI is very, very nascent and it's very early days for its adoption. And so naturally regulators might be a little bit nervous, but they want to create an environment where it's safe for people to test your model, and you're learning and get feedback. So one of the things that's been really useful for us has been when we've been trying to train our models on understanding and identifying financial promotions risks. We can go to the FCA and say, "Hey, if you've got an example of content that you've amended or withdrawn and why." And that's fantastic to have that open relationship because then that allows us to create models that have a minimum threshold that knows exactly where that bar is set from, their perspective of saying, "Look, this, this, this didn't cut it and this was, this was actually a risk that we flagged and actually ended up amending or withdrawing it." The other thing is also led to, and I was in Singapore in 2025 with the FCA as part of a cross-border jurisdiction or sandbox, they announced with the military authority of Singapore. And that's been really exciting as well because it means no longer can we just test our models in just the UK sort of market environment. We can also do it in that cross-border environment as well. And actually, in the world of financial promotions, most firms across board are now right. If you look at most big asset managers, wealth managers, investment firms, they're working in multiple geographies, so having that ability to not just understand the rules that would apply within the UK would also understand the rules that would apply for example in Singapore and maybe get some examples of promotion that they've amended or withdrawing within the context of the single-border market. That's really, really helped us as we build our solution for our clients. It's so good to hear about the sandbox. Every story I hear about it is a positive one, both for I think the regulator and also the people that are using it. It's been running now since about 2010, so I think they really know what they're doing. So far, we've talked about UK regulations, but of course the internet has made the world a much smaller place and nothing stops promotions from reaching UK customers from overseas. So how do you deal with the added complexity of multi-gear restrictions? It is another big challenge, especially where I am now. I take a very structured approach, mapping all of the local rules, the restrictions, risk disclosure requirements for each. Holding all of that together is kind of our brand, our brand's messaging. I work a lot with web teams to apply geotargeting. We spoke about earlier where the SCA expects anything overseas targeting the UK to be applied with the same rules. So I luckily understand how kind of the geotargeting and all that IP and all of that stuff works. Phil, if you've got anything to add? Yeah, I've got something to add. So interestingly, one of the big problems that we have is a lot of that have come to us who again are marketing or promoting within different jurisdictions, right? And so that means it's not just the FCA Cobbs school rules that apply or whatever it might be. It could be also US equivalent, so it's equivalent, different European equivalent, etc. And so in order to train our models on understanding what the financial promotions risks are in those different markets, we need somewhere where we can go and say, "Where is the comparable rules not just in the UK before all these different jurisdictions?" And so we work with the University of Cambridge outfit called the Regulatiu Gino Project. The Regulatiu Gino Project has tried to solve a very simple problem and that is to try and make global regulation machine-readable structured and comparable cross jurisdictions. So we pull from their database the financial promotions regulations specifically to the UK, but then equally that allows us to map that to all the different jurisdictions in their database of which there's over 150 different countries. And so what that means is we have a starting point in a machine-readable format which we can then extract the rules that apply for us in the multi-duerstictional context. So that client and the medal of the jurisdiction of the United States. context and then build a AI agent to build rich frameworks that understands readily what those rules apply within that multi-guristics in your context. I think one thing really important and I think shout out to Bob Wardoff and Mark Johnston from Reggie, you know, and the Reggie, Reggie, and the project is that creating an index on ontology that maps different regulations around the world is fantastic and it really opens up a lot of avenues for different firms to create really innovative features and products off the back of not just in financial promotions but more broadly. Imagine if you were able to understand the AML rules or anti-money laundering rules that apply to you in the UK and in say 25 different countries that you're hoping to operate in and you can do that on the fly very quickly and you had a date based where if there's a change in one jurisdiction that underlying database gets updated and then equally or underlying model gets updated with it. That's a fantastic thing to have it's really difficult to do particularly when regulations are written by human and it's a principle based, principle based regulations doesn't always make the best kind of AI products or kind of method data fields that you can easily prove at all from but at least you have a starting point to understand the equivalent regulations that apply outside of just the local market in which you operate. It's fascinating to hear more about the regulatory genome project I've been keeping an eye on what they're doing and we're going to get them in to talk on the podcast. So looking forward to that episode. You were talking about the regulators and you know across all the jurisdictions and we're looking at overseas coming at all the early. I will now see what the regulators isn't going to be one regulator that's going to have to look at this or do you think it's going to be you know different regulators are going to have to take this challenge from you know stuff that's coming from Singapore stuff that's coming from China let's say Hong Kong or America all of this is coming into the UK so how can the regulators challenge this or make sure they're keeping up a top of all these changes when it hey it could be you said earlier it could take three minutes to should do our promotion send it into the UK so how can we actually keep on top of all that information you know isn't it somebody's going to get through eventually isn't it wouldn't you see green pencil yeah you know what I think regulators have got a really difficult challenge I think cross-border enforcement cooperation you know you're starting to see things I mentioned the FCA and monetary authority of Singapore you know AI cross-border sandbox that's a great initiative you have obviously global securities bodies like Iosco who work with a lot of different regulators across a lot of different countries currently standards that then tend to get influenced into regulation for example that influencer report I mentioned that Iosco board out in 2025 but equally you're starting to see sort of more joint enforcement action so interesting hours on the panel in 2025 with Lucy Castle Dean who's the director consumer investments of the FCA as she was talking about how in June of 2025 the FCA led a coordinated global week of action they called it against illegal promotions by rogue influencers working together with lots of different regulators across Australia Canada Hong Kong Italy UAE I think there was a bunch of them and they actually led to some arrests as well I think the difficulty there is that particularly now when content can get created anywhere in the world and then market in a jurisdiction that is outside of the remit where it's created it means you have to cooperate when it comes to enforcement action as a regulator and so I think that was a really good example where regulators came together and they're very very successful in arresting a number of influencers but it's still just a drop in the water really in terms of what or didn't really touch the surfaces to kind of what the underlying problem is so I actually don't really know the the whole answer I think it needs to be some coordinated effort for sure I don't know which body that should come from it comes in terms of standards I mentioned I think I ask her in other bodies like that great for the standard setting but then there's the other side which is the reporting the monitoring and that probably needs to come from the regulatory and cross-border partnerships itself we talked earlier about social media cases and there's been several high-profile ones that you mentioned we all know that ignorance isn't an excuse but an excuse but it shows that the rules are complex what are your thoughts on on those cases I'm gonna let's take this because Stacy is actually a panel each year where she gives out awards to influencers fascinating podcast on influencers, influencers, content creators, board leaders, whatever you want to call them again it's so many different names for them but I think those cases really really highlight how easy first of all is unintentionally to break the rules in these fast-moving channels like social media and kind of going back to the point where we speak about traders even the like well-intended content can imply advice exaggerate returns or felt to give balanced risk information unfortunately we've also seen bad actors you know the media is incorrectly called them "vintage" influencers but you know these are content creators who have gone from talking about makeup to high-risk products and again we can do a whole episode of these individuals but essentially we're going to get more of these cases I think the key takeaway here is that all content creators influencers employees third parties need to understand what the registry expectations are you know I was at an event actually last week the Bank of England held an event for FCA Acer and kind of not kind of the main influencer, the influencers in this space and you know where we're talking about collaboration and one regulation it is about kind of just talking to those to those individuals traditional banks have failed and we are more likely to listen to these individuals so unfortunately we're going to see more of those cases but I can see collaboration working in the right direction. It's good to hear. On that I have a better thing maybe because I'm really old and I know what I listen to these financials or I have no idea but listen to them and I think who gives you the right to give that information out? Who gives you the what skills have you got? I've done qualifications you know we've all done qualifications but shouldn't there be an absolute ban on all this? You know that's maybe something you think you're oh no you can't do that on but some aspects they should be tighter is these people are actually influencing a lot of people that just don't understand what's going on with their their finances they don't understand about having a great financial literacy anyway. I agree. So you're doing something? And it's not just the FCA that's cracking down on these that ASA is also involved for exactly that reason because oftentimes influencers will subtly drop adverts in without telling their listeners that it's an advert so they'll just refer to their bank account and say oh it's amazing and it's like well that's a promotion. If you're telling me if you're recommending me to use your bank account or a particular product or service that is a promotion so I think it definitely does need to be tight and particularly because social media users are typically younger typically more easily influenced or though I think they're sharpening up quickly I think the learning curve is very steep for that generation but it's still not fair. 100% I also think that it's not just influencers or influencers I think even just general sales and marketing people working regulated firms need a little bit more context and education around this because for example a lot of them don't realise that you know if you go to an event and you're posting on LinkedIn and maybe you're pushing your firm's product that's an inducement you know you are and so that still falls within the rules where a lot of people who may be and a lot of sometimes these people who attend these events they might not be have done the senior manager certification they might not be in a regulated function within the firm themselves so they they might not know but that does just because you don't know something doesn't mean that you're still not captured by those rules. So I think now and maybe this isn't going to stay see it and I have been talking about and we're going to share a passion I was like when I when I left my my job of Bloomberg and came here to Finnspector actually went out to the market and I looked to see is there anywhere that sort of talking about or giving education on this intercept between marketing compliance and financial promotions not just from people who work in regulated firms from content crazy content reviews but also third party affiliates and could be applicable to them as well and there really isn't there really isn't and it kind of shocked me really and equally I kind of thought to myself maybe the FCA has a register of like all approved influence somewhere oh no that doesn't exist either so you know if you're someone who's looking to employ a third party it could be an influencer but it could be another regulated firm or it could be another entity and you want some assurance that they at least understand the rules and regulations within the the market the yacht rate in either UK or the US or wherever it might be maybe having had a tip box of having done a bit of learning or bit of a qualification to show that they have a minimum threshold by understanding would be a useful signal right so this is something when Stacey and I first met we were talking about you know actually there's no course out there and then Stacey actually said you know what this is something I've been thinking about developing myself for a long time and that led to us sort of talking with the CIS world about developing a potential marketing compliance course that will help people with financial promotions regulations yeah and what is this deal on? Section 21 firms. - There are companies that aren't fully FCA-alphurides, but they can put out certain financial promotions under rules. If you think about your boutique investment firms or your crypto-brow startup, that only target high network or sophisticated investors, they can operate but only in specific ways. Even then, still, the rules apply, they must be promotions must be fair, clean, not misleading. They can't just post whatever they like. Regulators are, as we've said, watching everyone. - Nice. So far, we've talked quite a lot about the problems that surround financial promotions, but I would like to balance that for our listeners. We're talking about some of the solutions. So I appreciate that the FCA publishes case studies on its website and helps firms learn from good and bad financial promotions that are out there. But that's really just a starting point. So what other resources or operational solutions are available? - Yeah, this is a great question, Victoria. I think there's a number, I mean, as I said, being the sandbox, we work with the FCA to get examples of financial promotions they've amended or we've drawn, but that's just one part of the puzzle, right? So there are other places like the advertising standards authority or the committee of advertising practice have codes, rulings for advertising standards. There's some examples that they have on their website as well, which is super helpful. There's obviously a lot of industry guidance from different bodies like the CISI, like the CFA Institute, where people are test to work in an ethical way or towards a certain standards again, and you can lean on those different bodies. I think I mentioned before, I ask goes another one. So they, for example, have some international case studies and cross-border learnings on things like influencers, on things like market compliance and different regular issue frameworks. But then there's also the internal policies, right? So I think that nothing beats the firm themselves, every single firm, above their own brand guidelines, right? And that would typically have a brand tone of voice. That leans on some sort of the consumer duty type rules, and that will impact marketing and the content that they create. But equally, you'll find the compliance on the flip side will typically have a financial promotions policy. It might not always be a PDF, it could be an Excel checklist, or it could be something that just lives in the brain of the compliance officer. But I think the combination of those things from both the regulator, standard setting bodies, different international bodies like IASK and all those internal policies create a pool where you can actually get a lot of information on what makes a good financial promotion or not and kind of help you create solutions like the one we've done at Finspector to help some of the people sitting in this intersect. Just mention Finspector. Some people may not know it. So could you talk a little bit more about what's all Kim about to what you're trying to do? Yeah, absolutely. So Finspector is a AI regulatory technology firm in helping firms with financial promotions compliance. And the way we came about is in 2022, I was actually doing some advisory work for an AI studio, an AI venture studio called Goodfolio. And that studio was at the time, we're earning a project where they were looking to build a investment platform to IASS, SIFS, general investment accounts for the retail market. And they had to become an authorised representative of a principal firm. And that principal firm was approving and reviewing a lot of the content that they were helping to create and put out for that particular platform. And there was always this multi-data in a round time getting stuff done. And being an AI studio, by the name, they understood sort of large language models, knowledge graphs, agente AI, or the rest of these buzzwords that happened in AI. And we sort of thought, surely this manual process can be made much more efficient using AI. And that's where the seed was planted within the studio and thought, maybe we can actually create a solution ourselves that solves with this brave problem that we're experiencing right now. And from that was born the idea of Inspector. So fast forward to today, the firm was registered in Communities House in March of 2025. And now we're at the stage where we scale and building sort of financial promotions, monitoring, review, and compliance tools for regulated markets. And so we helped them to do things, one inspecting content before it goes out the world as a promotion. And then we have a social media monitoring module where you can put the handle in, run it against an AI agent that understands your rules and the financial promotions rules of the regulator in which you have to adhere to. And it will fly potential risk back at scale. But I just want to caveat, I'm not taking away Stacey's jobs. So we actually work directly with people like Stacey. And this is where they really help us because every single client, we have their own bespoke rules. So almost every single instance that we create needs to be bespoke for the internal policies, et cetera, of that particular client. Honestly, that sounds like exactly what the industry needs. And as you say, you're providing a tool and a service that humans who work in businesses can then pick up and slot into their current architecture around financial promotions and the compliance. So clearly, you both know your stuff. So it may come as little surprise to our listeners that you are currently developing a certificate in financial promotions. What was the inspiration behind the course, perhaps Stacey, you could take us through it? Yeah, sure. So over the years, I train. I train other compliance professionals that I work with marketing because we are a partnership. We are not compliance and not blockers. We work together for the tools the same go. And in recent years, those are third party marketers, including AI providers, just so we can get the prompts right. And I understand that we need to adapt the way we teach to compliance. You might be quite heavy on rulebooks, cases with marketing. I'm like chucking the cheeky fine there. And then for influencers and third party marketers, it is strictly like simple do's and don'ts. And again, like Phil, I've been in this for over 12 years. And there's no real course. There's no real kind of thing for us to go out there. And I just thought, I've done it for years. Why not just put one out there? And for people in compliance who are just starting out or who need to-- it's not just compliance. It brings in our partners. It brings in marketing. It brings in influencers. A lot of the compliance professionals I work with don't understand the new features on social media. So it brings in that whole-- I'm taking a digital marketing course at the moment. Hopefully at the time of this going out would have passed it. But I bring that vocab to my colleague so that they can say no to the digital marketing team, but have you tried doing it like this? Because they fully understand their challenges too. So again, it's a very collaborative course. And for the time for this digital time that we're in. I probably add to that. And I think when Colin was working back in the day, on the-- I've got the 2016 edition 23 of the UK Financial Regulation Course by the CIS, I think now it's got big enough in terms of a problem. And also in terms of the number of formats that people create content. The financial promotion to marketing compliance probably deserves its own curriculum. And it's getting to the stage where it's much more complicated now than it probably was when I originally took this fantastic course. And I think now to Stacey's point, you've got such a different dynamic of players operating in that space. Where in the past you would probably have said, if you want to do a marketing compliance course, you probably just market it. That's a regulated people. So people working regulated firms. That's no longer the case. There needs to be people beyond the regulated sects of need to understand these rules. Like the social media influence, it's like the third party affiliates that Stacey mentioned. Yeah, just to clarify, I didn't actually write. I've just been training on it a number of times. But you're right. It's interesting because I think in the past, I always talked about the fact that your IT professionals should understand how IT impacts your front office and your back office now, it all works together. But now we're in a period where we actually are marketing to understand what the compliance rules are. We need the events people to understand what the rules are because it's coming over these different areas where before it probably was a gut signed up by compliance, tick the box, you know, use this presentation off you go. So we're now getting into a wider kind of remit. And you're absolutely right. It is something that I think maybe CSI should actually be looking at as well. Unfortunately, that brings us to the end of this episode. So Stacey felt a huge sincere thank you once again for generously sharing your FIN-prom expertise with us. Thank you very much for having us. Yeah, and thank you from myself. It's been a fascinating topic. And if you've enjoyed this episode, then please leave us a review. Subscribe on your children's dream platform. It gives us a thumbs up if you can. It would be great because there's a whole load of stuff that's coming in. But we've got regulatory transaction reporting. We have apprenticeships, and we also have the importance role of non-exec direct directors. We are keen to make the podcast interactive. So do send me your questions. It's victorious and our violin tin on any operational matters you are currently grappling with. And we will try our best to unpack them. And thanks for listening, everyone. Yeah. Bye-bye.