Why Marketing Materials Need a “Compliance Review”
for cross-border payments、MSO/MSB、virtual assetsRelated business、For wealth management and fintech companies，Marketing materials are often one of the first objects sampled by regulators and banks for due diligence。The common risk is not that "the content is not beautifully written"，RatherUnable to prove、Insufficient disclosure、Imbalanced expression、or misleading in a specific context。
We use an implementable review mechanism，Help companies achieve：
- before launch：Check publicity caliber and risk disclosure，Reduce subsequent rectification and removal costs；
- Delivering：to channels、KOL/Agent、Material version for consistency control；
- After placement：Create auditable traces (evidence chain)，Dealing with bank scrutiny、Partner compliance inquiries and regulatory spot checks。
If an enterprise involves both cross-border business and multi-jurisdictional promotion，Can be combined with ourCross-border business compliance solutions。
What are we reviewing?：Covering material types and high-risk touchpoints
Product Description、Cost and exchange rate display、Bonus activity terms、Customer application scope、Risk reminder location and visibility。
Statement of benefits and success cases、contrastive statement、Exaggerate convenience/success rate、Implied "guarantee/guarantee"。
Third-party representation consistency、Distribution discourse boundaries、Rebate Disclosure、Misleading titles and “promise of traffic diversion”。
business model、Compliance qualification statement、Partner quotes、Data sources and verifiability、Expression of future plans。
Reward threshold、limit、Validity period、Anti-cheating rules、Blacklists and Compliance Denial Rights、Dispute handling terms。
EDM、Short message、Whatsapp lingo、Customer service SOP about fees、Time limit for arrival、Description of Chargeback/Hold。
For payment and financial technology scenarios，We pay special attention to the following "high-frequency thunderstorms"：
- Fees and costs：Only displays the "lowest rate" but does not explain the applicable conditions、surcharge、Exchange rate spreads and caps；
- Receipt and success rate：Express "usually/average" as "guaranteed/second to"，or omit the failure condition；
- Compliance qualifications：Represent the license under application as approved，or use wording that is likely to evoke regulatory associations；
- Risk disclosure：Place risk reminders in invisible areas、overgeneralization、Or it is unbalanced with the main copy；
- Anti-Money Laundering Touchpoints：to "freeze"、Supplementary parts、There is a lack of transparent explanations in key aspects such as “Proof of Source”，Can easily trigger complaints and public opinion。
review framework：From compliance mapping to auditable evidence chain
By channel/audience/touch point (account opening、top up、exchange、Cross-border remittance、Rebates) Create lists and priorities。
around misleading statements、balanced disclosure、Cost display、Appropriateness and AML touchpoint setting review items and red lines。
to data、contrast、Success Stories、Provide evidence support and traceable citations for key statements such as timeliness and rates.。
Express important constraints upfront，Make sure disclosures are clear、visible、Match the main copy。
Output review comments、Revision and approval records；Create version number、Release date and channel delivery ledger。
Conduct random inspections on KOL/agent secondary creation and landing page dynamic content，Forming a closed loop of rectification and review。
If the company is also building a compliance system (KYC、Transaction monitoring、risk assessment andData compliance），Can be linked with the following abilities，Form a closed loop of "marketing customer acquisition - account opening KYC - transaction monitoring - complaints and investigation"：
- Fintech Compliance Consulting
- KYC identity verification system
- transaction monitoring system
- Data security assessment
Review steps and division of responsibilities
The recommended workflow is：Collect marketing manuscripts and evidence of claims；Determine the product、target customers、Release areas and channels；Check earnings、risk、Fees and License Statements；Review and document approval by compliance or legal personnel；Release a controlled version；Keep records of evidence and subsequent corrections。The business leader is responsible for facts and product information，Compliance or legal review personnel are responsible for making judgments about applicable rules，Publishers are responsible for version and channel consistency。This is the division of labor in project management，It is not a uniform quorum requirement for each region.。For applicable businesses in the UK, please refer to FCA COBS 4.2 fair、Clear and non-misleading requirements，Other regions should be reviewed according to local regulations。
Source basis (verified on September 6, 2026)：FCA COBS 4.2：fair、Clear and non-misleading communication。The specific obligations shall be subject to the applicable system and the facts of the individual case.。
Cost and budget reference (including optional license packages)
Marketing material review is usually based on "material quantity"、Channel complexity、business risk level、Whether it involves multi-language and multi-jurisdiction pricing?。
The service fees are subject to applicable jurisdiction、Business scope、Main structure、Data complexity and delivery schedule assessment；Involving government fees，The latest fees announced by the corresponding regulatory agency shall prevail.。
If you need to simultaneously improve the account opening pass rate and communicate with the bank on the quality of materials，Can be referenced：Hong Kong bank account opening guide
FAQ：Review issues that companies are most concerned about
Depends on material quantity and risk level。A common approach is to first do “high-risk material placement (landing page)、Account opening link、A quick review of KOL script)”，Then review long-tail content in batches and create reusable templates。
It is recommended to review them separately and align them for consistency.。The strength and weakness of wording in different languages、The location of conditional qualifications and risk warnings may be different，It is easy for "Chinese is more radical/English is more conservative" to lead to compliance gaps.。
Can。We usually recommend building a "library of available materials" + Banned words/banned commitment list + Sampling inspection and penalty clauses”，And conduct pre-launch review of key KOL scripts。
Usually includes review comments form、Revision comparison (redline/annotation)、Finalized、Version number and delivery ledger field suggestions，Facilitate subsequent audits and due diligence。
cannot be replaced。Marketing review focuses on 'risk of misleading versus disclosure balance' of external communications，Legal opinions and license compliance conclusions must be issued by professionals or institutions with corresponding qualifications。
The key is not the word count，And in the way of presentation：Clearly express constraints and risks in main copy，and ensure important information is visible、understandable、As obvious as the main selling point。
Confirm the products to be promoted first、Activity、main body、Customers and target areas，Then determine whether it is subject to corresponding financial promotion restrictions。The SFC’s Advertising Guidelines for Authorized Funds and the UK COBS have different scopes of application.，You cannot use the review conclusions of one market to cover the whole world.。 SeeBritish FCA on fairness、Rules for clear and non-misleading publicity。
Must be true、Not misleading，clear、fair、Balanced presentation of risks，Information is timely and consistent with the offering documents；Publishers are responsible for content and dissemination oversight。This guidance applies to relevant recognized collective investment schemes，Not the same rules for all corporate advertising。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
Advertising for applicable authorized funds，The publisher cannot be exempted from responsibility for the accuracy of the content；Quoting external information should have reasonable grounds to believe that it is accurate、Complete and up to date，and retain the source and date。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
Do not use without basis。Relevant words must truly conform to the product mechanism，and clearly state that the guarantor、condition、Scope and risks；British COBS also requires that when using guarantee or protection words, they must be fair, clear and not misleading.。 SeeBritish FCA on fairness、Rules for clear and non-misleading publicity。
Should be combined with media、Font size、Layout and publishing position to determine visibility，Do not use small print to cover up the exaggeration of the main copy。Risk warnings of authorized funds must be clear and readable、Proper location，and correspond to relevant information。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
The statistical period should be checked、Computing basics、Fee and dividend processing、Source and date，Avoid arbitrarily selecting favorable intervals。Ranking、Awards and performance must be based on evidence，The applicable minimum record and history display rules should be confirmed item by item in accordance with product guidelines.。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
cannot。In principle, the performance information advertised by a recognized fund must be actual results.；Hypothetical examples used to explain complex mechanisms have specific limitations，Unrealistic returns must be clearly marked and adverse scenarios presented in a balanced manner。Other products need to check the applicable rules separately.。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
Different investment scopes、risk、Divide aperture or coordinate scale will cause distortion。Comparables should be compared，Explain index and calculation basis，Charts are clear and not distorted；Significant changes in strategy or benchmark should also be explained。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
Applicable fund advertisements must display relevant currency returns or exchange rate risk warnings in accordance with the guidelines，And explain the basics of conversion。You cannot only show results that are beneficial to investors in certain currencies and ignore exchange fluctuations.。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
Does not imply official recommendation or guarantee of income。If an authorized fund advertisement mentions that it is authorized by the Securities and Futures Commission，It must be noted that endorsement does not represent official recommendation；Institutional license、Product approval and unregulated business must also be clearly distinguished。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
Do not circumvent licensing or product promotion rules by using the Internet。China Securities Regulatory Commission’s Online CIS Guidelines Emphasize Media Neutrality；Fund advertisements aimed at the Hong Kong public usually require a determination of whether prior approval or statutory exemptions apply.。 SeeSFC Guidelines on Online Advertising and Offerings of Collective Investment Schemes。
When COBS rules apply，It should be clear which matters are not regulated by the FCA or PRA，Avoid using agency regulatory status to mislead customers into thinking that all products and businesses have the same protection。 SeeBritish FCA on fairness、Rules for clear and non-misleading publicity。
Limited media time or space is not exempt from disclosure。When fund advertising rules apply，Audio warnings must be read clearly，Visual warnings must be displayed for sufficient time；Design and review should both consider what users actually see or hear。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
Need to check if the published version is still up to date、Accurate and consistent with current documentation。It is recommended to save delivery channels、Version、Date and removal record，Continuously inspect agent rewritten content；One review does not guarantee that all future communications will be compliant.。 SeeSFC Advertising Guidelines for Authorized Collective Investment Schemes。
If you want to integrate marketing review into your overall compliance governance (system、systems and training)，Can learn more：risk assessment systemandHong Kong Xintong AML/CRM system。
Factual and Compliance Review of Financial Marketing Materials
Financial marketing materials should accurately describe the service entity、License scope、risk、Fees and restrictions，Can't register company、The partner's qualifications or technical capabilities are written as its own license or guaranteed results。
- Check the name of each license plate、Licensed entity、License scope、Valid status and target countries。
- Remove Guaranteed Return、Guaranteed account opening、Guaranteed approval、Absolute statements such as zero risk and excessive comparison。
- Clearly disclose fees、risk、appropriateness、Customer assets and complaint channels。
- retain approver、Version、Release channel、Offline records and regulatory update triggering mechanism。
Official verification：IOSCO Investor Protection Information。Specific obligations must be combined with the subject、business、Customer location and latest regulatory confirmation。
