Financial Promotions Regime: Enforcement Trends

Enforcement activity under the financial promotions regime continues at an elevated pace, with particular supervisory attention on social media promotions and the growing use of financial influencers by regulated and unregulated firms alike.

Firms should note that supervisory scrutiny extends to promotions made on their behalf by third parties and affiliates, not just promotions the firm issues directly — an area where accountability is frequently less clearly assigned internally than firms assume.

We recommend firms using third-party promotional channels conduct a specific review of oversight arrangements for those channels, given the enforcement pattern suggesting this is an area where documented policy and actual practice frequently diverge.

This briefing reflects Alden Advisory's general commentary on a developing regulatory topic and is not legal or regulatory advice. Firms should seek specific guidance for their own circumstances.