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Financial promotions (including digital media) for cryptoassets

2 half-days with case study examples – this course can be adapted to different types of business


1: Introduction

Promotions beyond the FCA rules – Codes of Advertising Practice, law, good taste

What is a promotion and the extent to which it matters?

Financial Services and Markets Act, section 21 promotion prohibition

Financial Promotion Amendment Order 2023 and the extension of investments to cover qualifying cryptoassets

Extension of firm to include registered cryptoasset businesses but not electronic money or payment services businesses

Non-promotional communications and image adverts

Some exemptions from parts of the rulebook in the Financial Promotions Order

Removal of HNW and self-certified sophisticated investor exemptions

Finding the rulebook – COBS 4.12A – restricted mass-market investments

FG 24/1 on social media

The FCA Principles

The effect of rule breaches – punishments in FSMA for breaching the rules


2: The Rulebook

What do the conduct of business rules apply to?

Clear, fair and not misleading in COBS 4 and the ASA Codes

Compulsory risk warnings and risk summaries  – generally and for website and other digital media

Risk disclosure more generally prominence & font-size rule

Restrictions on incentives for cryptoasset promotions

Rule against unfair comparisons

Rules and guidance on specified expressions


Making promotions identifiable as such

Naming the firm, the regulator and the applicable compensation scheme

Past, simulated and future performance

Direct offers for cryptoasset promotions – cooling off, personalised risk warnings, categorisation and appropriateness testing


3. Mainstream issues in Digital media and promotions

Social media – FG 24/1

Pay-per-click and other sponsored links

Websites and disclosing how to complain

Unsolicited e-mail


4. Systems and controls

Sign-off procedures

Risk Management

The Compliance function

Approval of promotions for others (if relevant)


Get in touch

Contact Adam by e-mail, phone or post at:

E-Mail: or

Mobile: 07900 248150

The Attic, 117 Priory Road, London NW6 3NN.