Regulatory and compliance · Compliance officer, marketing lead, in-house regulatory counsel
Check a financial promotion before it is approved
An investment platform has a campaign of eleven pieces going live in a fortnight, spanning email, social posts and a landing page. The check runs each item against the promotion rules and marks the four that cannot go out as drafted.
- Agents
- Compliance & Regulatory
- First draft
- An item-by-item assessment across the campaign comes back from one run, before the go-live date.
The problem
Step 01 of 05
Load the campaign
All eleven items are uploaded, along with the platform's approval policy and the target audience note from the marketing team.
Project Halcyon: SPA warranties and disclosure
Buy-side warranty review, disclosure analysis and cited due-diligence grid.
- Client
- Halcyon Bidco Ltd
- Reference
- WC-2026-0412
- Practice area
- Corporate / M&A
- Jurisdiction
- England and Wales
- Responsible partner
- E. Vance
No conflict check on file.Chat, on this matter
Compare warranties with the disclosure letter.
Three high-priority exceptions require action: the unregistered charge, the change-of-control right and the tribunal claim.
Send a message… (@ to mention tools)BalancedPrepare for- 25 Aug
Disclosure exceptions matrix
Chat
- 21 Aug
Disclosure exceptions matrix
Run · completed · 560 credits
- 18 Aug
Project Halcyon: Disclosure Letter
Document · indexed
- 16 Aug
Project Halcyon: Share Purchase Agreement
Document · indexed
- 4 Aug
Matter opened
Opened
Step 02 of 05
Build the assessment columns
Columns cover whether the item is a promotion at all, the audience, balance of benefit and risk, prominence of warnings, past performance wording and the record of approval.
Document Parties and effective dateTEXT Term and renewalTEXT Limitation of liabilityTEXT Governing lawTEXT nda-hartwell-meridian.txt saas-agreement-northgate.txt board-minutes-hartwell.txt Step 03 of 05
Run the campaign through the grid
Each item is answered against every column with the wording quoted, so a failure points at the sentence that causes it rather than at the item as a whole.
Document Parties and effective dateTEXT Term and renewalTEXT Limitation of liabilityTEXT Governing lawTEXT nda-hartwell-meridian.txt saas-agreement-northgate.txt board-minutes-hartwell.txt Step 04 of 05
Read the four failures
Two social posts state a return without balancing risk, one email uses past performance without the required wording, and the landing page places the warning below the visible area.
Document Parties and effective dateTEXT Term and renewalTEXT Limitation of liabilityTEXT Governing lawTEXT nda-hartwell-meridian.txt saas-agreement-northgate.txt board-minutes-hartwell.txt Step 05 of 05
Give marketing the fixes
Each failure comes back with replacement wording and, for the landing page, a placement instruction the designer can act on.
Replace the UK/Ireland/EU non-compete with a 3 to 6 month restriction tied to competing corporate-law work.
Replace blanket data consent with a lawful-basis clause and a separate monitoring notice.
Remove the five-day carry-over cap and reference the statutory carry-over rules.
Narrow the client non-solicit to clients dealt with in the final 12 months.
Add an explicit working-time opt-out withdrawal mechanism.
Confirm the bonus clause states the discretion is exercised in good faith.
What comes back
A document, not a transcript.
- Every item assessed against the same columns, with the offending sentence quoted where an item fails.
- Replacement wording for each of the four items that cannot go out as drafted.
- A placement instruction for the landing page warning, written for the designer rather than the lawyer.
- A note on the approval record the firm needs to keep for each item once it is signed off.
Authorities it checks
- Financial Services and Markets Act 2000, s 21
- FCA Handbook, COBS 4
What it does not do
- It does not approve a financial promotion. Approval is an authorised person's act and stays with them.
- It does not assess whether the underlying product is suitable for the audience described.
- It does not publish, schedule or withdraw any item.