Most compliance teams can tell you exactly what they approved. Far fewer can tell you what is live right now. Financial promotions monitoring closes that gap: it checks the posts, pages and ads consumers actually see, catches changes after approval, and gives someone the job of fixing what it finds.
Two pieces of research published this year show why that matters. Neither proves an approval process failed. Both show that what reaches the public is often not what anyone signed off.
Dozens of firms on the FCA warning list were still running ads
On 7 October 2026, Which? published an investigation into 300 recent FCA warning list entries. Dozens of those unauthorised firms had adverts in the public ad libraries of Meta, Google or TikTok. Nine kept advertising after their warning was published, some for weeks or months. Two Meta ads were still active when Which? checked.
Those are unauthorised firms, not regulated ones. But the mechanism is the same one that catches authorised firms out: a warning, a rule change or an expired offer happens on one side, and the live ad carries on regardless because nobody is looking at it.
What Adclear found in crypto influencer posts
Earlier this year we analysed 57 of the most-viewed Instagram and TikTok posts promoting crypto trading, published over a little more than a year. 89% had at least one potential compliance issue against the FCA's financial promotion rules.
- 56% made no reference to the financial risks of trading crypto (69% on Instagram, 43% on TikTok).
- 54% did not disclose that the post was an advert, sponsorship or partnership.
- 40% did not present risks and rewards in a balanced way.
- 30% omitted the past performance warning.
- 11% promised guaranteed returns.
A few caveats. This was a selected sample of high-reach posts, not an estimate of all crypto content, and these are our assessments rather than FCA findings against the accounts. The disclosure figure also depends on the commercial relationship behind each post, which is not always visible from the outside.
What stood out was how basic the failures were. Missing risk warnings and missing ad disclosures are not hard legal questions. They are the kind of thing a reviewer would catch in seconds if the published version ever reached one. Our earlier piece on crypto marketing compliance in the UK covers the underlying rules.
What the FCA expects from firms using influencers and affiliates
The FCA's social media guidance, FG24/1, is direct on this point. Firms working with affiliates should take proactive responsibility for how those affiliates communicate financial promotions, with appropriate monitoring and oversight. A firm remains responsible for promotions it makes or causes to be made, whoever presses publish.
The guidance also expects each promotion to stand on its own. Risk information has to be prominent and suited to the format. A compliant landing page does not fix a social post that links to it, and a caption, a video overlay and a destination page can each change what a consumer understands.
Put those together and the published version is the thing that has to be right, not the version in the approval record. We've written a fuller breakdown of what FG24/1 actually requires.
How live content drifts from what was approved
Take an investment platform. Compliance approves a 60-second video with a balanced product explanation and the risk warning at the end. The influencer posts a 30-second cut and the risk warning is in the half that was dropped. The approval record still holds the original. Viewers see something else.
Other changes are quieter. An affiliate updates a comparison table. An influencer rewrites a caption to improve engagement. A promotional rate stays on a landing page after the offer ends. And some content goes out of date with nobody touching it at all, because the product terms or the evidence behind a claim have changed.
The useful distinction for the team is between a record of approval and evidence of the promotion's current state. You need both, and you need them connected, so you can see where a fresh review is due.
Building a post-publication monitoring process that works
Here is the operating model we see working across regulated firms. Adapt it to your products, your partner arrangements and the rules that apply to you.
1. Keep an inventory of live promotions
Record the accounts, URLs, campaign owners and partners. Link each asset to its approval record where one exists, with the intended audience, publication date and any expiry or review date. Agree with partners how they will tell you about new posts and new channels. If you do not know a promotion exists, you cannot monitor it.
2. Check what was actually published
Build a publication check into the campaign handover. Review the asset in its real format: captions, overlays, links, the first three seconds of a video. For video, check what is said as well as what appears on screen. Capture a dated copy so there is no argument later about what was reviewed.
3. Set review frequency around risk
Look more often at promotions where an error would do more damage, where partners edit content frequently, or where claims depend on figures that change. Write down the reasoning behind the schedule. A product change, an expired offer or a partner complaint should trigger a check between scheduled reviews. Our piece on why sampling doesn't cut it for affiliate and influencer monitoring goes deeper on this.
4. Give every issue an owner
A useful alert names the content, explains the concern and reaches someone who can act. Agree escalation routes and who has the authority to request changes or suspend a campaign. After a correction or removal request, check the live asset again and record the outcome. An issue that was flagged but never verified as fixed is still an issue.
5. Feed findings back into the next campaign
Look for repeat problems by partner, product and format. If the same warning keeps disappearing from short-form video, the fix is in the brief and the production process. Track how long issues stay open and how many corrections are verified, alongside how many checks you completed.
Connecting approvals with post-publication monitoring
Adclear combines financial promotion reviews and approvals with post-publication monitoring in one system. Scheduled scans cover websites, social media, affiliate sites, Discord and Telegram, and compare each live asset with the approved version so changes surface automatically. Per-partner compliance scores show which affiliates and finfluencers need attention, and partners can fix issues directly in the platform.
For compliance and marketing teams, that connection means a campaign is easier to oversee for its whole life, from sign-off onwards. The approved version is the reference point. Monitoring tells you when the live version no longer matches it.
Explore Adclear's post-publication monitoring to see how your team can check live promotions and manage changes across every channel.
Once you're booked in, we'll send you a free playbook on Financial promotions compliance for FinTechs.
