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Compliance · Financial Promotions

Affiliate promotions need oversight after approval

An approved script can change in a caption, edit or repost. Keep affiliate and influencer promotions connected to the version you reviewed and a named owner.

The approved script is in your records. The live post is on someone else’s account. Between the two, a creator has added a caption, cut the video and changed the opening line.

That is where a campaign review can lose sight of the promotion customers actually receive.

The commercial relationship belongs in the review

The FCA’s social-media guidance says firms should take proactive responsibility for affiliate promotions and maintain appropriate oversight. Firms remain responsible for promotions they make or cause to be made. The guidance also expects each communication to comply on its own. FCA FG24/1, paragraphs 1.3 and 1.6.

Start by mapping the arrangement rather than collecting creative files in isolation. Who commissions the content? Who edits it? Which accounts publish it? Where do links take the viewer? Who can require a correction?

These are practical scoping questions, not a substitute for assessing the legal responsibilities of each participant. They help prevent a campaign from entering production before anyone has established how it will be reviewed.

Give the creator a usable brief

An affiliate cannot reliably follow restrictions that arrive as a dense policy document with no connection to the campaign.

Our suggested brief separates the message from the boundaries. Explain the product, the intended audience, the claims that can be supported and the statements that must not be introduced. Identify the required review steps and the person who can answer questions before filming or posting.

Include the whole communication in the submission: the video or image, caption, thumbnail and destination page. Ask for the proposed placement as well as the source file. That makes it easier to spot a mismatch before production work is repeated.

Agree how changes will be handled. The creator needs to know whether a revised hook, an improvised reply or a repost requires another review. Leaving that decision until the content is already live creates avoidable uncertainty.

Check what was published

Publication is a useful checkpoint because it exposes differences that a source file cannot show. Compare the live promotion with the approved version and retain enough context to understand the placement.

Part of the promotionPractical check
Opening frame or thumbnailHas the main claim changed or become stronger?
CaptionHas new wording been added, or important context moved behind truncation?
Video editHave qualifying information or relevant frames been removed?
Destination pageDoes it match the offer and audience described in the promotion?
Repost or derivativeIs this the reviewed version, or a new communication needing assessment?

Prioritise the checks according to the product, the potential harm and the distribution arrangement. A routine screenshot of the account is not enough if it omits the content that needs review.

Keep the original finding attached to the affected place in the asset. For video, use a timestamp. For an image, identify the claim or region. The person making the correction should not have to infer which part of the promotion was questioned.

Define what monitoring actually covers

“Social media is monitored” is too broad to be a useful operational statement. Record the accounts and channels covered, what the process can detect and what still needs a manual check.

For a connected channel, new-post detection might create a review task. A change to a tracked website page might trigger another scan. Other placements may require the partner to submit evidence of publication. These are different mechanisms; give each a named owner.

Before launch, agree how a potentially serious issue will reach the person who can pause distribution or request a correction. Preserve the finding and the affected version before the live material changes. Record what was requested, what happened and whether the corrected post was checked again.

If content cannot be retrieved, record the coverage gap. A silent absence of data is not evidence that an account has published nothing problematic.

Close the campaign with its history intact

A useful campaign record connects the brief, submitted versions, findings, discussion, approval and checks after publication. It also shows unresolved questions and the decisions made about them.

That record helps when a partner relationship changes hands or an older post becomes relevant again. The next reviewer should not have to reconstruct the campaign from private messages and broken links.

Connor Financial Promotions supports file and post-link reviews, comments, version history and PDF exports. Monitoring is available for website changes and supported connected channels; the coverage should be checked against the campaign’s actual distribution plan.

The approval should remain connected to the promotion after it leaves your team.

James Zhao

Co-founder, Connor

James is the co-founder of Connor. After a corporate career at Barclays and KPMG as a software engineer, he built and exited his own software company. He has spent the last three years at the forefront of AI, and the most recent of them building AI-native products and the agent platform behind Connor.

Kashif Rafiq

Co-founder, Connor

Kashif is co-founder of Connor. He spent his career inside two of the most heavily monitored industries there are, investment banking at Goldman Sachs and energy at BP, working on the security and technology systems that keep regulated communications and data under control. He now builds the systems that let companies publish, permit, and observe what their AI agents can do.

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