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These are real outputs from the PromoCheck engine on example promotions, findings cited to the rule, verbatim quotes, a clean pass, and an honest refusal. No sign-in; nothing you do here leaves your browser.
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The promotion
“Invest in our crypto fund and earn guaranteed double-digit returns, risk-free. Get started today.”
This is a short-form social promotion for a crypto investment fund aimed at a retail audience. It presents guaranteed, risk-free double-digit returns with no capital-at-risk warning, no balancing risk disclosure, no prescribed high-risk warning, and no issuer/authorisation identification. Multiple serious breaches are flagged for compliance review.
Rules applied (10) · 6 flagged, 4 not flagged
“Not flagged” means no issue was raised for that rule on this product type, it is not a statement of compliance. A qualified person reviews every result.
- [GUARANTEE]No misleading guarantees of returnCOBS 4.2.1R
“earn guaranteed double-digit returns, risk-free”
The promotion presents an investment return as guaranteed and risk-free with no named guarantor. Crypto investment returns cannot be genuinely guaranteed, and this language is highly misleading for a retail audience.
Fix: Remove the words 'guaranteed' and 'risk-free'. Do not present investment returns as certain. State clearly that returns are not guaranteed and capital is at risk.
- [RISKWARN]Capital-at-risk / prescribed risk warningCOBS 4.12A
“Invest in our crypto fund and earn guaranteed double-digit returns, risk-free.”
This is a high-risk crypto investment promotion with no capital-at-risk warning at all. High-risk investments require the specific prescribed risk warning, which is absent here.
Fix: Add the prescribed high-risk investment warning, for example: 'Don't invest unless you're prepared to lose all the money you invest. This is a high-risk investment and you are unlikely to be protected if something goes wrong.'
- [BAL]Balanced presentation of benefits and risksCOBS 4.5.2R
“earn guaranteed double-digit returns, risk-free”
The promotion leads with returns and upside while omitting any of the corresponding risks. Benefits and risks are not given equal prominence.
Fix: Balance the return claim with clear, equally prominent disclosure of the risks, including that the value can go down as well as up and that all capital could be lost.
- [TARGET]Appropriate for the target audienceCOBS 4.12A
“Get started today.”
A high-risk crypto investment is being pushed to a general retail Instagram audience with no appropriateness or categorisation step and an unqualified call to action.
Fix: Include the appropriate categorisation/appropriateness process and restrict promotion of this high-risk product in line with the marketing restrictions for restricted mass market investments.
- [SOCIAL]Standalone compliance (social/short-form)FCA FG24/1
“Invest in our crypto fund and earn guaranteed double-digit returns, risk-free. Get started today.”
This standalone Instagram post contains no risk warning and no required disclosures. Each short-form promotion must be compliant and balanced on its own.
Fix: Ensure the required risk warning and balanced content appear within the standalone post itself, not on a linked page or bio.
- [IDENT]Clear identification as a financial promotionCOBS 4.3 / PERG
“Invest in our crypto fund and earn guaranteed double-digit returns, risk-free. Get started today.”
There is no identification of who is communicating or approving the promotion, nor any indication it is a financial promotion from an identified firm.
Fix: Identify the firm communicating the promotion and, where relevant, the FCA-authorised approver, so the reader knows who is behind it.
PromoCheck is an automated compliance-review aid, not legal or regulatory advice, and does not approve or certify any financial promotion. The FCA places responsibility for a financial promotion on the regulated firm, not on any tool. Every flag must be reviewed and signed off by a suitably qualified person before the promotion is published. Findings may be incomplete or wrong; absence of a flag is not a statement of compliance. Use is subject to the Terms of Service; liability is limited as set out there.
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