Yes, as a first reviewer. An AI agent can check a draft financial promotion against your rules checklist: balance of benefits and risks, required warnings, consistency with product terms, and claims it cannot evidence. It then drafts amendments. Approving the promotion for publication stays with a competent, authorised person, because the firm answers for every promotion it issues.
What makes a promotion compliant?
A financial promotion is any communication that invites or encourages someone to engage in financial activity: an advert, a social post, an email, a web page, a video. Regulators, such as the FCA in the UK, expect promotions to be fair, clear and not misleading. In substance, that means benefits are not presented without the relevant risks given similar prominence, required information and warnings are present, claims can be substantiated, and the overall impression matches the product.
The last test is the hard one. A promotion can contain every required phrase and still mislead, through emphasis, imagery or what it leaves out. So review needs both a checklist and judgement. An agent is good at the first and useful for the second.
What may the agent prepare?
The agent may:
- Check required elements: firm name, risk warnings, representative examples, eligibility conditions, and any channel-specific requirements.
- Compare every factual claim with the product terms and flag any that differ, such as a rate, fee or feature.
- Flag claims needing evidence, such as "fastest" or "most popular", and ask for the evidence.
- Check prominence: whether risk information is as visible as the benefits, including on small screens and in video captions.
- Check the target audience against the product's target market.
- Draft amendments and a review note with each issue explained.
- Track the approval record and re-review when product terms change.
The approver decides:
- Whether the promotion, taken as a whole, is fair, clear and not misleading.
- Whether evidence for a claim is sufficient.
- Whether the audience and channel are appropriate.
- Approval, conditional approval or rejection.
- Withdrawal of a live promotion that is no longer compliant.
What does a review look like?
Take a savings provider launching a fixed-rate bond. Marketing submits a social media video and a landing page.
The agent checks the landing page and finds the rate and term match the product terms, but the page says "access your money any time", while the terms allow early access only with a loss of interest. It flags the inconsistency and drafts corrected wording. In the video, the agent finds the rate shown in large text for eight seconds while the early access condition appears in small text for two seconds at the end. It flags the prominence issue. It also notes that the video's targeting includes an age group outside the product's target market.
The approver agrees with all three, accepts the corrected landing page wording, and asks marketing to re-cut the video with the condition shown on screen with the rate. She approves the landing page and holds the video. The agent records both decisions and sets a re-review for the date the rate changes. The full method is in how to review financial promotions before publication with an AI agent.
Which controls make agent review safe?
- Approval is a person's act. No promotion is published on the agent's review alone.
- Product terms are the source of truth. Claims are checked against the current product terms from the policy or product library, not against earlier marketing.
- Changes trigger re-review. When a product term changes, the agent finds every live promotion affected.
- Rules are owned by compliance. The checklist the agent applies is maintained by people and reviewed on a cycle, as part of the annual policy review.
- The record shows both views. The agent's findings and the approver's decision sit together.
Terms that appear in promotions often come from contracts too; see can an AI agent review contracts for compliance? The general principle is in our guide to AI compliance agents.
Questions people ask
Can the agent write promotions as well as review them?
It can, but the same agent should not do both. A separate review, with its own brief, gives a real check.
Do social media posts by staff count as promotions?
They can, if they invite people to take up a financial product. Your policy should say how staff posts are reviewed, and the agent can apply it.
Can the agent monitor live promotions?
Yes. It can check live pages and adverts against the approved versions and flag changes or terms that have gone out of date.