Put the agent between the marketing draft and the compliance approver. It checks every claim against evidence, confirms required risk warnings and disclosures are present and prominent, tests balance between benefits and risks, and drafts a marked-up review. A named compliance approver signs off or rejects each promotion, and nothing is published without that sign-off on file.
What is a financial promotion review, and who owns it?
A financial promotion is any communication that invites or encourages someone to take up a financial product or service: adverts, web pages, social posts, emails, app screens, scripts and, increasingly, content produced by AI agents. In most markets, promotions must be clear, fair and not misleading in substance, carry prescribed warnings for certain products, and present risks as prominently as benefits. Many regimes require a person with the right authority to approve promotions before they are communicated.
Marketing owns the content. Compliance, usually a financial promotions team, reviews and approves. The volume problem is real: a single campaign can produce hundreds of variants across channels and formats. Whether an AI agent can review financial promotions explains why the agent's role is review, not approval.
What are the steps?
- Person, marketing: submits the promotion with its target audience, channels, product and the evidence for every claim.
- Agent, depth 1: identifies the product and the rules. Which product type, which audience, which warnings and disclosures apply under your approved checklist for that product and market.
- Agent, depth 1: extracts every claim. Rates, returns, savings, comparisons, "best", "free", "guaranteed", testimonials, and any implied claim in images or layout.
- Agent, depth 1: matches claims to evidence. Each claim against the evidence supplied and against the product's current terms and rates. Unsupported claims are flagged.
- Agent, depth 1: checks warnings and prominence. Present, correct wording, adequate size and position for the format, visible without scrolling or clicking where required.
- Agent, depth 1: tests balance. Benefits against risks and costs, and whether the promotion would mislead the target audience in particular.
- Agent, depth 2: drafts the review. A marked-up copy with every issue, the rule or checklist item it relates to, and suggested fixes.
- Person, compliance approver: decides. Approve, approve with changes, or reject, with reasons.
- Agent, depth 1: checks the published version against the approved version once it goes live, and on a schedule while it stays live.
| Step | The agent does | Depth | Stays with a person |
|---|---|---|---|
| Submit | Nothing | None | Marketing |
| Rules | Applies the right checklist | 1 | Maintaining the checklist |
| Claims | Extracts explicit and implied claims | 1 | None |
| Evidence | Matches claims to proof and terms | 1 | Judging adequacy |
| Warnings | Checks wording and prominence | 1 | None |
| Balance | Tests risk against benefit | 1 | Judging fairness |
| Review | Drafts mark-up and fixes | 2 | Approving or rejecting |
| Live check | Compares published to approved | 1 | Acting on differences |
Which controls apply, and what evidence does each leave?
Approval by a named person. The agent cannot mark a promotion approved. Evidence: the approver's name, the version approved and the date.
Claims register. Every claim with its evidence and the date the evidence was checked. Evidence: a register that lets you withdraw promotions quickly when a rate changes.
Version locking. The approved version is stored as approved; any change needs re-approval. Evidence: hash or version on the approval, compared to what is published.
Live monitoring. Promotions drift: a web page is edited, a rate changes, an offer ends. Evidence: scheduled comparison results and withdrawals.
Checklist under change control. The rules the agent applies are maintained by compliance. Evidence: checklist version on every review.
What should you measure?
- Issues found by the agent that the approver confirmed, and the reverse.
- Promotions approved first time, a measure of marketing quality.
- Live promotions found out of line with their approved version.
- Turnaround time from submission to decision.
- Complaints or regulator queries about published promotions.
Where does it usually go wrong?
Implied claims missed. An image of a beach with a pension product implies an outcome, and a countdown timer implies urgency that may not be real. The agent must review images, layout and tone, not just text.
Channel limits ignored. A social post with a character limit cannot fit the full warning, so the warning is dropped. Some formats are unsuitable for some products; the approver should say so.
Personalised content at scale. An agent that generates personalised marketing messages creates a new promotion for each customer. Approve the template and the rules for variation, and sample outputs. Testing those rules before use follows the same discipline as testing an AML agent before using it: real cases, scored against a floor.
Stale evidence. A rate was correct at approval and changed the following week. The claims register should trigger re-review, and withdrawal if needed, when product data changes.
Approval treated as a formality. If the approver accepts every agent review unchanged, the approval adds nothing. Sample their decisions. The same pre-release logic applies elsewhere, as in reviewing payment sanctions hits before release: the agent prepares, a person releases.
The overall stance on compliance agents is in AI compliance agents.
Where Pryme fits
In Pryme, product terms and rates reach the reviewing agent from systems of record as sealed facts, while evidence supplied by marketing is declared until checked, so the review shows which claims rest on records. Approving a promotion is outside the agent's role scope; an attempt is refused and filed.
Questions people ask
Can the agent rewrite a promotion so it passes?
It can suggest fixes for each issue. Marketing decides how to rewrite, and the revised version goes back through review. An agent that rewrites and approves its own text removes the check.
Does the agent need to review promotions made by other agents?
Yes. Customer-facing agents that recommend or describe products may be making promotions. Their templates and outputs need the same review and sampling.
How do we handle promotions in several markets?
One checklist per market, applied according to the promotion's audience. A promotion that will appear in several markets must pass each checklist.