Ad Compliance and Legal · Restricted-vertical compliance (finance, health, crypto, gambling)
Market-by-market clearance for crypto, gambling, finance and health campaigns, covering MiCA, CNMV, DGOJ and the UK promotion regime.
About this service
Spain is where this goes wrong most often, and the reason is that the rulebook moved. Advertisers are still being handed restrictions from the 2020 text of Royal Decree 958/2020 that the Supreme Court annulled in 2024, while missing the requirement that still bites: a crypto campaign expected to reach more than 100,000 people has to be notified to the CNMV ten days in advance, carrying a specific risk warning in a specified place and size. One of those errors costs you reach you never had to give up. The other one is a file.
Regimes we read directly:
Crypto. MiCA on marketing communications, which requires them to be identifiable as such, fair, clear, not misleading, consistent with the white paper, and notified to the competent authority. Alongside it, CNMV Circular 1/2022 with its mandatory Spanish-language warning, and the UK financial promotion regime for cryptoassets, where the 24-hour cooling-off period for a firm's first-time investors and the prohibition on refer-a-friend incentives have ended more growth loops than any other single rule.
Gambling. Royal Decree 958/2020 as it now stands after the 2024 judgment, DGOJ licensing scope, the broadcast window, and the bonus rules that decide whether your welcome offer can be shown to anybody who is not already a verified registered player.
Finance. The financial promotion regime and, since the approver permission regime came in, the practical question of who will actually sign your promotion if you are not authorised yourself.
Health. Royal Decree 1907/1996 and the closed list of authorised health claims, which is a register anybody can check and which most supplement copy fails against in its first line.
How the clearance is written:
Per market, per channel, per claim. You get the rule, the source, what you may say, and the sentence we would say instead. Where a market is closed to you we write closed rather than risky, and we write it early enough that the budget can move.
A worked example of the difference:
A returns figure that is unremarkable in a UK institutional context, unlawful in a Spanish retail crypto campaign without the warning, and grounds for a financial products disapproval on Google in both. Three rules, one line of copy, and the fix is a different sentence in each market. That is the whole job.
Deliberately excluded:
Licence applications. We are not the people who obtain a DGOJ or CNMV registration for you, and we will introduce you to the people who are. Regulator correspondence and enforcement defence. Tax and corporate structuring, which is where a surprising number of these conversations try to go.
Say no to us if:
You are taking Spanish gambling traffic without a licence. You want a campaign cleared retroactively because it is already running. Or you want a second opinion to set against advice you have already had and did not like; get a third from counsel, not from us.
Who does the work:
Two reviewers, one on the market rules and one on the platform policies, because a claim can be entirely lawful and still undeployable. Finding that out after the legal review is the expensive order to do it in.