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Under the finfluence
Your guide to influencers, regulation, and compliant marketing
Under the finfluence: Your guide to influencers, regulation, and compliant marketing
—About Global Relay
Social media has fundamentally changed the way individuals access information, including financial advice.
Many retail investors—especially those from younger demographics—now no longer get their financial or investment advice through bank advisors, wealth managers, or a Financial Times subscription. Instead, it appears on TikTok feeds, Instagram ads, podcasts, and their YouTube algorithm.
The shift is undeniable, with many firms now working with social media finance influencers, or “finfluencers,” to reach younger and more online audiences. Research shows that:
Finfluencers present financial services firms with new opportunities to reach emerging audiences at scale but also present new avenues of risk. Regulators have begun to crack down on finfluencers and the firms that employ them in recent years:
In 2024, the Financial Industry Regulatory Authority (FINRA) fined a firm $850,000 for social media claims made by a finfluencer that were “not fair or balanced” and “contained exaggerated or misleading claims.”
In 2025, the Financial Conduct Authority (FCA) issued over 650 social media takedown requests and has taken several individuals to court for unauthorized financial promotions on social media.
In April 2026, seventeen global regulators undertook a coordinated “week of action” against noncompliant finfluencer activity.
Understanding the regulations that apply to social media marketing activity, and how firms can ensure the finfluencers they work with comply with these rules, is essential for organizations that want to engage the next generation of investors. Online content may be beginning to blur the lines between education, marketing, and investment advice, but regulatory expectations are very clear.
This guide explores how regulators in Canada, the U.S., and the U.K. view finfluencer activity, and outlines practical steps firms can take to stay on the right side of regulation while ensuring they can meet audiences where they are.
The term finfluencer is widely used in media and industry discussions, yet it rarely appears in legislation.
Regulators generally prefer to describe the activity associated with the individuals as they relate to improper or illegal financial promotions, rather than formalizing the definition.
In the U.K., the Financial Conduct Authority (FCA) defines finfluencers as:
Social media personalities who promote financial products or share investment advice with followers without proper authorization.”
Securities and Exchange Commission (SEC) defines finfluencers as:
Individuals who by virtue of their popular or cultural status, have the ability to influence the financial decision-making of others through promotions or recommendations on social media.”
In Canada, The Canadian Investment Regulatory Organization (CIRO) and the Canadian Securities Administrators (CSA) describe finfluencers as:
An individual who creates online content—such as on social media platforms, blogs, or message boards—to offer advice, tips, and guidance on managing money, investing, and achieving financial goals.”
While these definitions remain broad, what really distinguishes finfluencers from traditional financial advisors or commentators is the scale and immediacy of their reach.
A single post, video, or livestream can influence a large number of people to act in real time, shaping how audiences perceive financial products, investment opportunities, and even market trends.
Regulators will assess the content produced by finfluencers to establish whether it may constitute financial or investment advice:
Does it promote a financial product or service?
Does it encourage investment or trading?
Is the finfluencer receiving compensation or incentivized to promote financial services?
Could audiences interpret the content as financial advice?
Depending on these answers, the content may fall within the scope of existing rules governing financial promotions, investment advice, advertising disclosures, or market conduct. The remit of all regulators includes protecting investors and upholding market integrity, and they will act accordingly should finfluencer content be seen to harm either.
SECSecurities and Exchange Commission
FINRAFinancial Industry Regulatory Authority
FCAFinancial Conduct Authority
CSACanadian Securities Administrators
CIROCanadian Investment Regulatory Organization
The key regulators in the U.S. whose regulations impact finfluencer activity include the Securities and Exchange Commission (SEC), and the Financial Industry Regulatory Authority (FINRA).
The Marketing Rule was updated in 2020 and finalized in November 2022. It consolidated and replaced the old Advertising Rule and the Cash Solicitation Rule into a single, principles-based framework built for digital marketing channels.
The SEC’s Marketing Rule intends to help protect investors by differentiating between advertisements and advice. It applies to registered investment advisors, and governs every sponsored post, testimonial, or referral program a firm may run via a finfluencer. However, compliance obligations fall to the firm, rather than the influencer.
The rule covers any direct or indirect communication by an advisor that promotes a firm’s services to prospective clients, which includes emails, SMS/text messages, podcasts, blogs, and social media communications. “Indirect” communication refers to content provided to third parties by the firm for distribution, which would include finfluencer activity.
All advertisements are also subject to seven principles-based prohibitions where ads must not:
Include untrue statements of material fact
Make misleading implications
Omit material facts
Include unsubstantiated claims
Reference specific past investment advice out of context
Present information in a misleading way
Include certain prohibited performance claims
The Marketing Rule also stipulates that Advisers must:
Retain advertisements, approvals, disclosures and supporting documentation for at least five years, consistent with applicable books-and-records requirements
Document performance data, testimonials, endorsements, third-party ratings and any related compensation arrangements
Maintain records even for materials distributed to just two individuals
FINRA has very much been on the front foot when it comes to issuing messaging around finfluencer activity and pursuing enforcement actions against firms using finfluencer services non-compliantly. Finfluencers and the firms employing them are governed by a range of FINRA rules, including:
FINRA Rule (2210)(d)(1)(A) which requires all member firms’ communications to be based on principles of fair dealing and good faith, be fair and balanced, and provide a sound basis for evaluating the facts regarding any particular security, industry, or service. It also prohibits firms from making omissions within communications that would cause them to be misleading.
FINRA Rule 2210(d)(1)(B) states that no member may make any false, exaggerated, unwarranted, promissory, or misleading statements or claims in any communication. In addition, no member may publish, circulate, or distribute any communication that the member knows or has reason to know contains any untrue statement of a material fact or is otherwise false or misleading.
FINRA Rule 2010 requires member firms to observe high standards of commercial honor and just and equitable principles of trade in the conduct of their business.
The regulatory framework governing finfluencer activity in the U.K. has been set out by the Financial Conduct Authority (FCA), and includes the Financial Services and Markets Act 2000 (FSMA). Where U.S. regulators have primarily pursued firms for noncompliance, the FCA has taken criminal action against individual finfluencers where they have fallen short.
Under Section 21 of FSMA, a person must not, in the course of business, communicate an invitation or inducement to engage in investment activity unless that communication is made by an FCA-authorized person or its content has been approved by one.
The FCA provides a clear warning that unauthorized persons who promote financial products or services subject to regulation without the approval of an FCA-authorized person may be committing a criminal offense, which can lead to two-year imprisonment or a large fine.
Published in March 2024, FG24/1 became the definitive document for finfluencer compliance in the U.K. Crucially, it does not create new obligations, but clarifies how existing rules apply across social channels, including memes, reels, and online streams promoting financial services.
The guidance reiterates that any form of communication, including through social media, can be considered a financial promotion if it includes invitation or encouragement to engage in investment activity. This can include private or invitation-only channels like Discord, posts on public platforms such as Reddit, and content by unauthorized finfluencers. Online culture around cryptocurrency has resulted in memes being seen as financial promotions, meaning firms and regulators are now considering a format widely used humorously as no laughing matter.
Influencers that share non-compliant financial promotions may find themselves in direct breach of Section 21, even if those promotions were approved by an authorized person.
Firms’ marketing activity is also governed by the FCA’s Consumer Duty, which requires that communications support consumers in making well-informed financial decisions. The Consumer Duty states that:
The FCA explicitly states:
Under the Consumer Duty (the Duty), financial promotions must support retail customer understanding and communicate information to retail customers in a way that equips them to make effective decisions.
We want firms to consider this Guidance alongside their obligations under the Duty to deliver good outcomes for retail customers.”
Unauthorised persons, such as influencers, who promote financial products or services that are subject to regulation without the approval of an FCA-authorised person may be committing a criminal offence.”
Canada’s approach to finfluencer regulation is built on applying existing securities laws rather than writing new rules. The Canadian Securities Administrators (CSA) and Canadian Investment Regulatory Organization (CIRO) published Joint Staff Notice 31-369 in December 2025, providing guidance on how Canadian securities law intersects with the increasing use of social media financial influencers.
The guidance was produced for both finfluencers and firms to ensure that “those creating content and posting about investing do so transparently, honestly, and legally,” and provides concrete examples of how “both registrants and finfluencers can understand and be compliant with the requirements.”
Firms are reminded that those that engage finfluencers may be subject to referral arrangements under CIRO rules and NI 31-103, and should:
Perform adequate due diligence on finfluencers prior to engaging their services
Establish written agreements, including referral agreements, and set out roles and responsibilities of each party
Take steps to ensure the influencer is sufficiently well informed to discuss the firm’s products or services in a way that is balanced, fair, and not misleading
Verify on an ongoing basis that claims or statements made by the finfluencer about the firm or products are fair, balanced, and substantiated, and take corrective action if not
It is expected that “high-quality disclosure practices” are adhered to across all communications, and should be consistent with the firm’s continuous disclosure record in line with securities laws obligations, as laid out in CSA Staff Notice 51-348.
In June 2025, as part of The Global Week of Action Against Unlawful Finfluencers, the Ontario Securities Commission (OSC) undertook a review of nine issuers and 87 finfluencers, finding a “spectrum in the quality and accuracy of information” shared and that:
Some had provided investment advice without appropriate registration
Several had provided misleading information, particularly in the crypto space
In collaboration with The Decision Lab, the OSC also explored the relationship between Canadian retail investors and the financial information they encounter on social media.
The survey found that:
Despite the growing regulatory scrutiny surrounding finfluencers, there is opportunity for financial institutions to work effectively with them, although these partnerships must be managed with care to meet regulatory expectations.
Effective, compliant use of influencers requires firms to consider the desired outcome they want the finfluencer activity to achieve, which solutions, policies, or processes they need to put in place to onboard finfluencers compliantly, and what education is needed of both staff and finfluencers to ensure regulatory requirements are understood and abided by.
Understand which regulations apply to finfluencers in the region your business is based in, and any that may apply if the influencer is based outside of that region or the campaign may reach audiences internationally.
Firms must thoroughly research the finfluencers they want to work with before partnering with them, including reviewing past content to ensure it was compliant with all relevant regulation and did not contain potentially misleading information.
Due diligence efforts here may extend to reviewing the finfluencer’s wider social media presence to ensure they have not posted any content that may damage the firm's reputation by association or does not align with a firm’s values
While marketing or social media teams will primarily manage finfluencer relationships and activities, it is essential that necessary teams be aware of and involved with influencer relationships, including compliance and legal teams.
Assessing finfluencer posts and communications for potential signs of noncompliance, whether that be keywords that signpost potentially misleading information or where content may be considered financial advice, will enable you to spot potential risk and act on it before it can become a regulatory or legal issue.
The OSC survey identified that the three most common social channels used to access finfluencer content were YouTube (34%), Reddit (22%), and Instagram (21%). Finfluencers use a wide range of channels to connect with their audience, including X, TikTok, and LinkedIn. By capturing and archiving content that finfluencers are posting on your behalf, whichever channel it is posted on, you ensure you are compliant with recordkeeping aspects of regulations including the SEC Marketing Rule.
Asking finfluencers which channels they intend to use at the onboarding stage is a vital first step here
Influencer campaigns must be treated as financial promotions or as potentially constituting financial advice. Compliance teams should be involved in reviewing campaign objectives and messaging from the outset so that campaigns are compliant by default, before content is created or circulated.
Many influencers are unfamiliar with the rules around financial promotions, which can result in them being held criminally accountable and your firm becoming noncompliant. Filling them in on your firm, the products and services you offer, and how to advertise these compliantly and without being misleading is essential.
This step also includes internal education of staff and teams of the regulatory requirements governing finfluencer activity and sharing any pertinent examples of where regulators have stepped in as a “cautionary tale.”
