











Investment Promotions with an Overseas Element
Length: 9 Pages
Applies to: Investment Firms
Fully Customisable COBS 4.9 Guide – Financial Promotions with an Overseas Element
Get a fully editable COBS 4.9 – Promotions with an Overseas Element Guide, tailored to help investment firms navigate the complexities of cross-border communications under the FCA Handbook and the Financial Services and Markets Act 2000 (FSMA). This guide explains the key rules and exemptions that apply when UK-based firms create, approve, or distribute financial promotions that are targeted at clients outside the UK—or where elements of the promotion originate overseas.
The guide covers core concepts such as the “directing” of promotions to the UK public, the territorial scope of COBS, and how Section 21 FSMA and FPO exemptions (e.g. Article 12, Article 28) impact firms’ marketing activity across borders. It helps firms understand when they are subject to UK rules versus when overseas regimes may apply, especially in relation to EEA jurisdictions, third countries, and reverse solicitation.
Detailed scenarios and checklists are included to support compliance teams in assessing risk, documenting rationale, and implementing controls. Topics covered include dual-regulated product marketing, MiFID vs non-MiFID implications, passporting discontinuation, and how to frame disclaimers appropriately for international audiences. The guide also helps firms build workflows that align with both UK and local rules when distributing digital content globally.
The document supports the development of cross-border governance protocols, providing tools for reviewing marketing material, maintaining approval logs, and escalating higher-risk or high-profile campaigns. It integrates these practices with wider compliance frameworks under SYSC, GEN, and the Consumer Duty, helping firms demonstrate robust oversight and fairness in all outbound communications.
This Microsoft Word guide is instantly downloadable and fully editable. It is ideal for investment firms, DFMs, global compliance teams, legal advisers, and marketing leads. It saves time and enables firms to confidently manage cross-border financial promotions while meeting FCA expectations and maintaining compliance across multiple jurisdictions.
Length: 9 Pages
Applies to: Investment Firms
Fully Customisable COBS 4.9 Guide – Financial Promotions with an Overseas Element
Get a fully editable COBS 4.9 – Promotions with an Overseas Element Guide, tailored to help investment firms navigate the complexities of cross-border communications under the FCA Handbook and the Financial Services and Markets Act 2000 (FSMA). This guide explains the key rules and exemptions that apply when UK-based firms create, approve, or distribute financial promotions that are targeted at clients outside the UK—or where elements of the promotion originate overseas.
The guide covers core concepts such as the “directing” of promotions to the UK public, the territorial scope of COBS, and how Section 21 FSMA and FPO exemptions (e.g. Article 12, Article 28) impact firms’ marketing activity across borders. It helps firms understand when they are subject to UK rules versus when overseas regimes may apply, especially in relation to EEA jurisdictions, third countries, and reverse solicitation.
Detailed scenarios and checklists are included to support compliance teams in assessing risk, documenting rationale, and implementing controls. Topics covered include dual-regulated product marketing, MiFID vs non-MiFID implications, passporting discontinuation, and how to frame disclaimers appropriately for international audiences. The guide also helps firms build workflows that align with both UK and local rules when distributing digital content globally.
The document supports the development of cross-border governance protocols, providing tools for reviewing marketing material, maintaining approval logs, and escalating higher-risk or high-profile campaigns. It integrates these practices with wider compliance frameworks under SYSC, GEN, and the Consumer Duty, helping firms demonstrate robust oversight and fairness in all outbound communications.
This Microsoft Word guide is instantly downloadable and fully editable. It is ideal for investment firms, DFMs, global compliance teams, legal advisers, and marketing leads. It saves time and enables firms to confidently manage cross-border financial promotions while meeting FCA expectations and maintaining compliance across multiple jurisdictions.
Length: 9 Pages
Applies to: Investment Firms
Fully Customisable COBS 4.9 Guide – Financial Promotions with an Overseas Element
Get a fully editable COBS 4.9 – Promotions with an Overseas Element Guide, tailored to help investment firms navigate the complexities of cross-border communications under the FCA Handbook and the Financial Services and Markets Act 2000 (FSMA). This guide explains the key rules and exemptions that apply when UK-based firms create, approve, or distribute financial promotions that are targeted at clients outside the UK—or where elements of the promotion originate overseas.
The guide covers core concepts such as the “directing” of promotions to the UK public, the territorial scope of COBS, and how Section 21 FSMA and FPO exemptions (e.g. Article 12, Article 28) impact firms’ marketing activity across borders. It helps firms understand when they are subject to UK rules versus when overseas regimes may apply, especially in relation to EEA jurisdictions, third countries, and reverse solicitation.
Detailed scenarios and checklists are included to support compliance teams in assessing risk, documenting rationale, and implementing controls. Topics covered include dual-regulated product marketing, MiFID vs non-MiFID implications, passporting discontinuation, and how to frame disclaimers appropriately for international audiences. The guide also helps firms build workflows that align with both UK and local rules when distributing digital content globally.
The document supports the development of cross-border governance protocols, providing tools for reviewing marketing material, maintaining approval logs, and escalating higher-risk or high-profile campaigns. It integrates these practices with wider compliance frameworks under SYSC, GEN, and the Consumer Duty, helping firms demonstrate robust oversight and fairness in all outbound communications.
This Microsoft Word guide is instantly downloadable and fully editable. It is ideal for investment firms, DFMs, global compliance teams, legal advisers, and marketing leads. It saves time and enables firms to confidently manage cross-border financial promotions while meeting FCA expectations and maintaining compliance across multiple jurisdictions.