Choosing a fintech marketing agency: why compliance comes first
Hiring a fintech marketing agency is a compliance decision before it is a media one, because in Singapore the licensed firm's accountability for its agency's ads cannot be delegated.
The Monetary Authority of Singapore's Guidelines on Standards of Conduct for Digital Advertising Activities (FSG-03), in force since 25 March 2026, list "advertising agencies and advertising network providers" among a firm's external digital marketers. The board may delegate the work, "but their accountability cannot be delegated." The Guidelines apply to "all financial institutions and their digital marketers" (1.1) and are principles-based (1.4).
This guide is for marketing leads at payments, lending, wealth and insurtech firms (our fintech industry page covers the sector) who are hiring a paid media partner across Singapore, Malaysia, Australia, the US and Canada. Each rule binds only the institutions it names.
Our thesis: fourteen questions, each tied to a regulator or platform rule, sort a partner who can run financial ads from one who gets the account suspended.
What compliance questions should you ask a fintech marketing agency?
Ask the 14 questions below and accept only answers that arrive with a document attached.
A verbal "yes, we handle compliance" is worth nothing in a regulator's file.
| # | Question | Why it matters | Evidence to ask for | Rule behind it | Last verified |
|---|---|---|---|---|---|
| 1 | Do you check our licence in every target market before launch? | Platforms ask for authorisation per country | Licence-to-market sheet, dated | Google financial services verification; Meta financial ads policy | 27 Oct 2026 |
| 2 | Who checks creator and affiliate licence status? | MAS expects disclosure of influencer licence status | Creator vetting log | MAS FSG-03 Example 2.1(f); ASIC INFO 269 | 27 Oct 2026 |
| 3 | Does targeting stay inside our target market? | Credit and insurance ads must target adults | Audience settings export | Meta 18+ rule; ASIC INFO 269 (Australia) | 27 Oct 2026 |
| 4 | Where is the substantiation for each claim? | Outcome claims need evidence on file | Claims register with sources | ASIC RG 234.19 | 27 Oct 2026 |
| 5 | Does every ad and variant pass our sign-off before launch? | Unapproved additions can make the whole ad yours | Approval log with timestamps | MAS FSG-03 5.5, 5.8; BNM FTFC 12.2 | 27 Oct 2026 |
| 6 | How do warnings survive short formats? | Risks cannot live only on another page | Format-by-format disclosure plan | MAS FSG-03 5.4; BNM FTFC 12.5; ASIC RG 234.176 | 27 Oct 2026 |
| 7 | Whose name is on Google's financial verification? | Verification is per location | Verification status screenshot | Google Ads Help, financial services verification | 27 Oct 2026 |
| 8 | Who owns the ad accounts and payment profile? | Admins count as authorised representatives | Account ownership list | Google Ads Help, same page | 27 Oct 2026 |
| 9 | What happens if verification is revoked? | Google can suspend the account | Written disapproval playbook | Google Ads Help, same page | 27 Oct 2026 |
| 10 | What personal data do you hold, and when is it deleted? | In Singapore, their processing stays your obligation | Data processing clause, deletion proof | Singapore PDPA s4(3) (PDPC guidelines); other markets differ | 27 Oct 2026 |
| 11 | Do you keep a register of every ad that ran? | Complaints need the ad as shown | Ad register sample | MAS FSG-03 Example 4.1; ASIC RG 234.177 | 27 Oct 2026 |
| 12 | How fast can you pull a live ad or creator post? | MAS expects the ability to "promptly locate, modify or remove" ads | Takedown time in the contract | MAS FSG-03 5.2(c), a consideration | 27 Oct 2026 |
| 13 | Who on the team has run regulated financial accounts? | MAS lists sector track record as a criterion | Named team, prior sector work | MAS FSG-03 5.7 | 27 Oct 2026 |
| 14 | Will our rules sit in your contract? | MAS names formal agreements as one way | Draft clauses, no unapproved content | MAS FSG-03 5.8 (one way); FTC Endorsement Guides FAQ | 27 Oct 2026 |
MAS is behind seven of the 14 questions, because it is the one regulator here that writes down how to vet an agency. An agency that answers only the three Google account questions (7 to 9) is a media buyer.
Who should own Google and Meta financial verification?
The licensed firm should own its financial verification, because Google treats whoever administers the ad account, including an agency, as the authorised representative.
Google's financial services verification help page (Germany edition; check yours) puts it plainly: "An authorized representative is an admin of the Google Ads account or of the payments profile paying for the ads. This includes advertising agencies, subsidiaries, or other entities that manage the Google Ads account on your behalf." Verification is also per country: Google's list of regulators and enforcement dates covers 42 locations and requires "a separate verification needed for each targeted location".
The US and Canada are next. On 20 October 2026 Keerat Sharma, Google's VP and General Manager for Ads Privacy and Safety, wrote that Google is "bringing our Financial Services Verification program to the U.S. and Canada in early 2027". Our guide to Google's verification gate covers the mechanics.
Meta's financial and insurance ads policy asks advertisers to "verify their business and/or individual identity" and show they are authorised "where this is a requirement". Meta announced on 5 March 2025 that advertisers targeting Singapore must verify who pays for and benefits from their ads, phased in from April 2025.
Our decision rule, for any account that runs Google Ads or Meta for a licensed product:
- Ad accounts, Business Manager and the payments profile sit in the fintech's legal name.
- The agency gets user access, never ownership.
- If an agency insists on running spend through its own payments profile, decline. Google may treat its admin as your authorised representative, and Google says false information or a policy breach means verification "will be revoked with immediate effect and your account may be suspended".
Marketing financial products online: what each regulator expects of your partners
Regulators judge the ad as published, whoever made it, but of the five markets only Singapore's MAS spells out how a licensed firm should choose and supervise an advertising agency.
Our compliance guide has the full rules; this table keeps what changes the agency conversation, for fintechs and banks and wealth firms alike.
| Market | Ad conduct rule | Who it binds | What it says about partners | Google financial verification | Last verified |
|---|---|---|---|---|---|
| Singapore | MAS FSG-03, in force 25 March 2026 | MAS-regulated financial institutions and their digital marketers (1.1) | A framework to select digital marketers (5.7); monitoring (5.9) | Enforced since 30 August 2022 | 27 Oct 2026 |
| Malaysia | BNM Fair Treatment of Financial Consumers, PD 028-103, 27 March 2024 | A closed list of licensed institutions: banks, insurers, takaful operators, approved advisers and others | One line: "proper due diligence" before appointing representatives and agents to market (13.5). A media agency as "agent" is our reading | Enforced since 14 April 2026 | 27 Oct 2026 |
| Australia | ASIC RG 234, issued 9 June 2026 | Promoters of financial products and credit, including intermediaries and agents (234.3) | Advertiser holds "primary responsibility"; a publisher that contributes is "in the same position as the promoter" (234.186) | Enforced since 30 August 2022 | 27 Oct 2026 |
| United States | 12 U.S.C. 5536; FTC Endorsement Guides | Covered persons and service providers; advertisers (FTC) | Statute silent on agencies. FTC: "Your company is ultimately responsible for what others do on your behalf." | Not yet listed; announced for early 2027 | 27 Oct 2026 |
| Canada | Bank Act s. 627.03 | Banks and authorized foreign banks (s. 627.01) | Silent on agencies; no "false or misleading information" to customers or the public | Not yet listed; announced for early 2027 | 27 Oct 2026 |
Check your licence class in the "Who it binds" column before relying on a row. Only MAS gives a selection framework for agencies; the US and Canada rows are silent, so there the 14 questions rest on platform rules and your own supervision duty. In Australia an agency that places or contributes to an ad can carry responsibility of its own.
"Financial institutions should have a framework to assess and select appropriate digital marketers."
Monetary Authority of Singapore, Guidelines on Standards of Conduct for Digital Advertising Activities (FSG-03), paragraph 5.7, issued 25 September 2025. Read the guidelines.
Australia's RG 234, issued on 9 June 2026, says: "While the primary responsibility for advertising material rests with the organisation placing the advertisement, the publisher may also have some responsibility for the content of an advertisement" (234.183). It adds: "Promoters should keep a record of their advertising" (234.177), and consumer-outcome claims "must be able to be substantiated" (234.19).
On 12 May 2025 the CFPB withdrew its 2022 interpretive rule on digital marketing providers, which had treated marketers that help select prospective customers as typically service providers under the statute (withdrawn-guidance list). The statute did not move: 12 U.S.C. 5536 still bars any "covered person or service provider" from unfair, deceptive or abusive practices. Whether your agency counts as one now turns on the statute's own definition.
How does a compliant fintech campaign get approved?
Our six-gate flow takes a campaign from licence check to live monitoring, and the gate that decides the rest is your compliance sign-off on every ad and every platform variant.
The six gates and their order are Leapbuzz's method; MAS, BNM and ASIC source the individual rules only. The agency runs the media; the licensed firm owns the gates.
Gate 4 is the one automation strains most. Automated formats recombine your headlines, images and video, and MAS says firms "should not disclaim responsibility for segments of video advertisements" (5.5, about influencers' added content; applying it to automated recombination is our extension). A partner who cannot show which variants your compliance team saw is asking you to sign for ads nobody approved.
Made-up round numbers. A lender approves 8 headlines and 4 images; automated mixing can serve 32 combinations. If compliance never saw a combined render, the log covers the parts and none of the ads.
Our performance marketing work for regulated advertisers starts from the same rule: no ad runs before compliance has seen it.
Shortlisting agencies for paid media under MAS, ASIC or BNM rules and unsure which of them can document these 14 answers? Leapbuzz, an AI-native marketing consultancy based in Singapore and working across Singapore, Malaysia, Australia, the US and Canada, returns a partner audit: each question scored against each agency's evidence, with the gaps marked. Ask for the audit.
Agency compliance scorer: is this partner ready for a licensed fintech?
A partner is ready when the three gate questions are documented and at least 12 of 14 answers come with a document. Tick each documented answer and the scorer returns READY, GAPS or RISK. Leapbuzz sells performance marketing, so we are a candidate partner too: the same 14 questions apply to us.
Illustrative heuristic. Score = documented answers out of 14. Questions 1, 5 and 7 are gates: if any is unticked, the result is RISK. Mark 7 not applicable if the agency runs no ads where Google requires verification. Question 8 is not a gate, because ownership can move before launch. Otherwise 12 to 14 is READY, 8 to 11 GAPS, 7 or fewer RISK. READY means the paperwork exists, not that the campaign is compliant.
Not scored yet
Tick each question the agency backed with a document. The result appears here.
Do this today
Send the 14 questions to your current agency before any new pitch.
Score what comes back and fix the three gates first: licence check, sign-off on every variant, verification in your own name. Then move the ad accounts and payments profile into the fintech's legal name.
For the commercial side, see our guide to judging a fintech growth partner on CAC and LTV and our banking marketing partner guide.
This is marketing guidance, not legal advice. Have your compliance or legal team confirm how each rule applies to your licence.