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Part 4 - Best Practice Guide to Managing Compliance of New Financial Promotion Materials
- Dave Moore
- May 28
- 7 min read
Updated: Jun 6
This Guide is part of our Best Practice Guide to Managing Compliance of New Financial Promotion Materials.
If you have not already done so, we recommend that you first read the Introduction Section of this Guide. That explains the purpose of the Guide covers and how to use it.
Purpose of the Approval Activity
The business purpose of the Approval activity is to … obtain Compliance’s approval for the content that has been created so that it can be released for publication / distribution.
Compliance are normally responsible for this activity
In some organisations, Compliance have agreed to delegate approval of some content types to Marketing
Compliance Related Objectives
The main content compliance related objectives for this activity are:
Ensure that only content that is fully compliant, is approved
Ensure that across the organisation, that a consistent and standardised set of compliance requirements and checks are used when assessing if content is compliant or not
Minimise the amount of time and effort that needs to be spent on reviewing and approving the content
Ensure that in situations where content fails the approval process, that:
The reasons are clear and recorded
Content creators can easily understand what changes or updates they need to make
Minimise the elapsed time needed to complete the approval process
Best Practice – Key Elements and Potential Solutions
This section lists the key elements of best practice for this activity and shows for each element:
Which level of best practice they are part of – Standard or Advanced
The solutions that are likely to enable the best practice element to be achieved. (More information about these solutions, can be found in this guide - 7 Solutions That Help Achieve Best Practice)
No. 1 - Checked Before Submission
For the content to have been thoroughly checked against all compliance requirements by the content creator, before it is sent for approval
Level:
Standard
Advanced
Potential solution(s):
Compliance Checking System
No. 2 - The Right Approver
It is easy for the content creator to identify the correct approver or approval team to send their content to
Level:
Standard
Potential solution(s):
Operating Model
No. 3 - Submission Process
It is easy for the content creator to send their content to the correct approver or approval team
Level:
Standard
Potential solution(s):
Work Management System
No. 4 - Submission Process (Automated)
For the content to be automatically routed to the correct approver or approval team
Level:
Advanced
Potential solution(s):
Work Management System
No. 5 - Version Control
The version of the content sent to the approver is recorded
Level:
Standard
Potential solution(s):
Work Management System
No. 6 - Version Control (Automated)
The version of the content sent to the approver is automatically recorded
Level:
Advanced
Potential solution(s):
Work Management System
No. 7 - SLA Management
The date and time that content was sent to the approver is recorded
Level:
Standard
Potential solution(s):
Operating Model
Work Management System
No. 8 - SLA Management (Automated)
The date and time that content was sent to the approver is automatically recorded
Level:
Advanced
Potential solution(s):
Operating Model
Work Management System
No. 9 - Locking Content
Any content that is in the process of being reviewed is locked and not able to be edited / updated
Level:
Standard
Advanced
Potential solution(s):
Digital Asset Management System
Content Creation & Management System
No. 10 - Compliance Rules
There is a centralised (and wherever possible, standardised) set of compliance guidance, rules and wording which:
Is approved and managed by Compliance
Is agreed with and understood by Marketing
Can be applied to any type or format of content
Is used across the organisation in a consistent way
Level:
Standard
Advanced
Potential solution(s):
Standardised Compliance Guidance, Rules & Wording
No. 11 - Content Specific Compliance Requirements
Content approvers are able to easily identify and understand what all of the compliance requirements are, for the specific content item that they are assessing
Level:
Standard
Advanced
Potential solution(s):
Compliance Briefing
No. 12 - Checking If Content Meets Requirements
Content approvers are able to quickly and easily check if the content meets the compliance requirements
Level:
Standard
Potential solution(s):
Compliance Briefing
No. 13 - Checking If Content Meets Wording Requirements (Automated)
Content approvers are able to automatically check if the content meets the compliance requirements regarding wording to be included
Level:
Advanced
Potential solution(s):
Compliance Checking System
No. 14 - Checking If Content Meets Non-Wording Requirements (Automated)
Content approvers are able to automatically check if the content meets the compliance requirements regarding all other (non wording related) requirements
Level:
Advanced
Potential solution(s):
Compliance Checking System
No. 15 - Failure Reason (Automated)
Where an automated check has been carried out and that check shows that a requirement was not met, for the content approver to be automatically provided with the reason / rationale
Level:
Advanced
Potential solution(s):
Compliance Checking System
No. 16 - Failure Feedback
Content approvers are able to quickly and easily "mark up" the content to highlight to the content creator, any areas of the content that do not meet the regulatory compliance requirements … and to explain what needs to be added or changed in order to be compliant
Level:
Standard
Advanced
Potential solution(s):
Compliance Checking System
Content Creation & Management System (?)
No. 17 - Recording Outcomes
Content approvers are able to quickly and easily record the results of their assessment
Level:
Standard
Advanced
Potential solution(s):
Compliance Checking System
Work Management System
No. 18 - Recording Failure Reasons
Content approvers are able to quickly and easily record the reasons why any content has failed the approval process and what corrective action is required
Level:
Standard
Advanced
Potential solution(s):
Compliance Checking System
Work Management System
No. 19 - SLA Management - Approval Completion
The date, time and outcome of all assessments are recorded
Level:
Standard
Potential solution(s):
Operating Model
Work Management System
Digital Asset Management System
No. 20 - SLA Management - Approval Completion (Automated)
The date, time and outcome of all assessments are automatically recorded
Level:
Advanced
Potential solution(s):
Operating Model
Work Management System
Digital Asset Management System
No. 21 - Informing Creators
Content approvers can quickly and easily provide the results of their assessment to content creators
Level:
Standard
Advanced
Potential solution(s):
Work Management System
Compliance Checking System
No. 22 - Understanding Failure Reasons
Where content has failed to be approved, content creators are able to easily identify and understand any updates they need to make to their content
Level:
Standard
Advanced
Potential solution(s):
Content Creation & Management System
Compliance Checking System
No. 23 - Checking Updated Content
Where content has failed to be approved and has subsequently been updated, for the content approver to be able to easily see what updates have been made
Level:
Standard
Advanced
Potential solution(s):
Content Creation & Management System (?)
No. 24 - Recording of Approved Content
Where content has passed the approval process:
An approval ID is allocated and saved as part of the approval record
An expiry date is allocated and saved as part of the approval record
The content is marked as final and not able to be edited
Level:
Standard
Potential solution(s):
Digital Asset Management System
No. 25 - Recording of Approved Content (Automated)
Where content has passed the approval process:
An approval ID is automatically allocated and saved as part of the approval record
An expiry date is automatically allocated and saved as part of the approval record
The content is automatically marked as final and not able to be edited
Level:
Advanced
Potential solution(s):
Work Management System
Digital Asset Management System
We will be happy to email you a full version of this Guide (in PDF format)
Benefits of Achieving Best Practice
Overall, achieving content compliance best practice for the Approval activity is likely to:
Ensure that content is sent to the correct approver
Reduce the amount of time that approvers spend on:
Identifying / understanding what the compliance requirements are for any specific content
Checking if content meets the compliance requirements
Providing feedback to the content creator
Ensure that compliance checks are consistent across the whole organisation
Reduce the overall elapsed time to complete the approval process
Minimise the risk that non-compliant content will be approved in error
Provide the organisation with a complete and robust audit trail
The tables below, give a high-level view of the type and scale of benefits that can be typically realised by achieving a best practice position.
Note. The scale of benefits to be achieved, will depend on:
How far the current way of working is from the best practice way of working
Which level of best practice is achieved – Standard or Advanced
Standard Level
Advanced Level
Do You Have Best Practice?
The following are common indicators that best practice is NOT in place:
Compliance rules and compliance wording are managed via one or more Excel worksheets
Compliance rules are interpreted / applied differently across the organisation
Content creators often do not understand or accept the reasons for their content failing the approval process
Checking if content meets the compliance requirements, takes more than:
15 minutes for multi-page content
8 minutes for half or single page content
There are no SLAs in place regarding content approval
Content for approval is often marked as “urgent” and approvers are often placed under a lot of pressure to complete their reviews and / or to “be more flexible”
If your organisation has any of the above, then it is likely that you are not operating to best practice.
We can help you to:
Define what best practice is appropriate for your organisation
Identify and quantify the benefits that will be realised by achieving best practice
Identify the solution(s) that will enable you to achieve that best practice
Build the business case for any investment that is needed
You may also be interested in our services shown below. These were both designed to help with the activity of content approval.
If you would like to find out more about how we can help ...
Other Activities
Click on the buttons below to view our best practice guides for the other activities involved in the creation of new financial promotion content.
Disclaimer
The information is this guide represents Athena's views based on our experience and also based on input that we have received from a range of different people involved in both creating and approving financial promotion material.
We welcome any thoughts or suggestions regarding:
What "best practice" is or isn't
How best to achieve "best practice"
Anything that you would like to be included in the guide
Copyright Athena Know-How Ltd 2025
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