UK: Section 21.
Three lawful gateways: be FCA-authorised, have an authorised approver approve the content, or fit a Financial Promotion Order exemption. Reach into the UK decides — see the FCA’s February 2026 HTX action. The three gateways →
Approval, advice and review are three different things — only one makes a UK promotion lawful.
Three products get sold as “sign-off”. NorthPoint sells the third — review — and is included here, disclosed.
| Approval | Advice | Review | |
|---|---|---|---|
| Who performs it | An FCA-authorised firm holding the approver permission | A law firm or qualified counsel | An in-house team, or an operator such as NorthPoint (us) |
| What you get | A lawful route for a specific UK promotion, marker visible on the asset | A reasoned, possibly privileged opinion on your facts | A per-rule verdict, the triggered line quoted back, a rewrite |
| Speed | Regulated process | Partner hours | Campaign speed |
| What it is not | Not a compliance guarantee; not valid outside the approver’s own asset-class permission | Not approval; it does not make a promotion lawful | Not approval and not legal advice. Information only |
Three lawful gateways: be FCA-authorised, have an authorised approver approve the content, or fit a Financial Promotion Order exemption. Reach into the UK decides — see the FCA’s February 2026 HTX action. The three gateways →
No approval gateway. Responsibility stays with the offeror or authorised CASP; fines for the most serious infringements run to €15 million or 12.5% of annual turnover (Article 111). The penalty range →
Review, not approval: finished assets against published MiCA, FCA and GDPR rule packs — “checked”, never “compliant”. Useful upstream of both, a substitute for neither. Free checks →
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