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Procedure for UK Financial Services Advertisers to meet Google’s Verification Requirements

This articles looks at the procedure and process for UK financial services advertisers to meet Google’s verification requirements for financial services advertising. Financial services advertisers in the UK must meet Google verification requirements by August 2021.

Globally, Google has introduced advertiser identity verification. This requires the advertiser to provide personal, business and regulatory information, including details of their financial license to provide regulated financial services.

In the UK, this follows from February 2021 when Google wrote to the Financial Authority, outlining its plan to tackle scam ads for financial services. In this letter, Google confirmed an update to its Financial Service policy, requiring financial services advertisers to complete its business operations verification. Furthermore, Google confirmed that it planned on implementing a procedure to verify the identity of financial services advertisers, a process it called the Advertiser Identity Verification. It stated that this process would require such advertisers to submit personal legal identification, business incorporation documents or other information to prove the identity of such advertisers.

From August 2021, if your company wishes to show financial services adverts of any kind in the UK, including adverts to UK users who wish to seek financial services, you, the advertiser, must be verified by Google. As part of the verification procedure, you will be required to demonstrate that you are authorized and regulated with the UK’s financial regulator, namely the Financial Conduct Authority, or the FCA for short. Alternatively, you must qualify for one of the exemptions list below. This requirement covers financial services whether or not they are regulated services by the UK’s regulator - the Financial Conduct Authority.

Key definitions

FCA-authorized advertisers: this means financial services advertisers that are authorized by the UK’s Financial Conduct Authority (FCA) to provide financial services activities.

Approved third parties: these are advertisers whose ads are approved by an FCA-authorized firm. Examples would be agents or appointed representatives working under a principle firm.

Exempt non-financial service advertisers: these are advertisers that do not promote financial services but have a strong reason to target users on Google who appear to be seeking financial services. Examples of exempt non-financial service providers are search engines and e-commerce platforms.

Google’s Verification Requirements for FCA-authorized Firms:

To be eligible for the UK FCA verification, financial services advertisers promoting regulated financial services activities must be authorized by the UK’s financial services regulator, namely, the Financial Conduct Authority (FCA) and complete Google’s identity verification program.

Step 1: UK FCA Authorization

For the verification process, you will need to provide the following information to Google using its form:

- Google Ads account Customer ID

- Name of the Authorized Representative applying for verification

- Your business details (full name, address, email address)

- Your domain(s) or website(s) included in the UK Financial Conduct Authority register and any of your other domain(s) or website(s) used for advertising on Google Ads which are not included in the FCA’s register

- UK FCA registration number (FRN) for your regulated company

- Warranty that you will comply with any and all obligations that relate to the communication of, approval of, and restrictions on, financial promotions as per applicable regulatory and legal requirements.

It is important that the information you provide during the verification process matches exactly with the business details found on the FCA’s register of authorized firms. This includes, your FCA registration or authorisation number, name of your firm, contact details and your registration number.

Once you have successfully completed Google’s verification, a certificate will be applied to your Google Ads account. Google will notify you on the status and outcome of your verification application.

Step 2: Advertiser Identity verification

Step 2 of Google’s verification process is applicable to advertisers who have not completed Google’s advertiser identity verification process before.

You will be asked to submit identity verification documentation in addition to providing the UK FCA authorisation for your business. You will receive an email and an in-account notification that will guide you through the identity verification process in Google Ads. After Google has sent you the email, you will have 30 days to start the identity verification process. If you fail to do so within this time, your account will be paused.

You must ensure that the information you provide for the identity verification process matches with the business details you submitted in Step 1.

In order to complete the advertiser identity verification process, your application must be submitted by an Authorized Representative. The Authorized representative may be required to submit a form of personal ID. You can see the list of acceptable identity documents here.

After completing steps 1 and 2, you will be permitted to display financial services adverts in the UK, to UK users.


Verification requirements for approved third-parties

If you meet the definitions of an Approved Third Party (defined above) you will need an FCA regulated firms to initiate the verification process for you. This may be the case for agents or appointed representatives working under a principle firm.

Verification process for FCA-authorized firms

If you are an FCA regulated firm you can start the verification process using Google’s verification form.

You will be required to provide information including:

- Google Ads account ID

- Name of the Authorized representative applying for verification

- Your business details

- Domain names of third-party advertisers whose ads are approved by you

- Confirmation that you will approve any third-party financial promotions

Verification requirements for exempt non-financial services advertisers

If you meet the above definition, you can also apply for verification. If your verification application is successful, you will be approved to show adverts to UK users.

As part of the verification process, you will be required to provide information, including:

- Google Ads account ID

- Name of the Authorized representative applying for verification

- Your business details, including name, address and contact details

- Your domain names or website(s) used for Google Ads

- Confirmation that you will not use this exemption to run Google Ads promoting financial services

After you have completed the verification process, Google will send you an email confirmation along with a certificate to your Google Ad account, allowing you to publish adverts to UK users.

Important information regarding Google's policy

If you are found by Google to be promoting financial services after completing the verification process and you provided false or inaccurate information during the verification process, or you violated Google’s Financial Products and Services policy, your verification will be revoked and your account is likely to get suspended.

Similarly, Google may revoke your verification or take action depending upon your conduct e.g. receiving multiple customer complaints or receiving regulatory warnings from the FCA.

You will be required to renew your verification, periodically. Google will write to you when your renewal is required. Similarly, Google may also ask you to re-verify your ID.

Adverts relating to the following categories will not fall under the scope of Google’s policy concerning financial services. However, firms offering such services must still comply with all other Google Advert policies:

- Products in scope of Google’s Debt services policy

- Products in scope of Google’s Complex speculative financial products policy: contracts for difference, rolling spot forex, financial spread betting. Ads for this category will be able to target UK users seeking financial services as long as they meet the requirements of google’s Complex speculative financial products policy and complete verification, if requested by Google.

- Gambling: see Google’s gambling policy - Gambling and Games policy)

- Products in scope of Google’s Cryptocurrency, Credit repair, and Binary options policies

Penalty for violating Google's policy

If you are found to violate this policy, Google will issue you a warning, giving you 7 days before suspending your account.

How Buckingham Capital Consulting can help

Buckingham Capital Consulting is a leading international consulting firm, specialising in financial services licencing, compliance and consulting, in sectors including, payment services, cryptocurrency, electronic money, banking and investment services.

We can advise you on the best course of action and strategy based upon your business, both on advertising and verifying your business with Google and obtaining the relevant license(s) from the UK regulator- the Financial Conduct Authority, where and if required.

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