Sturgeon Ventures have been responsible for the preparation, verification and approval of many  financial promotions. Our work involves helping clients to prepare a complete and successful financial promotion with regards to any asset class, funding vehicle or corporate finance transaction.

In addition, we can also assist clients when it comes to verification of the promotion before it is sent to potential investors.

What is a Financial Promotion?

The handbook that has been created by the FCA makes it clear that a financial promotion is: ‘An invitation or inducement to engage in investment activity that is communicated in the course of business’.

Simply put, if you need to send out a business plan, or any other promotion including an email campaign, to potential investors, then it is possible you are about to release a financial promotion. In other words, you are asking or inviting potential investors to engage in business.

The Rules for Financial Promotions Approval

If you are not authorised by the FCA and come under its regulation, you are viewed as ‘an unauthorised person’. Section 21 of FSMA covers unauthorised persons. This area is known as ‘the financial promotion restriction’. If you come under the unauthorised person area and contravene this restriction it is viewed as a criminal offence.

Any approach to a potential investor in the UK is governed by the FSMA. As regards raising equity finance from investors, this is an area that is full of regulation. Professional advice is absolutely necessary. This even covers business plans, which, when sent to a potential investor, constitute a ‘financial promotion’.

Financial Promotion Rules – UCIS

UCIS cannot be promoted to the general public. Section 21 of FSMA does not allow the promotion of UCIS by ‘unauthorised persons’. It will allow promotion if the promotion is approved by an authorised person or comes under an exemption in the financial promotion order.

Section 238 of FSMA then goes further by precluding promotion of UCIS by authorised persons, except where an exemption is available.

The Content of your Financial Promotion

The Conduct of Business Sourcebook, created by the FCA, states that an authorised firm must ensure that the promotion is clear, transparent, fair and not misleading.

The Sturgeon Ventures’ Team

Every single member of our team is an authorised person, and can assist with any compliance with FSMA and any other legislation. We have considerable experience with giving advice on FSMA and any other issues that centre on financial promotion. This means we can provide experienced guidance through all the processes and procedures. As authorised persons, we can also issue an approval for a financial promotion.

Your Next Step

If you require an authorised person to approve, verify, issue or approve your financial promotion, then please contact Sturgeon Ventures today. We can arrange a meeting to discuss any requirements you may have in more detail. We can also offer impartial advice, and help you make the right decisions when considering the issuance of a financial promotion.


External Links :

The Conduct of Business Sourcebook, created by the FCA –

Communicating with Clients including Financial Promotions (COBS 4) –


Other Services

Corporate Finance

Compliance Services

Sturgeon Academy