A few months ago we saw the FCA take its financial promotions game to the next level.  And we wondered whether the FCA would be able to keep it up.

Well, they are.

It's not just the number of financial promotions they're reviewing - though that's certainly increasing impressively.

Or even the number of FCA cases resulting in firms withdrawing or amending a promotion - which has recovered from 2022 H1 doldrums, led by cases in the retail banking space.

All that is eclipsed by the number of financial promotions actually amended or withdrawn as a result of FCA engagement.

Which translates to massively increased efficiency: for each FCA financial promotions case, the number of financial promotions amended or withdrawn has skyrocketed.

Which all but confirms our suspicions that the FCA is ramping up its spot-checks of promotions at the same time as it uses Dear CEO letters alongside engagement with single larger firms to obtain mass amendments or withdrawals.

The kicker?  Whilst the FCA is making loud noises about online harms, website and social media promotions are actually trending down as a percentage of all promotions amended or withdrawn, over the last two years (the increase in the last few quarters has been anaemic at best).

So don't just think that online is where the interventions are at.  When it comes to your compliance efforts, your more traditional promotions matter just as much.