A broker discovers a comparison site ranking it first, with a table of figures nobody at the firm supplied, a bonus offer the firm does not run, and a country list that includes two markets where it holds no permission. The affiliate is being paid per acquisition and has never spoken to anyone in compliance. That situation is common, and it is a supervisory problem long before it is a marketing one.
What a network actually checks
Serious networks run a two-sided vetting process. On the advertiser side the process looks like know your business: incorporation documents, ownership and control, identification of directors and beneficial owners, the regulatory permission the firm relies on, the markets it may accept clients from, and screening against sanctions and adverse media. The reason is not politeness. A network that pays commissions to and from a firm involved in unlicensed solicitation or sanctions exposure has its own banking and its own liability to worry about, and those checks are the same family as the ones described in AML basics for trading firms.
On the publisher side the checks are about traffic quality and content. Where does the traffic come from, is it incentivised, is it branded search on the advertiser's own trademark, are the landing pages the network's or the publisher's, and what claims do those pages make. Networks that skip this end up with advertisers demanding clawbacks and publishers demanding payment on the same conversions.
Where the introducing broker line sits
The part founders most often miss is that in several jurisdictions, introducing clients to a financial services firm for reward is itself a regulated activity. Depending on the market, an introducer may need its own registration, may be permitted to operate only as a tied agent of an authorised firm, or may be restricted from communicating anything beyond the firm's own approved material. The mechanism differs by country and the classification depends on precisely what the introducer does, so this is a question for local counsel rather than for a partnership manager.
The practical consequence is consistent even where the rules differ. A firm authorised in a strict market cannot outsource its financial promotion rules by paying someone else to break them. If the affiliate's page promotes your product to retail clients in a market with an approval regime, that promotion generally has to be approved by an authorised person, and the responsibility sits with the firm. This is the same principle running through CFD marketing restrictions.
Affiliate arrangements are regulated differently in each market, and whether an introducer needs its own registration depends on facts this article cannot assess. Nothing here is legal advice. Take advice from counsel in every market your partners send traffic from.
The commercial checks that stop the bleeding
Beyond the regulatory layer there is a straightforward fraud layer, and trading affiliate programmes attract it. The recurring patterns are self-referral through friends and family accounts, incentivised sign-ups where the user is paid to register, traffic bought on the advertiser's own brand term so the affiliate is paid for demand the firm created, cookie stuffing, and volume that converts to deposits and then to chargebacks. That last one is the expensive version, because the firm pays the commission and then loses the deposit and a dispute fee, a dynamic covered in chargebacks explained.
The controls that work are dull and contractual. A clawback window long enough to catch reversal patterns rather than a payout on registration. Commission paid on funded, verified and retained accounts rather than on clicks or leads. A brand bidding ban written down and monitored. Pre-approved creative held in one place, with a rule that partners may use it and nothing else. A named country list in the contract, restricted to markets the firm may accept clients from. And a termination clause that does not require sixty days of notice while the traffic keeps arriving.
Monitoring is the part that gets skipped
Contracts are worth nothing without someone looking. The minimum viable monitoring is a monthly crawl of partner landing pages, a search for the brand name to see who is bidding on it and what they claim, a review of conversion quality per partner, and a check of where registrations are geolocating relative to the agreed country list. Firms that run partner networks at scale build a partner record showing the entity, the KYB evidence, the approved markets, the creative set and the review history. Some of that lives naturally in a broker back office; our Broker CRM keeps partner and client records in the same place so the review is not spread across spreadsheets.
Prop firms carry a variant of the same problem. Their affiliates are often creators promoting evaluation products, and the copy tends to drift toward income framing because that converts. As prop firm regulation develops, the gap between what a partner says and what the firm actually sells is the exposure that matters. The answer is the same as everywhere else in this article: approve the words, name the markets, watch the output, and be willing to cut a partner that earns well and writes badly.
"Every affiliate page is a page you published, as far as a regulator is concerned. If you would not sign off on it in-house, do not pay for it."
— Alex Onta, Executive Director, SINGUARD
Key Takeaways
- Networks run know your business checks on advertisers and traffic quality checks on publishers, because both sides affect their own banking and liability.
- In several markets, introducing clients for reward is itself regulated, and an authorised firm cannot outsource its promotion rules by paying someone else.
- Pay on funded and retained accounts with a real clawback window, since commission plus chargeback is the expensive failure mode.
- Contracts without monthly monitoring of partner pages, brand bidding and traffic geography are decoration.
Frequently Asked Questions
Does an affiliate promoting a broker need its own registration?
It depends on the market and on what the affiliate actually does. Some jurisdictions treat introducing clients for reward as a regulated activity requiring registration or tied agent status, others focus on the promotion itself and place responsibility on the authorised firm. Take local legal advice on the specific arrangement.
Who is responsible when an affiliate page makes a claim the firm never approved?
In markets with a financial promotion regime, the authorised firm is generally responsible for promotions of its products, whoever wrote them. Paying a third party does not transfer that duty, which is why pre-approved creative, a written country list and a fast termination right are the controls that matter.
What is the most common way affiliate programmes lose money?
Commission paid on volume that reverses. Self-referrals, incentivised registrations and traffic that deposits and then disputes leave the firm paying the partner while losing the deposit and a dispute fee. Paying on funded and retained accounts with a clawback window closes most of it.
About the Author
Alex Onta is an Executive Director at SINGUARD. He built eTrader, the terminal, the mobile apps, eTrader Broker, Copytrading, Business and Community, along with the worldwide clustered-server infrastructure it all runs on, with his brother Roman Onta helping on the design, and he leads that division today. Together with Roman he builds the Prop Firm CRM, the Broker CRM, Scalegram and CopySignals, and the two of them carry worldwide compliance, payment processing and international business structuring side by side. He lives and works in Dubai for most of the year. Meet the executive duo leading Singuard's five divisions.