by Jude Ayua
Google LLC has notified advertisers it would update its “Cryptocurrencies and related products policy” in January 2025. Specifically for the United Kingdom, Google said beginning 15 January, it would require advertisers offering crypto-related products and services targeting the UK to register with the country’s Financial Conduct Authority (FCA) and be certified by Google.
The registration requirement applies specifically to ads promoting cryptocurrency exchanges and cryptocurrency (software) wallets. Additionally, ads promoting hardware wallets holding “private keys of cryptocurrencies, NFTs or other crypto-based assets,” must not offer other services like “purchasing, selling, exchanging or trading assets.” Google also stated that advertisers must comply with any other local legal requirements.
FCA’s position on crypto assets promotions
In November 2023, the FCA released a policy statement, “Guidance on Cryptoasset Financial Promotions” with a focus on “…reducing consumer harm and … helping to support better compliance with the relevant rules and deliver better overall consumer outcomes” in the UK.
The Guidance is applicable to “authorised persons communicating or approving financial promotions relating to qualifying cryptoassets [and] MLR (Money Laundering Regulations) registered persons communicating financial promotions…” It defines a financial promotion as “an invitation or inducement to engage in investment activity” which can take many forms, including adverts in print, broadcast or online media, marketing brochures, emails, websites, apps or social media posts. It provides that “financial promotions must be fair, clear, and not misleading.”
Read also: UK proposes prohibition of public offering of crypto assets.
The FCA’s overall aim is “to support long-term economic growth in the UK by reducing … loss of trust in financial services caused by customers not fully understanding the risk when purchasing cryptoassets.” The FCA believes “clearer and fairer promotions will enable consumers to be better informed to make appropriate decisions aligned with their needs and risk profile.”
Google’s decision to update its policies in January 2025 to align with the FCA’s requirement shows its commitment to regulatory compliance. Allowing only FCA-registered entities to advertise will ensure crypto users’ protection against fraudulent or unregulated services.
What the policy means for UK crypto users and promoters
Google’s recent move will reinforce the legitimacy of crypto-related offerings in the UK. As advertisers must meet Google’s certification and FCA registration requirements, it will promote greater transparency and compliance. It will also limit access to UK users to more reputable crypto assets service providers.
On the other hand, while the policy aims to protect users, it poses difficulties to smaller entities to reach a broader customer base. It could also raise advertising costs and compliance barriers for these entities, and limit user awareness of emerging, innovative platforms.
Smaller or newer crypto businesses that cannot meet Google’s certification requirements may struggle to advertise, reducing the visibility of their products and services to the UK market. Established and well-resourced firms that meet these requirements will have a competitive edge, dominate the market, reduce competition, and limit consumers’ choices.
Other jurisdictions
Google’s policy also applies to various jurisdictions. In its notice, Google emphasized, “As a reminder, we expect all advertisers to comply with the local laws for any area that their ads target. This policy will apply globally to all accounts that advertise these financial products.”
Google’s advertising policy states that it must certify advertisers who wish to push ads for restricted financial products including cryptocurrency exchanges, software wallets, and hardware wallets that hold the private keys for cryptocurrencies, NFTs or other crypto based assets. Google provides a list of countries in different regions and the scope of ads it allows in compliance with local licensing requirements.
In Asia-Pacific, advertisers of crypto-related services and products on Google require licensing from designated authorities in the following countries: Hong Kong, Indonesia, Japan, Philippines, South Korea, and Thailand.
In North and South America, the requirement is applicable to Canada and the United States.
In Europe, Africa, and the Middle East, the countries advertisers require licensing for Google crypto-related ads are Bahrain, France, Finland, Germany, Israel, Kenya, Russia, South Africa, Switzerland, and the United Arab Emirates. Note that Google will add the UK in January 2025 based on this notice.
Although Nigeria is not on the list, the Nigerian Securities and Exchange Commission (SEC) recently proposed an amendment to its Rules on Digital Assets to include advertisement of digital assets. All advertisements, marketing, or promotions about digital asset products will require the SEC’s prior approval. They must be accurate and not exaggerate or promise rapid returns. Third-party advertisers such as social media influencers must obtain prior authorization from the SEC before promoting digital assets. They must also verify that the entities they promote have a SEC virtual assets service providers license. Perhaps, the Nigerian SEC’s rules will become applicable to crypto-related Google ads targeting Nigerians in June 2025 after it passes the amendments.
Read also: UK trader charged for operating illegal crypto ATM.
Jude Ayua is a policy analyst at CAB. A lawyer, Jude is an associate at Infusion Lawyers where he is a member of the Blockchain & Virtual Assets Group. He is also a member of the Policy & Regulations Committee of the Stakeholders in Blockchain Technology Association of Nigeria (SiBAN). Jude reports and writes on crypto policy and regulations. jude@infusionlawyers.com
