DubaiCryptoGuy is a fictional social media influencer based out of Dubai with a significant online following. The influencer has recently entered into a paid partnership with ABC VASP to promote its services.
 

Figure (12): Fictional social media profile of influencer based out of Dubai
 

COMPLIANT: Reference to certain posts being sponsored (but note each sponsored post should also be clearly labelled as explained further below).
 

In Figure (12), the influencer’s social media bio contains a statement that the profile may contain sponsored posts. This is an example if good practice for the home page of a profile however, as explained further below, it is not sufficient to qualify as a clear and prominent indication of which posts are sponsored by ABC VASP.
 

In order to comply with Marketing Regulation I.C.2.k, the influencer should also include a clear statement in the caption of each post sponsored by ABC VASP that those posts are made as part of a remunerated arrangement with ABC VASP.
 

As the posts sponsored by ABC VASP are likely to relate to VA Activities conducted by ABC VASP, DubaiCryptoGuy must ensure that all sponsored Marketing is conducted on behalf of, and approved by, ABC VASP. It is the influencer’s responsibility to confirm with ABC VASP that it is Licensed by VARA to carry out the VA Activity(ies) to which the Marketing relate.
 

Below are further examples of non-compliant sponsored posts on social media: 
 

NOT COMPLIANT: Indication of sponsored post not clear and prominent (hidden in lower right corner of image).
 

Figure (13) shows a sponsored social media post which does not include a clear and prominent indication of a sponsorship. While the image contains the wording, “Sponsored by ABC VASP”, in the bottom right corner, this statement is not clearly visible or easy to spot against the background of the image.
 

Figure (14): Sponsored social media post by influencer based out of Dubai
 

NOT COMPLIANT: #spon is not a clear and prominent indication that this post is sponsored.
 

Figure (14) shows a sponsored social media post which is not clearly identifiable as paid or sponsored content. Although the caption includes a hashtag stating the name of ABC VASP (“#ABC-VASP”), it does not contain any wording that clearly indicate that the post is sponsored by ABC VASP.
 

In particular, the hashtag “#spon” (intended to be short for “#sponsored”) in the caption of the post is not sufficient to clearly identify the post is sponsored or paid content.