Building Binance’s UK Financial Promotions operating model

A new regulatory perimeter for crypto marketing

In 2023, crypto firms operating internationally were preparing for a significant change in how they could communicate with consumers in the UK. From 8 October, the UK Financial Promotions regime was extended to qualifying cryptoassets, bringing websites, mobile apps, social media, advertising and other customer-facing communications within a much more structured regulatory framework. The territorial scope was broad as well: overseas firms needed to consider communications capable of having an effect on UK consumers, even where those communications originated outside the UK.¹

The new rules affected more than advertising copy. They introduced requirements around prominent risk warnings, customer understanding and appropriateness, restrictions on incentives and, for first-time investors, a cooling-off period. Promotions also needed to meet the overarching standard of being clear, fair and not misleading.²

For Binance, the scale made implementation considerably more complicated. By the end of 2023, the platform reported approximately 170 million registered users, 431 tradable assets and 1,785 trading pairs globally.³ The customer experience extended across a large ecosystem of trading products, asset pages, mobile and web interfaces, educational content, automated communications, affiliates and marketing channels.

My role was to help turn those regulatory requirements into something that could actually operate across that ecosystem. I owned a significant part of the operational and marketing implementation, working across Compliance, Legal, Product, Engineering and other functions to translate the new requirements into customer journeys, access controls, operating procedures, approval processes and implementation logic.

Choosing the UK operating model

One of the first questions was how the UK experience itself should be structured. We considered several approaches, including creating a completely separate UK application and website, building a more independent local exchange using existing Binance infrastructure, or retaining the global platform while establishing a dedicated UK environment with additional controls.

The approach ultimately selected centred on Binance.com/en-GB. This allowed much of the existing global infrastructure to remain in place while providing a distinct environment through which the UK experience could be controlled. Contemporary reporting from October 2023 confirmed that UK retail users were redirected towards the dedicated /en-GB experience and that the available product set was adjusted for the UK market.⁴

The URL itself was only the visible part of the solution. Behind it, we needed a clear regulatory perimeter defining who should enter the UK environment, which products and content they could access, and how those rules should behave across different customer states.

Turning regulation into product logic

A customer's physical location was only one signal. A logged-out visitor arriving from a UK IP address presented one scenario. An authenticated customer registered in another jurisdiction who happened to be visiting the UK presented another. A UK KYC-verified customer accessing Binance while travelling overseas created another variation.

We therefore mapped the interaction between three core signals and translated those combinations into specific platform behaviour:

• IP location to understand where the user was accessing the platform.
• Authentication state to distinguish a visitor from a known customer.
• KYC jurisdiction to identify the jurisdiction associated with an authenticated account.

The implementation required detailed scenario mapping across different entry points and customer states. Working with Compliance and Legal, I helped convert regulatory interpretation into specific customer journeys and product requirements that Product and Engineering could implement consistently across web and app.

Mapping the UK customer journey

Once the access model was established, we needed to map what a UK customer could encounter throughout the wider Binance ecosystem. The review covered:

• landing and product pages
• asset information and trading journeys
• FAQs and educational content
• pricing and disclosure information
• promotional modules
• website and app interfaces
• CRM and automated lifecycle journeys
• in-app notifications
• affiliate and creator activity

The challenge was both scale and time. Binance had accumulated years of global product and marketing material, while the regulatory implementation date was fixed. Instead of treating every page as an isolated problem, we combined detailed content review with broader platform controls. Some experiences could remain available with amendments, others required localisation, while certain products, journeys or content needed to be restricted for UK users.

Across the programme, more than 500 UK-facing materials and customer touchpoints were reviewed, amended, restricted or brought within the control framework. This included areas that might previously have been considered part of the product experience rather than marketing.

Adapting the product experience

The implementation consequently extended into the product itself. We reviewed how product and asset information appeared to UK users, how pricing and disclosure information was presented, what content could remain accessible and whether certain global journeys needed to be adapted or restricted.

Consistency was critical. Removing a product from one landing page had limited value if the same customer could still discover or access it elsewhere in the application. Controls therefore needed to work across the customer journey and across both web and mobile.

This created a continuous dependency between regulatory interpretation and product implementation. A Compliance requirement could ultimately require a change to routing logic, an app component, an asset journey, a disclosure, a content module or the process governing future product changes.

Building the operating model behind the platform

Preparing the UK experience for 8 October was only part of the challenge. New products, campaigns and content would continue to be released after the implementation date, so the controls needed to operate as an ongoing system rather than a one-off remediation exercise.

I developed and helped implement the processes governing how UK-facing activity would subsequently be managed, including:

• standard operating procedures
• product and content review workflows
• ownership and escalation routes
• approval requirements
• documentation and evidence standards
• change-management controls
• processes for previously reviewed materials

Business and operational teams retained first-line ownership, with Legal and Compliance providing regulatory interpretation and challenge. Where required, materials also progressed through an external authorised approval process.

The design problem was balancing regulatory control with operational practicality. Binance remained a fast-moving global technology business, so the process needed to establish when something required a new review, how approved templates could be reused, what constituted a material change and how exceptions should be escalated without requiring every decision to start again from first principles.

Extending the framework into marketing

The same controls also had to apply beyond the core product. Binance communicated with customers through CRM, automated lifecycle journeys, in-app notifications, affiliates, creators, social platforms and campaign activity. Those channels needed to operate within the same UK framework as the product itself.

We therefore reviewed both existing marketing materials and the systems responsible for generating future communications. An automated email or in-app message could still create a regulatory requirement even though nobody was manually publishing it at that moment.

The marketing operating model consequently moved towards embedding regulatory review earlier in the process, with clearer ownership over what required review and how approved content could subsequently be used. The objective was to support ongoing business activity after launch rather than treat October as the end of the programme.

Coordinating delivery across the organisation

The programme involved more than eight core internal functions, including Product, Engineering, Legal, Compliance, Risk, Marketing, Operations and Customer Service, alongside external advisers and approval partners.

Each function approached the programme from a different perspective. Compliance and Legal interpreted the requirements, Product and Engineering needed executable specifications, Marketing needed workable processes for ongoing communications, Customer Service needed to understand the customer impact, and Risk needed visibility over the resulting controls.

My role frequently sat between these groups. I helped turn regulatory interpretation into operational decisions another team could execute, whether that meant defining a customer-routing scenario, documenting an approval workflow, changing a product journey or establishing how recurring marketing activity should be governed.

Delivering for 8 October

The programme ran over several months against a fixed regulatory deadline. By 8 October 2023, the work had established a dedicated UK digital experience, introduced access and routing controls, reviewed more than 500 customer-facing materials and touchpoints, adapted product and content journeys, and implemented the governance processes required to support the UK environment.

The resulting customer experience was the visible part of the programme. Behind it sat months of regulatory interpretation, journey mapping, product changes, content review, approval processes, cross-functional coordination and operational design.

The project remains one of the clearest examples from my career of regulatory go-to-market at scale. Regulation establishes the boundaries, but implementation comes down to the practical decisions a customer experiences: which page they see, what information is presented, which product they can access, what communication they receive and what happens when the platform changes again. My contribution centred on helping translate those requirements into an operating model that Product, Engineering, Marketing and Operations could execute.