When CFD brokers pay affiliate partners, who bears regulatory responsibility?

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The author argues that when CFD brokers pay to acquire clients, regulatory scrutiny may extend beyond the brokers to affiliates, review sites, content publishers, and influencers. The article compares the tied agent rules under MiFID II with the UAE’s restrictions on unlicensed client-referral activities, and notes that the relevant responsibility depends on the promoter’s actual conduct and the applicable jurisdiction.