1. actor clarity
Is it clear who is behind the offer?
☐ Legal entity clearly named
☐ Responsible persons identifiable
☐ Roles (platform, intermediary, provider) clearly separated
☐ Use of anonymous or diffuse structures
Classification: Unclear actor structures make any well-founded classification of interests difficult.
2. business model & monetization
Is it clear how the provider earns money?
☐ Fees transparently disclosed
☐ Commissions disclosed
☐ Performance-based remuneration clearly explained
☐ Monetization only implicit or hidden
Classification: If you don't understand the business model, you can't evaluate incentives
3. Incentive structure
What is the economic benefit for the provider?
☐ Long-term user success
☐ Activity / trading frequency
☐ Subscriptions / signals / volume
☐ Unclear or contradictory
Classification: The more activity is rewarded, the greater the potential conflict with user interest.
4. Conflicts of interest Are potential conflicts of interest openly disclosed?
☐ Proprietary trading of the provider disclosed
☐ Participations / partnerships transparent
☐ Third-party commissions clearly marked
☐ No or only general information Classification: It is not the conflict that is problematic - but its invisibility.
5. Origin of results & representations
Is it clear where performance data comes from?
☐ Real money, demo, backtest clearly separated
☐ Time periods traceable
☐ Cancellations / restarts visible
☐ Results without context
Classification: Figures without origin are marketing, not information
6. Presentation of risks & losses
Are risks communicated realistically
☐ Drawdowns visible
☐ Loss phases explained
☐ Volatility named
☐ Focus almost exclusively on profits
Classification: Transparency is more evident in losses than in successes.
7. Role of influencers & third parties
Is it clear what role external actors play?
☐ Advertising clearly marked
☐ Remuneration disclosed
☐ Separation of opinion and marketing
☐ Emotionalized success narratives
Classification: Reach does not replace neutrality
8. Control & freedom of choice
How much control remains with the user?
☐ Clear intervention options
☐ Risks individually adjustable
☐ Automation optional
☐ Loss of control by design
Classification: Transparency also includes the question of who stops in case of doubt
9. Language & Tonality How is communication done?
☐ Factual, explanatory
☐ Differentiated
☐ Restrictions clearly named
☐ Simplifying, emotionalizing
Classification: The more emotionalized the communication, the more important critical distance is
10. Expectation management
How are results classified
☐ Marked as historical
☐ Marked as non-transferable
☐ Without promises of success
☐ Implicit assumptions of repetition
Classification: Transparency is shown by what is not promised.
1. affiliate model
Compensation per referral or completion
How does it work?
The finfluencer receives compensation when users use a personalized link to:
Payment is typically made:
Why is this attractive?
Easy to implement Scalable with reach Independent of users' actual trading success
Where is the conflict of interest?
The economic incentive lies before the actual use: Motivation for activation, not for suitability testing Success of the model does not depend on whether users benefit in the long term
Critical classification
Affiliate models reward persuasiveness, not quality of results. The more emotional and simplified the presentation, the higher the conversion
2. Commission model on current sales
Compensation dependent on activity or volume
How does it work?
The finfluencer receives:
As long as the referred user is actively trading, compensation flows.
Why is this attractive
Where is the conflict of interest?
A direct conflict of interest arises here:
Inactivity is often rational from a user perspective - but economically disadvantageous from a commission perspective.
Critical classification
This model favors: frequent action permanent market presence low inhibition thresholds Not because it delivers better results, but because activity itself is monetized.
3. "Order book share" / flow-based participation
Compensation via order flow or indirect market effects
How does it work? This model is less visible, but structurally relevant.
The finfluencer benefits indirectly when:
The remuneration is not always explicitly per user, but via:
Why is this attractive?
Where is the conflict of interest?
The user believes they are following a strategy or opinion. In fact, their order behavior is economically exploited without:
playing a role.
Critical classification
This model shifts the focus completely: from the outcome of the user to the usability of their behavior This mechanism is usually not recognizable to outsiders.
These constellations mentioned here in relation to the respective models are not illegal and not problematic per se
They become problematic when:
The user judges content according to its message -
the provider is remunerated according to its effect. This is the core of information asymmetry.
Rule of thumb: If remuneration is linked to activation, volume or order flow, every recommendation should also be read as a business model.
Conflict of interest is mitigated if the decision-making process of a prospective customer