If you thought the recent round of cryptocurrency advertising bans in the UK were tough, at least they targeted advertisements from individual companies, take a look at what happened in Spain and Singapore. today.

Read more: UK Regulator’s Ban on ‘Misleading’ Ads Stimulates Crypto Regulation Debate

Spain’s National Securities Market Commission has just established a pre-approval mandate for all cryptocurrency advertising aimed at 100,000 or more people and added mandatory disclaimer language in the vein of health warnings for advertisements on cigarettes.

Singapore has just banned it outright.

As cryptocurrencies gain mainstream awareness around the world, there has been a rising tide of concern that retail investors don’t understand how risky cryptocurrency can be. Even the largest and most well-known cryptocurrencies like bitcoin and ether are extremely volatile against stocks, rising and falling by 5% to 10% or more in a matter of hours on a regular basis.

And, the growing interest in decentralized finance adds a whole new dimension of risk thanks to the wide availability of highly leveraged futures and options markets, and the frequency with which borrowers from the DeFi lending platform are hit with margin calls who see their collateral sold as its price drops. Then there’s fraud, sweepstakes, nine- and ten-digit exchanges, and protocol hacks.

See also: PYMNTS DeFi Series: The Very Real Risks of DeFi

Singapore just say no

On Monday, January 17, the Monetary Authority of Singapore released a new set of “Guidelines on the Provision of Digital Payment Token Services to the Public.”

Referring to crypto exchanges and other licensed companies that provide cryptocurrency services as Digital Payment Token Providers, or DPTs, the MAS warned that advertisements should avoid featuring crypto trading “d ‘a way that trivializes the high risks of trading TPDs’ or suggests that it is suitable for the general public.

Specifically, this includes a ban on advertising their “services in public spaces in Singapore or through any other media aimed at the general public in Singapore”. Besides exchanges, this includes banks and financial institutions licensed to provide crypto services.

This includes “any form of advertisements or promotional materials in public areas such as Singapore public transport, public transportation venues, broadcast media or periodical publications, third party websites, social media platforms, public events or roadshows”.

Hiring or paying third parties such as social media influencers or websites to promote their services or crypto trading, in general, is also excluded.

Which leaves the websites and mobile apps of exchanges and service providers, as well as their own official social media channels.

In other words, sing only in choir.

Authorization required

On the same day, the Spanish National Commission for the Securities Market, the CNMV, published a circular on advertising investments in crypto.

It required “clear, balanced, fair and non-misleading risk content and information in a prominent manner,” in all crypto advertisements along with a disclaimer: “Investments in crypto-assets are unregulated. They may not be suitable for retail investors and the full amount invested may be lost.

The rules specifically exclude non-fungible token announcements (NFTs).

Beyond that, it establishes a procedure requiring any crypto advertising campaign targeting a mass audience of 100,000 or more to obtain pre-approval for advertisements. This includes advertisers themselves, advertising service providers and “any other natural or legal person who carries out such activity on its own initiative or on behalf of third parties”.

This specifically includes anyone paid to promote crypto assets, including social media and other influencers.

Additionally, any links in these advertisements must include language such as “It is important to read and understand the risks of this investment, which are explained in detail at this link”.

The CNMV noted that no new regulations on crypto assets had been established and provided a number of exemptions for cryptocurrencies and products “not used for investment purposes”.

Besides NFTs, this includes certain “utility tokens” — used to run a blockchain project rather than being offered as an investment — white papers, analyst and workshop presentations, “and blockchain ad campaigns. undertaking when they comply with certain requirements”.

It also does not apply to cryptocurrencies that “have the nature of financial instruments” because they are already subject to a separate set of rules.

Repression in the UK

The UK’s Advertising Standards Authority (ASA) has recently waged a crackdown on crypto ads, with the most recent target being ads from Crypto.com – an exchange based, ironically enough, in Singapore.

He banned two advertisements as “misleading”.

One involved an ad in the Daily mail the newspaper app that said, “Buy bitcoin with credit card instantly.” The other was in the mobile game Love Balls, offering interest rates “up to 8.5%” by staking crypto.

Both were deemed “irresponsible and took advantage of consumer inexperience or credulity”, and the latter’s interest rate claims “could not be substantiated”, the ASA found.

“We told them that future advertisements should make it clear that purchasing cryptocurrency using a credit card may be subject to higher interest rates, additional fees, and that some issuers credit card companies prohibit the purchase of cryptocurrency,” the ad agency said in a statement.

Other recent ad bans included one for the Arsenal Football Club fan token on December 22 and ads for Coinbase and Kraken exchanges on January 5.

And, of course, here in the United States, we have US Senator Elizabeth Warren (D-Mass.) leading the charge for better investor protection. And on December 21, Facebook finally managed to relaxation its longstanding near-ban on crypto ads, increasing the number of regulatory licenses it considers acceptable to be approved to run advertising from three to 27. This was two and a half years after plans to its own cryptocurrency, Libra — now Diem — stablecoin.

Read more: Senator Warren calls DeFi the ‘most dangerous’ part of crypto during Senate hearing