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Intellectual property · Technology · Digital assets — Lithuania & Estonia

Marketing review: stages and deadlines

Marketing review checks every public message about a token issuance before it goes out: website copy, decks, social posts, and paid promotion. It runs in three stages — drafting, clearance, and sign-off — and takes one to three weeks in practice, depending on how many markets the campaign covers.

What changes once marketing enters review

Before review starts, marketing materials are drafts and can be rewritten freely. Once a draft is submitted for clearance, every later change has to go through the same cycle again. This is the point most teams underestimate: a small wording fix after sign-off is not a small fix procedurally, it is a new review.

The practical effect is timing risk rather than legal risk at this stage. A campaign that misses its clearance window slips its whole launch date, because publication cannot happen before written sign-off exists. Teams that build in one buffer round of comments finish closer to the original date than teams that assume the first draft will pass.

Stages and typical timing

The table below sets out the three stages as they run in practice. Timing varies with the number of markets and the number of draft rounds, so the ranges are wide by design.

StageWhat happensTypical duration
DraftingMarketing team prepares copy against the issuance documentation3–7 days
ClearanceLegal checks claims for consistency with the underlying documents and flags promissory language2–5 days per round
Sign-offCompliance function issues written clearance; publication date is set only after this step1–2 days

Most campaigns need two rounds of clearance, not one. A single-market campaign with clean drafting can clear in a week; a multi-market campaign with paid promotion usually needs closer to three.

What to do

  1. The marketing team collects every asset — copy, visuals, paid placements — into one package before the first submission.
  2. The compliance officer checks the package against the issuance documentation, not against the marketing team's own assumptions about it.
  3. Legal flags any claim that reads as a promise of value, return, or listing outcome, and returns it for rewrite.
  4. The marketing team revises flagged language and resubmits the full package, not only the changed lines.
  5. The compliance officer issues written sign-off once every flag is closed.
  6. The project lead sets the publication date only after sign-off is in hand, never before.

Who decides

Sign-off sits with the issuer's own compliance function, not with outside counsel. Counsel identifies the issues; the compliance function owns the decision to publish. Where a trading venue or distribution partner has its own review step, that step runs in parallel and has its own deadline — it does not replace internal sign-off.

Common forks

If the campaign targets more than one market, each language or market variant needs its own clearance round, because claims that read as neutral in one market can read as a guarantee in another.

If any material promises a price outcome, a return, or a guaranteed listing, that line is stopped at first review. No amount of rewording moves this forward until the promise is removed, not softened.

If the underlying issuance documentation is still being finalised, marketing sign-off is deferred. Reviewing claims against a document that is still changing produces a clearance that has to be redone.

Sources and limits

This page describes the review procedure, not the substance of any single claim. Whether a specific counterparty is who it says it is sits outside marketing review. A worked scope for that question is set out in Counterparty in Malta.

Whether a specific document is genuine, current, and consistent with the deal is also a separate exercise. A worked scope for that question is set out in Document in Singapore.

Whether a target market's rules allow a given claim at all depends on facts this page does not hold. A worked scope for that question is set out in Jurisdiction in Hong Kong.

Related reading

Marketing review usually runs alongside, not instead of, the listing track. The listing side of the timeline is covered separately: Listing preparation step by step.

Verified

Checked in November 2025. This description reflects procedural practice rather than a single regulatory text. For how we collect, cross-check, and date procedural steps, see Methodology: collection, cross-checking and dating in practice.

FAQ

How long does marketing review take in practice?

One to three weeks from first draft to sign-off. Single-market campaigns with a clean first draft clear faster; multi-market campaigns with paid promotion take longer, mainly because of extra clearance rounds rather than any single slow step.

Which documents are needed to start?

The full marketing package — copy, visuals, and any paid placement text — plus the current issuance documentation it has to match. Submitting the package in pieces is the most common cause of extra clearance rounds.

What happens if the other side does not respond?

If a partner platform or distribution channel holds its own review and does not respond, the publication date attached to that channel slips. Escalating early, rather than waiting out the silence, is what keeps the rest of the timeline on track.

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