In its factsheet Finfluencer – Tipps für verantwortungsvolle Werbung, the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht or Bafin) previously emphasised that advising others as to which investments they should make, or refrain from making, may amount to regulated investment advice.
By way of background, finfluencers will not ordinarily satisfy the statutory













