Zango report

The New Era of Marketing in Financial Services

AI is transforming how financial institutions create and personalise marketing content. This report brings together leaders from across Portugal’s financial sector to set out how firms can respond - strengthening compliance while preserving trust and delivering clearer, fairer communications for customers.
Rt Hon John Glen MP

Miguel Maya, CEO, Millennium bcp

In the report, Miguel Maya provides an essay on "Trust as a foundation of marketing in the age of AI".

“Whether through human interactions or digital channels, the same principles apply: accuracy, transparency, respect for privacy and a commitment to the customer’s best interests.”

— Miguel Maya, CEO, Millennium bcp

CONTENTS

The collected essays in this report

01
Miguel MAya, CEO, Millennium bcp

Trust as a foundation of marketing in the age of AI

Why adopting AI well is a trust challenge rather than a technology one, and how AI becomes the new gateway to financial information.

02
Emanuel Silva, CEO, IMGA

AI in asset management democratising the ability to compete

How AI narrows the scale gap for smaller managers, and why accountability for how products are represented cannot pass to the algorithm.

03
Manuel Caldeira Cabral, Former Member of the Board, ASF

AI in insurance: better risk assessment requires better supervision

Where sharper risk pricing ends and revenue extraction begins, and why supervisors need their own analytical tools to tell the two apart.

04
Inês Palma Ramalho, Partner, Pérez-Llorca

How existing financial marketing rules co-exist with AI-generated content

The legal shift from approving one advertisement to governing a system, and why the AI Act applies alongside existing financial marketing rules.

05
RAQUEL VILA VERDE, GROUP OF HEAD OF COMPLIANCE, CGD

Marketing compliance in the age of AI

What Portugal's tightened advertising regime demands of firms, and the safeguards AI review systems need before compliance can rely on them.

06
Francisco Luís Alves, Head of LEGAL, INsurance, Fidelidade Group

When AI talks to AI: conduct risk and customer communications

What changes when customers and insurers both use AI to write, and why disclosure alone settles none of the harder questions.

07
Pedro Oliveira Machado, Country Senior Director, Grupo Ageas Portugal

Rethinking the Three Lines of Defence

The case for a five lines of defence model, with controls embedded in processes and the board accountable under the EU AI Act.

08
André Praseres Henriques, Chief Compliance Officer, BPI

Ahead of the curve: how compliance functions get ready for AI

How to build oversight before the rulebook arrives, using the finfluencer lesson, use case inventories and honest answers about shadow AI.

09
João Pedro Tavares, Programme Director, Católica Lisbon

Why AI is opening a marketing compliance skills gap in banking

Why AI-mediated distribution breaks traditional marketing and compliance roles, and the mix of skills banks now need to build across teams.

10
‍
Inês Caria,
Chief Compliance Officer, Banco Santander Totta

Building a culture that adopts AI responsibly while oversight keeps pace

What complinace by design means in practice and how control, traceability and customer protection are built into every solution from day one.

11
‍
Rogério Campos
Henriques, CEO, Fidelidade

Do customers understand what they are buying?

Why a company's growth should never depend on a customer failing to understand what they have bought or being unaware of an important limitation of a product.

Executive summary

Key themes

01

Trust is at stake

Financial institutions run on trust that takes years to earn and seconds to lose. As communications become more personalised, customers still expect transparency, fairness, and clear accountability for the outcome.

02

One message has become thousands

A single campaign to 100,000 customers can become 100,000 variations. Each may be factually accurate while differing in emphasis, in the features highlighted and in the prominence given to risk.

03

Compliance can move upstream

Rather than acting as a final checkpoint, compliance can increasingly apply regulatory requirements and internal standards as marketing is created, helping teams identify issues earlier and work more consistently.    

04

Accountability stays with the institution

AI may generate the wording, but the regulated institution remains responsible for what customers are told, how it is presented and how they are likely to understand it.

05

Assurance must continue after approval

Content can be adapted, republished or personalised after launch. Firms therefore need an ongoing view of what is live, where it appears and whether it still meets regulatory and internal standards.

06

Capability has to catch up with technology

Marketing, compliance and technology teams all need to adapt as AI changes how content is created and governed. Building those capabilities will be critical to using AI responsibly at scale.    

Contributors

Commentary from leading voices across Portugal's financial services

Zakaria Ouraich

Manuel Caldeira Cabral

Former Member of the Board, ASF, and former Minister of the Economy

Chris Kiew-Smith

Miguel Maya

CEO

Edward Thompson

Raquel Vila Verde

Group Head of Compliance

Michael Phillips

Inês Palma Ramalho

Partner and Head of the Financial Services Department

Ashi Bajwa

Emanuel Silva

CEO

Ritesh Singhania

Ritesh Singhania

CEO and Co-Founder

Andrew Henderson

Pedro Oliveira Machado

Country Senior Director

Robbie Constance

João Pedro Tavares

Programme Director

Andrew Henderson

Francisco Luís Alves

Director of the Business
Legal Department

Robbie Constance

André Prazeres Henriques

Chief Compliance Officer

Robbie Constance

Rogério Campos Henriques

CEO

Robbie Constance

Inês Caria

Chief Compliance Officer

✦  What the Rds

Key findings

01

One campaign can become thousands of communications

PERSONALISATION

AI allows content to be generated and adapted at a scale that traditional, asset-by-asset approval processes were not designed to oversee.

02

Compliance has to move into the creation process

CONDUCT RISK

Rather than acting as a final checkpoint, compliance increasingly needs to apply regulatory requirements and internal standards as marketing assets are created.

03

The firm’s judgement needs to become reusable

GOVERNANCE

Approved claims, qualifiers and past decisions need to become institutional knowledge that can be applied consistently across all campaigns.

04

Assurance cannot stop at approval

OVERSIGHT

Firms need an ongoing view of what is live, where it appears and which communications are affected when content, products or regulatory requirements change.

Get the full report

A guide for risk and compliance leaders on how AI is changing the marketing in financial services - with key findings, signals, and practical takeaways.
Full report PDF
Contributions from senior financial services leaders
Perspectives banking, insurance and asset management
Implications for marketing, compliance and customer trust
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