Scroll past a Cleo ad on TikTok and you might not realise you've seen one. There's no product demo, no download prompt, no APY figure, no reassuring voiceover. In one, a woman talks to camera about being in a long-term relationship - it takes a while to clock she's talking about a money app. Another ends on the line "Who the fck is Cleo?" with no follow-up answer. A third is a mockumentary office sketch about a colleague called Susan who has six coffees on her desk. Punchline: "One drink is fine. Six is Susan."
These are the only two pieces of paid creative Cleo has run in the UK in the past six months. And across five videos - two paid, three organic - there is barely a product feature in sight.
This is not an accident. It's a content strategy that's worth unpacking properly, because it says something interesting about how a certain kind of fintech brand is thinking about acquisition - and about what happens when a marketing team decides, deliberately, to step outside the performance measurement framework entirely.
What the content is actually doing
The first thing to notice about Cleo's TikTok presence is the production range. Some of it is deliberately rough - a short pixel art animation in a retro Windows 95 aesthetic, a "totally not a virus, trust me, I'm a homepage" desktop icon, the word "algorithms" appearing over a floppy disk. Chaotic, ironic, built to feel native to the platform.
Other content is notably high production. A brand film positions what Cleo calls its "AI Finance Assistant and Roastmaster" as an actual character - shot across multiple locations, proper lighting, pinstripe suits. A chat bubble shows Cleo saying something cutting about a subway driver and a boyfriend. It's more short film than advertisement.
What unites all of it is tone. Cleo is positioning itself not as a financial tool but as a personality - specifically, a personality that will talk to you about money the way a slightly chaotic, occasionally brutal friend would. The "Roastmaster" framing is deliberate. The implication is that traditional financial apps are clinical and condescending, and Cleo is the alternative for people who find that alienating.
That's a clear demographic signal. The Susan ad isn't aimed at everyone - it's aimed at someone in their mid-twenties who recognises the person with six coffees on their desk, who earns enough to spend carelessly but not enough to feel secure about it, and who is mildly anxious about money but absolutely does not want to be lectured about it. The identity-based positioning works because the target audience is meant to see themselves as the person who gets the joke, not the person who is the joke. You're not Susan. But you know a Susan.
In the US, where Cleo's core product sits, this demographic likely skews toward the 18-28 range - a cohort that tends to find traditional financial advertising patronising and responds to brands that feel like peers rather than institutions. TikTok's own user base tilts younger, which makes it a plausible fit.
The compliance architecture is deliberate
Here's where the content strategy gets more structurally interesting.
Across the two paid ads and two of the three organic videos, there is no compliance disclaimer. No small print. No regulatory language of any kind. For anyone who has worked in fintech marketing, that absence is immediately noticeable - financial promotions in the UK require FCA approval and specific disclosure language, which tends to put a hard floor on how creative the creative can get.
The reason these ads carry no disclaimer is that they're not making any financial claims. They're not promoting a product, a rate, or a feature. They're building a brand. And brand content - entertainment that happens to be made by a fintech - sits outside the financial promotion rules entirely. This isn't a loophole; it's an architectural choice. By keeping paid creative in the pure brand-building category, Cleo preserves complete creative freedom. No compliance review, no mandated disclosures, no constraints on tone.
The one organic video that does carry a disclaimer is revealing precisely because of that contrast. Two women in a restaurant, one accusing the other of only being there for the Cleo card. Light, conversational, same brand tone as everything else - but at the bottom of the screen, small print: "Cleo Card issued by WebBank, Member FDIC. Subject to approval. $1 minimum deposit required." That's a US financial promotion. A specific product is being promoted, so the compliance language has to be there.
The distinction between that video and the others makes the strategy legible. Everything without a disclaimer is entertainment. Everything with one is an ad. Cleo is running both, but keeping them visually almost identical - so the brand warmth built through the entertainment content transfers to the product content without a visible seam.
The measurement decision
To understand why this creative approach is notable, it helps to understand why TikTok is an uncomfortable platform for many fintech performance marketers in the first place.
Where last-click attribution is the default - and it still is in many teams - TikTok is structurally disadvantaged for products with a longer consideration cycle, which financial products tend to have. Someone sees a TikTok, doesn't immediately convert, eventually downloads the app a week later via a Google search. Last-click gives the credit to Google. TikTok shows a CPA of zero and looks like it isn't working. Budget moves to Meta and Google, where the attribution is cleaner and the numbers make sense on a dashboard.
The suspicion - and it's a reasonable one - is that TikTok ends up underused by fintech performance teams not because it doesn't reach the right audience, but because the measurement framework makes it hard to justify the spend. Direct response creative on TikTok tends to disappoint on last-click metrics regardless of what it's actually contributing, so teams default to the channels where they can show clean returns.
My read on what Cleo is doing - and this is an outside view, not an inside one - is that they've found a way to sidestep this entirely. By running pure brand content with no CTA and no conversion intent, they're not trying to make TikTok work as a direct response channel. The conversion happens elsewhere, downstream, in channels where it can be measured. TikTok's job, if this interpretation is right, is simply to make sure Cleo is already somewhere in the consideration set when that moment arrives.
If that's the thinking, it's a pragmatic solution to a real constraint - routing around the measurement problem rather than fighting it. But it's worth saying clearly: this is inference from the creative, not confirmation from the team.
The broader point
What makes Cleo's approach worth studying is that it represents a coherent answer to a genuine problem: how do you market a financial product to an audience that has been trained by the internet to ignore, mock, or scroll past anything that looks like an ad?
The answer they've landed on is: don't make it look like an ad. Make it look like content. Build a character, build a tone, build the kind of brand that people mention to their friends - not because of a referral incentive, but because they find it genuinely entertaining. Then let the conversion happen downstream, in whatever channel it happens in, and accept that you won't be able to draw a straight line back to the TikTok video that started it.
The compliance architecture supports this rather than constraining it. By separating brand content from product content at a structural level, the creative team retains the freedom to operate without the disclaimers and approval processes that typically flatten fintech advertising into something forgettable.
The willingness to operate without a CPA target on this channel is arguably the most interesting part of the strategy. It suggests a marketing team that understands the limits of performance measurement well enough to know when not to apply it - and has made the case internally to run brand content on its own terms rather than forcing it to justify itself through a framework it was never designed to satisfy.
Whether that holds as Cleo scales - when acquisition targets grow and the pressure to attribute every pound of media spend intensifies - is a different question. But as a content strategy for a specific audience on a specific platform, it's a more considered approach than most fintech TikTok content tends to be.
Disclaimer: All video content featured in this article belongs to Cleo. No ownership is claimed over any of the material shown.