Reverse solicitation: Rules of the road and international enforcement trends

Andrea Vianelli and Antonio Appon
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Andrea Vianelli: COO Asset Management & Strategic Advisory, Laser Digital, Switzerland
Antonio Appon: Legal and Compliance Officer, Laser Digital, Switzerland

Journal of Financial Compliance, 2025, vol. 9, issue 1, 40-59

Abstract: This paper discusses the concept of reverse solicitation in the context of cross-border provision of financial services, seeking to combine a theoretical and a pragmatic approach to a topic that has not been — to the authors’ knowledge — subject of in-depth analyses leading to actionable insights. In particular, it offers a practitioner’s perspective on how reverse solicitation is often invoked as a silver bullet to enable a cost-effective market access route, despite being a very narrow (and often without exit) alley. After introducing the concept of reverse solicitation as ‘exception to the rule’ rather than as a de facto alternative to licencing, the author(s) offers an overview of the most recent legal and regulatory sources on reverse solicitation in the EU as well as in other selected markets. The final section concludes with observations on some of the open challenges around the concrete application, both from an investment firm as well as from a supervisory perspective, of reverse solicitation. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/business/.

Keywords: crypto assets; digital assets; Market in Crypto Asset Regulation (MiCAR); regulation; reverse solicitation; DeFi; financial instruments; financial law; investment services; cross-border; regulation (search for similar items in EconPapers)
JEL-codes: E5 G2 K2 (search for similar items in EconPapers)
Date: 2025
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