Crypto-Asset Regulation · glossary
MiCA's narrow exemption for a client who approaches a firm entirely on the client's own initiative, and only for the service asked for. An advertisement, an app-store listing aimed at the country or a referral scheme ends it. It is never a way into a market. Definition: Reverse solicitation · Binder §1.5 · Chapter 6
Explained in Chapter 6, The Passport, the Map of Regulators, and the Country That Left, of Crypto-Asset Regulation.
For firms outside the EU, MiCA's answer is a narrow no, in Article 61. Reverse solicitation covers a client who approached the firm entirely on the client's own initiative, and only for the service asked for. Most other countries draw a similar narrow line, so the Binder applies this test to any client who comes to Halcyon from outside its notified states.Read Chapter 6, The Passport, the Map of Regulators, and the Country That Left →
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the MiCA rule that a firm outside the EU needs no MiCA authorisation for a service an EU client asks it for entirely on the client's own initiative, and for that service only (Article 61); this binder applies the same narrow test, in reverse, to a client outside the EU who approaches Halcyon, and whether that client's own country permits the service is that country's law;Read the definition in the document →
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