Reverse Solicitation Rules address situations where a client initiates contact with a financial firm regarding a product or service without prior promotion from the firm. These rules typically aim to differentiate between legitimate client-initiated inquiries and disguised marketing efforts that bypass regulatory restrictions. They are particularly relevant in cross-border financial services to prevent firms from circumventing local regulations. Adherence helps ensure proper market conduct.
Context
Reverse solicitation rules are highly pertinent to digital asset firms operating globally, especially those serving clients in jurisdictions where they are not licensed. Companies often rely on these provisions to justify providing services to overseas clients who approach them unsolicited. However, regulators are increasingly scrutinizing claims of reverse solicitation to prevent their misuse as a loophole for unregistered activities. Future enforcement actions will likely clarify the strict boundaries and evidentiary requirements for asserting reverse solicitation.
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