Reverse Solicitation

Reverse solicitation is the argument that a firm needs no local authorisation because the customer approached it on their own initiative rather than being marketed to. Where a regime provides such an exemption at all, it is drafted narrowly: it is meant for a genuinely unprompted approach, it covers only the service actually asked for, and advertising, sponsorship, referral payments or targeted messaging through any channel are normally enough to defeat it. What matters to a customer is what relying on it implies. A firm making the argument is telling you that it is not authorised where you live, which usually means the local supervisor has no remit over it, local conduct and client-asset rules do not apply, no local compensation scheme covers the account, and any complaint has to be pursued wherever the firm is established. The claim is often presented as a formality — a box to tick at signup stating that you approached the firm, or a clause in the terms — and ticking it changes nothing about where the firm is actually authorised. Whether the exemption exists, and how narrowly it is read, differs by jurisdiction.