Regulatory Alerts2025-04-30
Added · Updated
CSSF Circular 25/887: Application of ESMA Guidelines on Third-Country Crypto Solicitation and Reverse Solicitation Exemption
The CSSF integrates the European Securities and Markets Authority (ESMA) guidelines into its administrative practice to define when third-country firms are deemed to solicit clients in the EU and to establish supervision practices preventing circumvention of the reverse solicitation exemption under the Markets in Crypto Assets Regulation. This circular applies to third-country firms as defined by Article 59 of MiCAR and becomes effective on 27 April 2025. The document mandates that competent authorities monitor online activities, exchange information with other authorities, and react to complaints to detect unauthorized solicitation, while clarifying that promotional acts such as regional SEO or influencer marketing constitute solicitation regardless of the client's subsequent initiative.
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