Notice Regarding MiCA Article 61 – Reverse Solicitation Framework

Vigilance (3-102-935700) S.R.L., operator of the Vigiler platform, is committed to full regulatory compliance in all jurisdictions where its services may be accessed. With specific regard to the European Union, the company operates exclusively within the framework of Article 61 of the Markets in Crypto-Assets Regulation (MiCA), commonly referred to as reverse solicitation.

What This Means for EU-Based Users

The Vigiler platform is not marketed, promoted, or made available to customers in the EU through any form of solicitation. Instead, all interactions with EU-based users are initiated solely by those users on their own initiative, in full alignment with the principles of reverse solicitation.

To ensure transparency and compliance, please note the following:

  • The Service Provider has no offices, agents, representatives, or marketing presence in any EU Member State.
  • The Service Provider does not advertise or actively promote its services to EU residents.
  • Access by EU-based users is entirely user-initiated, without invitation, targeting, or solicitation from the Service Provider.
  • For audit and compliance purposes, the platform may record and retain technical data (such as IP addresses and timestamps) to verify that account creation and usage originated from the Customer’s own initiative.

Any third-party references to Vigiler, including referral or promotional content, are not authorised or endorsed by the Service Provider. We explicitly disclaim any responsibility for third-party initiatives that may appear to promote our services within the EU.

EU-based users acknowledge that their engagement with Vigiler is self-directed and not the result of any form of targeting or encouragement by the platform operator.

Compliance with MiCA and ESMA Guidelines

Vigilance S.R.L. takes its compliance responsibilities seriously. In accordance with MiCA Article 61 and related guidance issued by the European Securities and Markets Authority (ESMA), the platform does not offer or promote additional crypto-asset services to EU users beyond those specifically and independently requested by the user.

To further reinforce the principles of reverse solicitation and regulatory alignment, the platform has implemented the following limitations for EU-based customers:

  • Full compliance with EU Regulation 2023/1113 regarding the transmission of information alongside fund and crypto-asset transfers (commonly known as the Travel Rule).
  • As of 29 February 2025, support for USDT (Tether) and PAXG (Paxos Gold) has been discontinued across the platform.
  • As of 1 July 2025, no new invitation codes are issued to any user globally to reduce the risk of unsolicited access.

Important Disclaimer

This notice is provided for informational and transparency purposes only. It does not constitute legal advice, and it does not represent any form of marketing, solicitation, or offer of services to residents or entities located in the European Union.

Any EU-based users who access or use the platform do so at their own initiative and risk. Activity inconsistent with reverse solicitation principles may result in service limitations or suspension in accordance with MiCA and related national regulations.

For compliance-related inquiries, please contact our legal team at: [email protected]

Future Considerations

Vigilance S.R.L. actively monitors the evolving regulatory landscape in the European Union. While we currently operate solely on a reverse solicitation basis, we reserve the right to reassess our position in the future. If regulatory clarity and stable licensing frameworks emerge, we may consider establishing a licensed EU presence.

Currently, however, no services are being marketed, offered, or provided through any entity, affiliate, or representative within the European Union.

Platform operator: Vigilance (3-102-935700) S.R.L. – https://vigilance.ltd – Plaza Forencia No. 10, San Rafael, Costa Rica 10203.