1. Introduction and Parties to the Agreement

This Client Agreement (the “Agreement”) governs the legal and commercial relationship between NPE Market Limited, a company registered under the laws of Saint Lucia with registration number 2024-00497, having its registered office at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros Islet, Saint Lucia, and its operational office located at 24th Floor, The One Tower, Barsha Heights, P.O. Box 390114, Dubai, United Arab Emirates (hereinafter referred to as the “Company”, “we”, or “us”), and any individual or legal entity that opens an account and receives trading services from the Company (hereinafter referred to as the “Client”, “you”, or “your”).

This Agreement forms a legally binding contract and applies to all products, services, accounts, and transactions offered by the Company. By opening an account, submitting required verification documents, depositing funds, accessing the trading platform, or placing any transaction, the Client acknowledges, confirms, and agrees to be bound by the terms set forth herein.

To clarify the nature and effect of this Agreement:

1. This Agreement is entered into on an execution-only basis.
2. The Company does not provide investment advice or recommendations.

3. The Agreement shall become effective only upon the completion of all required identity verification procedures (KYC) to the satisfaction of the Company and the subsequent activation of the Client’s Trading Account.

1. The Client is solely responsible for all transaction decisions.

5. This Agreement constitutes a continuing contractual framework that governs all present and future transactions, dealings, and operations executed by the Client with the Company. Accordingly, once activated, the Agreement shall remain in full force and effect until formally terminated by either Party in accordance with the applicable termination provisions.

1. The English version of this Agreement prevails over any translation.
2. The Client acknowledges and agrees that this Agreement is not subject to cancellation based on it being concluded at a distance or by electronic means. No cooling-off period applies, and upon acceptance, the Agreement becomes legally binding on the Client.

2. Scope of Services and Nature of Trading

The Company provides the Client with access to electronic trading platforms, including but not limited to MetaTrader 5 (MT5), for the purpose of executing Contracts for Difference (CFDs) on foreign exchange currency pairs, commodities, indices, precious metals, and other financial instruments offered by the Company.

The trading services offered by the Company are provided over-the-counter (“OTC”), meaning transactions are executed directly between the Client and the Company, and are not conducted on a regulated securities exchange or central clearing venue.

2.1. Nature of CFD Transactions

A Contract for Difference (“CFD”) is a financial derivative that enables the Client to speculate on the price movement of an underlying financial asset without acquiring ownership, possession, or any enforceable rights to the asset.

The Client understands and agrees that:

1. CFDs are leveraged instruments. The margin deposited represents only a portion of the transaction value.
2. Leverage amplifies both profits and losses, and adverse price movement may lead to rapid and significant equity reduction.
3. The value of a CFD position is determined by the difference between the opening price and the closing price of the transaction.
4. The Client does not acquire shareholder rights, entitlement to dividends, delivery of commodities, or settlement in physical currency or futures contracts.

CFDs are speculative and high-risk, and may not be suitable for all investors. The Client represents that they fully understand the risks associated with leveraged trading.

2.2. Pricing and Liquidity Construction

The Client acknowledges that pricing of CFD instruments is derived from the Company’s liquidity aggregation and pricing architecture, which integrates executable price feeds from multiple external liquidity providers, institutional venues, and electronic market-makers. Pricing is formatted, filtered, and displayed through the Company’s trading systems.

To ensure transparency:

1. The Company constructs tradable prices using aggregated bid/ask data from its liquidity sources.
2. The Company may apply mark-ups, mark-downs, and execution adjustments to reflect liquidity conditions, volatility, and risk exposure.
3. The pricing displayed on the trading platform may differ from prices available on other brokers, exchanges, or market data vendors.
4. There is no single universal price for any OTC CFD instrument, and the Company is not obligated to match external pricing.

The Client expressly accepts that the Company’s pricing is the official and binding price for the purpose of all trade execution, margin valuation, and account equity calculation.

2.3. Execution Model and Role of the Company

The Client acknowledges that the Company operates a Hybrid A-Book / B-Book execution framework. This means the Company may:

• Internalize Client trades and act directly as the counterparty (B-Book), and/or
• Transmit trades to external liquidity providers for execution (A-Book).

The determination of execution routing is made solely by the Company, based on liquidity conditions, market depth, volatility, trade size, risk analysis, historical Client trading behavior, and the Company’s internal risk management policies.

The following principles apply:

1. The Company is the principal to every CFD transaction executed under this Agreement.
2. The Client does not have the right to request or enforce execution through any specific liquidity provider.
3. The Company is not required to disclose its hedging, external execution counterparties, risk decisions, or internal trade routing logic.
4. The Company may hedge or may choose not to hedge Client trades.

The Client’s contractual relationship is exclusively with the Company, not with any underlying liquidity source.

2.4. Execution Quality, Slippage and Latency

The Client understands and accepts that:

1. Slippage may occur, favourable or unfavourable, depending on market conditions.
2. Orders are executed at the best available price at the time of execution, which may differ from the requested price.
3. During periods of high volatility or low liquidity, spreads may widen, price updates may accelerate, and execution may be delayed.
4. Such outcomes are normal and expected in OTC derivative markets and do not constitute improper execution, system failure, or breach of duty by the Company.

2.5 Services Provision and Trading Conditions

1. The Company provides the Client with access to trade the financial instruments that are listed on the Company’s Website, which may include, but are not limited to: Foreign Exchange (Forex), Contracts for Difference (CFDs), Commodities, Precious Metals, Indices, and Crypto assets.
2. Any market commentary, research information, analysis, news or educational content made available by the Company is provided for informational purposes only and shall not constitute investment advice, investment recommendation, or solicitation to engage in any trading activity. The Company does not guarantee the accuracy or completeness of such information and shall not be held liable for any losses incurred as a result of reliance on such content.
3. The Company is not obligated to assess the suitability or appropriateness of the trading services or financial products offered to the Client. The Client confirms that they understand the risks associated with leveraged trading and are solely responsible for evaluating their own risk tolerance and making independent trading decisions.
4. The Company reserves the right, at its sole discretion, to delay, restrict, suspend, or refuse the provision of services or execution of orders during abnormal market conditions, technical disruptions, system outages, or events that may impact fair and orderly execution.
5. Execution of orders may vary depending on market liquidity, platform performance, volatility levels, and overall market conditions. The Company further reserves the right to adjust leverage levels, margin requirements, and other trading parameters without prior notice, particularly during periods of high market volatility, significant economic announcements, weekends, market gaps, and extraordinary market events, to ensure proper risk management and stable trading environments.

3. Definitions and Interpretation

For the purposes of this Agreement, the following terms shall have the meanings set out below. Terms used in the singular include the plural and vice versa, and headings are for convenience only and do not affect interpretation.

3.1. “Account”
Means the trading account held by the Client with the Company for the purpose of trading CFDs and performing deposit, withdrawal, and account management operations.

3.2. “Agreement”
Means this Client Agreement together with all Operative Documents referenced herein, as amended from time to time.

3.3. “Applicable Law”
Means any statute, regulation, directive, rule, order, court decision, regulatory guidance, or supervisory requirement that applies to the Company’s operations.

3.4. “Ask Price”
Means the price at which the Client can buy a CFD instrument from the Company.

3.5. “Bid Price”
Means the price at which the Client can sell a CFD instrument to the Company.

3.6. “CFD (Contract for Difference)”
Means a derivative contract where the Client and the Company agree to exchange the difference in value between the opening and closing price of the position, without ownership of the underlying asset.

3.7. “Client Money”
Means funds deposited by the Client and held by the Company for the purpose of margin, trading, settlement, and withdrawal, subject to operational, liquidity, and banking risk.

3.8. “Company”
Means NPE Market Limited, as described in Section 1 of this Agreement.

3.9. “Equity”
Means the real-time value of the Client’s Account calculated as:
Equity = Account Balance ± Floating Profit/Loss.

3.10. “Execution-Only Basis”
Means that the Company does not provide advice or recommendation, and the Client independently makes all trading decisions.

3.11. “Floating Profit/Loss”
Means the unrealized profit or loss on open CFD positions.

3.12. “Free Margin”
Means the amount of Equity available to open new positions, calculated as:
Free Margin = Equity – Margin Used.

3.13. “Leverage”
Means the ratio that determines the required margin relative to the exposure of a CFD position.

3.14. “Margin”
Means the required amount of funds needed to open and maintain CFD positions.

3.15. “Margin Call”
Means a notification to the Client indicating that Equity has fallen to a level where additional funds are required to avoid liquidation of open positions.

3.16. “Stop Out Level”
Means the Equity level at which the Company may automatically close some or all open positions without notice.

3.17. “Platform”
Means MetaTrader 5 (MT5) or any other electronic trading system provided by the Company for entering, viewing, and closing transactions.

3.18. “Spread”
Means the difference between the Ask Price and the Bid Price quoted by the Company.

3.19. “Stop Loss / Take Profit Order”
Means conditional orders intended to close a position once price reaches a predefined level, subject to availability of executable price and market conditions.

3.20. “Slippage”
Means the difference between the expected price and the executed price due to market movement, liquidity depth, volatility, or technical delay.

3.21. “Prohibited Trading Activity”
Means any activity that manipulates, exploits, disrupts, or unfairly abuses the Company’s pricing, execution system, bonuses, latency, or liquidity feeds; specific rules are detailed in Section 10.

4. Account Opening, Verification and Eligibility

4.1. Account Application and Onboarding

In order to open a trading account with the Company, the Client must complete the online registration process, provide accurate personal information, and submit all documents requested by the Company as part of its identity verification and due diligence procedures. The Company may require additional information at any time to complete or re-confirm the Client’s identity, residence, financial profile, trading experience, risk understanding, or other relevant suitability factors.

4.2. KYC and Identity Verification Requirements
The Company conducts verification procedures (“Know Your Customer” or KYC) in accordance with its internal policies and Applicable Law relating to anti-money laundering, counter-terrorism financing, fraud prevention, and financial crime controls.
The Client must provide, without limitation:

1. Valid proof of identity (e.g., passport or national identity card).
2. Valid proof of residential address (e.g., utility bill or bank statement).
3. Any additional information or documentation the Company deems necessary to verify identity or location, including selfie verification, biometric confirmation, or video verification.
4. A Trading Account shall be deemed active and operational only upon formal confirmation issued by the Company. Mere submission of the application or registration on the platform does not constitute account activation.
5. The Client acknowledges and agrees that the Trading Account shall not be considered active, nor shall the Client be entitled to access trading services, until the Company and/or the appointed verification service provider (including but not limited to Sumsub Platform) has reviewed and approved all required identification and corporate documentation. The Client shall not claim or imply that the account was active prior to such confirmation.

Failure to complete KYC satisfactorily may result in the account not being opened, being suspended, or being permanently closed.

4.3. Enhanced Due Diligence (EDD), Source of Funds and Source of Wealth
The Company reserves the right to request evidence regarding the origin of the Client’s funds and overall financial capacity. This may include, without limitation:

• Bank account statements
• Employment or income verification
• Invoices, contracts, or financial statements
• Corporate ownership documents (for business accounts)

Where the Company reasonably determines that funds may be associated with unlawful, suspicious, unverified, or high-risk activity, the Company may:

• Delay or refuse deposits or withdrawals
• Freeze or place limitations on the account
• Terminate the Client relationship
• Report the activity to relevant authorities

The Client irrevocably agrees that the Company may take such actions without any obligation to disclose the results, methods, or sources of its compliance review.

4.4. Politically Exposed Persons (PEPs) and Restricted Persons
The Client must disclose if they or any beneficial owner is a Politically Exposed Person, a close associate of a PEP, or a family member of a PEP.
The Company may refuse to open or continue servicing accounts linked to:

• PEP high-risk classifications
• Persons subject to sanctions
• Persons from jurisdictions subject to international restrictions
• Persons with unclear or unverifiable identity or fund sources

4.5. Residency and Jurisdiction Restrictions
The Company does not provide services to residents of certain countries where CFD trading is restricted, prohibited, unsupervised, or presents elevated compliance risk. The list of restricted jurisdictions is determined solely by the Company and may be updated without notice.
The Client is solely responsible for ensuring that they are legally permitted to use the Company’s services in their country of residence.

4.6. Corporate and Institutional Accounts
Where the Client is a legal entity, the Company may require:

• Certificate of Incorporation / Company Registration Extract
• Memorandum and Articles of Association
• Register of Directors and Shareholders
• Proof of business address and active operations
• Identification and verification of all ultimate beneficial owners (“UBOs”)

For Corporate (Business) Clients, activation of the Trading Account shall occur only upon the Company’s receipt of a duly completed and signed Corporate Trading Account Application Form, the Client’s full acceptance of all applicable Agreements, Policies, and Terms published by the Company, and the successful completion of all corporate due diligence and verification procedures (KYC/KYB) to the Company’s satisfaction.

The Company may refuse to open accounts for shell entities, nominee ownership structures, bearer-share entities, or high-risk business categories.

4.7. Right to Decline or Terminate the Client Relationship
The Company retains full discretion to refuse an account application, suspend account activity, request additional documents, impose transaction limits, or terminate this Agreement at any time, where it considers such action necessary to comply with its regulatory, legal, or risk management obligations.
The Company is not required to provide the Client with a reason for such refusal or termination.

4.8. Accuracy of Information Provided by the Client
The Client must ensure that all information provided during onboarding and throughout the business relationship is accurate, complete, and up to date.
The Client must notify the Company immediately of any change in:

• Personal or contact information
• Residential or business address
• Banking arrangements
• Ownership structure (for corporate accounts)

Failure to maintain accurate information may result in account suspension or closure.

5. Client Money, Safeguarding and Fund Handling

5.1. Segregation and Holding of Client Money
Funds deposited by the Client are held by the Company in one or more accounts with financial institutions, payment service providers, or liquidity-related banking partners, in accordance with the Company’s internal safeguarding standards. Client funds may be held in omnibus (pooled) accounts, alongside funds of other clients. The Client acknowledges that omnibus holding is a standard practice in OTC derivatives trading, and that individual allocation of specific funds to a specific Client account is not maintained on a segregated bank ledger level, but on the Company’s internal accounting records.

The Company may place Client funds in segregated or pooled (omnibus) accounts; however, any interest, income, or yield generated from the use or placement of such funds shall be retained solely by the Company, and the Client hereby expressly waives any claim to such amounts.

5.2. No Custodian or Trustee Relationship
The Client acknowledges that the Company is not a deposit-taking financial institution and does not act as a trustee, custodian, or fiduciary with respect to Client Money. The relationship between the Client and the Company is that of creditor and debtor. Upon deposit, the Client grants the Company the right to hold, transfer, and manage funds for the purposes of margining, settlement, hedging, withdrawal processing, and operational liquidity.

5.3. Banking Counterparty and Intermediary Risk
Funds may be held with international banks, payment processors, correspondent banks, or liquidity settlement venues located in or outside Saint Lucia.
The Client acknowledges and accepts that:

• The financial institutions used by the Company may not be regulated in the Client’s jurisdiction.
• The Company has no control over the performance, solvency, timing, or operational capacity of such institutions.
• In the event of insolvency, regulatory seizure, operational failure, or force majeure affecting a banking partner, the Company shall not be liable for any resulting loss, delay, or unavailability of funds.

The Company will exercise reasonable care in selecting banking partners but does not guarantee their performance.

In the event of insolvency, operational failure, technical outage, regulatory action, or force majeure affecting any financial institution, correspondent bank, or payment provider holding Client Money, the Client acknowledges that the Company shall not be liable for any loss, unavailability, delay, or partial recovery of funds, and the Client may only have an unsecured claim against such institution.

5.4. Payment Processing and Withdrawal Handling
Deposits and withdrawals may be processed through third-party payment providers. The Company does not guarantee processing times, settlement speeds, or availability of specific payment channels. Withdrawal requests are processed only to payment methods in the Client’s own name, and the Company may request additional documents to verify account ownership or the legitimacy of funds.
If the Client submits a withdrawal request without having engaged in trading activity following the most recent deposit, the Company reserves the right to charge a processing or administrative fee, typically ranging between 3% and 6% of the withdrawal amount, depending on the payment channel used.

5.5. Funds Used as Margin and Exposure Collateral
Upon opening trading positions, the Client’s funds form part of the margin collateral securing open CFD positions. Once funds are used as margin, they are considered exposed to market risk, and losses may reduce the Client’s balance.

5.6. Right to Refuse, Delay, or Review Transactions
The Company may, at its discretion and without obligation to provide justification:

• Delay the execution of deposits or withdrawals
• Request additional verification documents
• Freeze or restrict account access
• Decline or reverse a transaction

where it has reasonable grounds to believe that:

• Funds are linked to fraud, financial crime, evasion, or sanctions breaches
• The transaction originates from or is destined to a high-risk jurisdiction
• The identity or account ownership cannot be verified
• The withdrawal request would result in account insolvency or breach of margin obligations

5.7. Set-Off Rights and Outstanding Obligations
The Company may set-off, deduct, or net any fees, negative balances, or owed amounts from the Client’s Account. If a client account enters a negative balance, the Client remains liable for full repayment unless the Company’s Negative Balance Protection policy explicitly applies.

Negative Balance Protection applies only where explicitly provided in the Company’s product offering and policies. Where Negative Balance Protection does not apply (including but not limited to certain Professional accounts and high-risk strategies), the Client remains fully liable for any resulting negative balance and agrees to repay such amounts upon demand.

5.8. Dormant and Inactive Account Balances
If no activity occurs in the Client account for a continuous period specified in the Company’s policies, the account may be classified as Dormant, and maintenance or administrative fees may apply. If the balance is negligible and unclaimed over a legally permitted timeframe, the Company may transfer the remaining funds to a charitable or administrative allocation at its discretion.

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5.9. Title Transfer Collateral Arrangement

If the Client is classified as a Professional Client or Eligible Counterparty, the Company may treat all or part of the Client’s funds as collateral transferred to the Company for the purpose of securing present or future trading obligations. Under this Title Transfer Collateral Arrangement (TTCA):

• Such funds may not be treated as Client Money under safeguarding rules,
• May not be held in segregated accounts, and
• In the event of Company insolvency, the Client will rank as an unsecured creditor for the value of such collateral.

The Client agrees that they must not deposit funds under Professional classification unless they understand and accept the reduced level of protection described in this section.

6. Deposits, Withdrawals, Fees and Transaction Costs

6.1. Deposits
The Client may deposit funds from the account or wallet that titled by their name into their Account using any method permitted and made available by the Company at the time of the deposit. The Company may update, add, limit, suspend, or remove deposit methods at any time without prior notice, taking into consideration payment system availability, regulatory obligations, risk controls, and liquidity management requirements.

Deposits are credited to the Client’s Account only after the Company, in its sole discretion, is satisfied regarding the legitimacy, origin, and ownership of the funds. The Company may request additional documents before crediting or releasing any deposit.
The Client acknowledges that deposit processing times may vary, and delays may occur due to intermediary bank handling, payment channel verification, system maintenance, or regulatory screening.

6.2. Withdrawals
The Client may request the withdrawal of funds that are not being used to cover current margin obligations, provided that:

• The withdrawal is made to a payment method registered in the Client’s name.
• The Client has submitted all required KYC/AML/EDD documents and passed verification.
• The Company is satisfied regarding the legitimacy of the withdrawal request and the destination of funds.

If a withdrawal request is submitted while there are open trades, the Company may decline or reduce the withdrawal if completing it would place the Account at risk of margin deficiency or liquidation.

6.3. Withdrawal Processing Time
The Company aims to process withdrawal requests within a reasonable timeframe In general 24 business hours, all withdrawal requests are reviewed exclusively during the official operating hours of the Finance Department and the Account Management Team. These hours are Monday through Friday from 09:00 to 17:00, and on weekends (Sunday and Monday) from 09:00 to 14:00. It is hereby clarified that any withdrawal request submitted outside these official hours will automatically be processed on the next business day during operational hours. The involvement of the Technical Department and the Risk Management Unit in verifying transactions may extend the processing time of withdrawal requests.

However, the Client acknowledges that:

• Withdrawal processing time is not guaranteed.
• Additional compliance or banking reviews may extend processing time.
• Intermediary banks, payment processors, or correspondent institutions may impose delays outside the Company’s control.
• The originating wallet and the destination wallet must be identical. In accordance with anti-money-laundering (AML) regulations, all deposits and withdrawals must be made through the same payment source, and the wallet used must be registered under the client’s own name.
• A client who has made a deposit but has not executed any trades shall not be permitted to submit a withdrawal request. In order to become eligible for withdrawal, the client must complete a minimum trading volume of 05 lots. Only after this trading requirement has been fulfilled will the withdrawal request be accepted for processing.

6.4. Right to Request Additional Documentation
For any deposit or withdrawal transaction — irrespective of amount — the Company may require:

• Proof of payment method ownership
• Bank statements or payment account history
• Source of Funds / Source of Wealth documentation
• Additional identity or location verification

If the Client does not fully comply, the Company may freeze, suspend, or terminate the Account and report the activity to relevant authorities if required under Applicable Law.

6.6. No Cash or Third-Party Payments
The Company does not accept or process:

• Cash deposits
• Deposits made by third parties on behalf of the Client
• Withdrawals to third party accounts

Any such attempt may result in account suspension and regulatory reporting.

6.7. Reversals, Chargebacks, and Disputes
If the Client initiates a chargeback, payment dispute, recall request, or reversal, the Company reserves the right to:

• Immediately suspend all trading and withdrawal activity
• Reverse profits derived from disputed or unverified funds
• Recover any negative balance or losses resulting from the payment dispute
• Report the activity to relevant financial institutions, PSP risk networks, and compliance authorities

The Client agrees not to dispute transactions without legitimate basis and acknowledges that improper chargebacks constitute breach of contract and may be pursued as fraudulent conduct under Applicable Law.

6.8 Internal Transfers Between Accounts

6.8.1 The Client may perform internal transfers between their own Trading Accounts held under the same Client Profile without requiring prior approval from the Company, provided that such transfers comply with the Company’s risk management and operational rules.

6.8.2 In cases where an Account is subject to specific restrictions, including but not limited to tournament accounts, promotional bonus accounts, gifted balance accounts, or award-based accounts, the Client must obtain confirmation from their Account Manager before initiating any transfer.

6.8.3 If the Client transfers or attempts to transfer bonus funds, promotional credits, tournament prize balances, or any non-withdrawable credit into another Trading or Wallet Account without meeting the required trading conditions, the Company reserves the right to reverse the transfer, suspend or terminate the Client’s Trading Account(s), and cancel any associated profits derived from such funds.

6.9 Payment Channels, Fees and Withdrawal Conditions

6.9.1 Fees may be charged on deposits or withdrawals depending on the payment method, region, intermediary banking channels, or blockchain network fees, particularly in relation to USDT-based transfers (including but not limited to USDT TRC20, USDT BEP20, and USDT ERC20). The Client acknowledges that blockchain network fees fluctuate and are outside the Company’s control.

6.9.2 Where the Client requests a withdrawal from the Trading Account without any trading activity following the deposit, or where trading activity is considered insufficient, the Company reserves the right to charge a withdrawal processing fee equal to the actual transaction and handling costs incurred by the Company.

7. Trading Terms and Order Execution

7.1. Order Placement and Platform Usage

All trading transactions are initiated by the Client through the electronic trading platform provided by the Company, including MetaTrader 5 (MT5). The platform serves as the Client’s primary interface for placing, modifying, and closing CFD positions. The Client acknowledges that the platform merely provides access to trade execution, and that execution outcomes depend on market conditions, liquidity availability, and the Company’s pricing and routing infrastructure.

7.2. Price Feed Construction and Tick Data Processing

Prices displayed on the platform are derived from the Company’s multi-source liquidity aggregation system, which receives continuous bid/ask quotes from external liquidity providers, prime broker feeds, and electronic market-making entities. Incoming price ticks may undergo:

• Data normalization
• Spread or risk adjustment
• Latency compensation processing
• Filtering of non-executable or stale quotes

The Company publishes only executable pricing, meaning that each displayed price is a live tradable quote subject to liquidity depth and size availability.

7.3. Execution Routing and Order Matching Logic

Upon receipt of an order, the Company determines the execution path based on internal risk models, liquidity availability, and market conditions. The Client acknowledges and agrees that:

1. The Company may internalize the trade (act as counterparty), or
2. The Company may route the trade to its liquidity providers for execution, or
3. The Company may execute the trade through a liquidity aggregation engine, splitting or combining liquidity streams were beneficial.

The Client has no right to request a particular execution venue, routing method, or liquidity provider.

7.4. Market Orders and Slippage Behavior
A market order is executed at the best available price at the time the order reaches the execution system.
The Client acknowledges that:

• Rapid price fluctuations may cause the executed price to differ from the requested price.
• Slippage may occur in either direction (positive or negative).
• Slippage is a normal feature of financial markets and does not constitute improper execution, platform malfunction, or breach of duty.

7.5. Pending Orders (Limit, Stop, Stop-Loss, Take-Profit)

Pending orders are executed only when the quoted price reaches or passes the order’s trigger level.
The Client acknowledges that execution may not occur at the exact trigger price, but rather at the next available executable price, particularly during:

• High volatility periods
• Gaps, news releases, or market openings
• Low liquidity trading sessions

Stop Loss and Take Profit orders are not guaranteed.

7.6. Spread Dynamics and Market Conditions

Spreads are variable and may widen or contract depending on:

• Underlying market liquidity
• News or macroeconomic events
• Venue liquidity fragmentation
• Time-of-day (e.g., rollover or session close)
• Volatility shock or market discontinuity

The Client acknowledges that spread widening may result in position liquidation if Equity falls below the Stop Out Level.

7.7. Platform Availability and Execution Timing

The Company endeavours to maintain platform availability and execution continuity. However, the Client acknowledges that delays or interruptions may occur due to:

• Network conditions outside Company control
• High-volume periods affecting liquidity
• Internet or data routing issues
• Hardware, software, or connectivity failures

Such events do not void trades nor constitute basis for compensation.

7.8. No Guaranteed Execution or Profitability

The Company does not guarantee:

• Immediate execution
• Execution at the requested price
• Profitability of trades
• Protection from losses beyond margin

Trading CFDs is a high-risk activity, and the Client bears all resulting financial outcomes.

7.9 Capacity and Responsibility of the Client

The Client acknowledges and agrees that:

• The Client acknowledges and agrees that they enter all Transactions with the Company as Principal, meaning they act on their own behalf and not as an agent or representative of any third party. Accordingly, the Client shall be fully and solely responsible for all obligations and liabilities arising from their trading activity.
• The Company shall not recognize any other person’s interest in the Client’s Trading Account, regardless of whether the Client has disclosed such interest or whether such person claims rights to funds or positions in the Account, unless the Company has provided its prior express written consent.
• If the Client authorizes any individual or third party (including, but not limited to, an account manager, signal provider, or IB) to place orders or act on their behalf, such authorization shall be deemed valid and binding. The Client remains solely responsible for all instructions, orders, Transactions, or actions taken through their Trading Account until written notice of revocation of such authorization is received and acknowledged by the Company.
• The Company is entitled to rely on and act upon any instruction transmitted through the Client’s Access Credentials (including login, password, API keys, or Trading Platform access tokens) without any obligation to further verify the identity, authority, or authenticity of the person giving such instructions. Any action performed using the Client’s Access Credentials shall be considered as duly authorized by the Client.
• In the event the Client wishes to terminate any authorization previously granted to a third party, the Client must notify the Company in writing. The termination shall become effective only upon the Company’s confirmation. Until such confirmation is issued, all previously granted authorizations remain valid.
• The Client is solely responsible for maintaining the confidentiality and security of their Access Credentials. The Company shall bear no liability for any losses arising from unauthorized or improper access to the Trading Account resulting from the Client’s negligence, disclosure, or failure to protect such credentials.

7.10 Providing Quotes and Pricing Conditions

7.10.1 The Company provides the Client with tradable price quotations (“Quotes”) for all financial instruments available on its trading platforms. Quotes are derived from liquidity providers, pricing aggregators, market data sources, and internal pricing models. The Client acknowledges that the pricing environment in over-the-counter (OTC) products may differ from exchange-traded pricing.

7.10.2 The Company may, at its sole discretion, permit or restrict order execution outside standard market trading hours. The Company is under no obligation to provide pricing or order execution during such periods, and trading conditions may differ, including wider spreads and increased slippage.

7.10.3 The Client is responsible for monitoring trading hours, trading session breaks, market holidays, instrument-specific availability, and schedule changes, as published on the Company’s Website or displayed within the trading platform. The Company shall not be liable for losses arising from the Client’s failure to monitor such schedules.

7.10.4 The Company reserves the right to modify spreads without prior notice, particularly during periods of:

• Low liquidity,
• High volatility,
• Major economic announcements,
• Market open/close transitions,
• Extraordinary or abnormal market conditions.

Spread widening is a normal characteristic of OTC trading and does not constitute improper pricing or malfunction of the trading platform.

7.10.5 The Client acknowledges that chart prices may display only the Bid price, and execution pricing is dependent on the Bid/Ask spread. Accordingly:

• Buy (Long) positions are opened and closed at the Ask price.
• Sell (Short) positions are opened and closed at the Bid price.

7.10.6 Stop Loss and Take Profit activation rules:

• For Buy (Long) positions: Stop Loss and Take Profit are triggered by the Bid price.
• For Sell (Short) positions: Stop Loss and Take Profit are triggered by the Ask price.

The Client acknowledges that differences between Bid and Ask pricing may result in Stop Loss or Take Profit activation even when such price level is not visible on the chart.

7.10.7 The Client understands and accepts that slippage may occur during Market Orders, Pending Orders, Stop Loss, and Take Profit execution, particularly during fast market movement. Slippage may be positive or negative, and orders shall be executed at the best available price at the time they reach the execution venue.

7.10.8 Market data and pricing information provided by the Company is for the Client’s personal trading use only and may not be copied, transmitted, distributed, or disclosed to any third party without the Company’s prior written consent.

7.11 Client’s Requests and Instructions

7.11.1 The Company shall execute Client Orders strictly in accordance with the pricing, execution conditions, and order-processing rules applicable on the Trading Platform at the time the Order is received. The Client acknowledges that all Orders are subject to market conditions, liquidity availability, and margin sufficiency at the time of execution.

7.11.2 The Company may, at its sole discretion, decline, suspend, or delay the processing of any Order if one or more of the following conditions apply:
a) The quoted price was indicative, stale, manifestly erroneous, or no longer available;
b) The Client does not have sufficient Free Margin to support the Order;
c) The Order is placed during market closure, trading suspension, abnormal volatility, or technical interruption;
d) The Company suspects fraud, abuse, scalping behaviour intended to exploit system latency, money laundering, or any prohibited trading activity;
e) A Force Majeure or system failure occurs which prevents timely execution.

7.11.3 Execution prices may differ from prices displayed on charts, due to differences between Bid and Ask pricing, spread fluctuations, execution queue time, and available market liquidity. The Client understands that slippage may occur during periods of volatility and accepts that Orders may be executed at the next best available market price.

7.11.4 For Orders with a size that exceeds Normal Market Volume, the Company may:
a) Fully execute the Order at multiple price levels (partial fills), or
b) Execute the Order only partially, or
c) Decline execution entirely,
in accordance with liquidity conditions in the underlying market. The Company shall not be held liable for any losses arising from such conditions.

7.11.5 The Client acknowledges that chart prices reflect Bid prices only. Buy Orders and Buy-related Stop Loss/Take Profit levels are executed based on the Ask price, while Sell Orders and Sell-related Stop Loss/Take Profit levels are executed based on the Bid price. The fact that a chart price reached a level does not guarantee execution if the corresponding Bid/Ask level has not been met.

7.11.6 The Company reserves the right to remove, cancel, or archive Pending Orders that remain inactive, expired, or untriggered for a prolonged period, in accordance with system performance and data management requirements. The Client will not have a claim for compensation as a result of such removal.

7.11.7 The Company may, for operational efficiency, archive trading history records older than one (1) month in the Trading Platform interface. Such records shall remain accessible to the Client in downloadable form through the Client Portal for no less than the minimum period required under applicable regulatory data retention laws.

7.11.8 The Client is solely responsible for the security and confidentiality of their Access Credentials. Any instruction or Order submitted through the Client’s Trading Account shall be deemed valid and legally binding, regardless of whether the Client personally performed the action.

7.12 Platform Use and Operational Integrity
The Client acknowledges that the Trading Platform provided by the Company is offered on an “as is” and “as available” basis. The Company shall take reasonable measures to maintain the functionality of the platform but does not guarantee uninterrupted operation, execution speed, or constant data availability. The Client is solely responsible for ensuring stable internet connection, functioning devices, and proper system configuration required to access and operate the Platform.

7.13 Protection of Access Credentials
The Client is solely responsible for maintaining the confidentiality and security of all login details, passwords, authentication factors, and account access credentials. The Company shall not be held liable for any loss, damage, or unauthorized trading activity resulting from the Client’s disclosure, sharing, or mishandling of such credentials, including but not limited to allowing IBs, signal providers, third-party traders, acquaintances, or online groups to access the Trading Account.

7.14 Market Data and Indicative Pricing
The Client acknowledges that market data, price quotations, and chart displays on the Trading Platform are indicative and may reflect Bid prices only, while order execution may occur at Ask or Bid prices depending on the nature of the transaction. Due to liquidity variations, volatility, slippage, and execution depth, the displayed price may differ from the actual execution price. Such differences are inherent to OTC and leveraged trading and shall not constitute grounds for dispute or compensation.

7.15 Client Monitoring Responsibility
The Client is required to actively monitor the Trading Account and manage open positions at all times. The Company does not provide account management, portfolio monitoring, trade supervision, or any form of discretionary or advisory trading services. All decisions to open, modify, or close positions are made solely at the Client’s discretion and risk.

7.16 Prohibition of Unauthorized or Abusive Practices
The Client shall not engage in any form of system abuse, platform manipulation, latency arbitrage, quote exploitation, coordinated trading schemes, or any other trading behavior intended to gain unfair advantage over the Company, its liquidity providers, or its technological infrastructure. The Company reserves the right to suspend, restrict, cancel trades, adjust account conditions, or terminate the Trading Account if such behavior is detected.

7.17 Liability for Third-Party Access and Trading
If the Client provides access to the account, intentionally or unintentionally, to any third party, including but not limited to account managers, influencers, EA/robot operators, Telegram/WhatsApp agents, or external signal services, the Client accepts full responsibility for all resulting financial outcomes. The Company shall not be liable for any loss or damage arising from third-party involvement or control.

8. Margin Requirements, Stop-Out Rules, Liquidation Procedure and Leverage

8.1. Margin as a Condition of Trading

When the Client opens a CFD position, a portion of their Account Equity is set aside as Margin, representing collateral required to sustain the exposure. Margin is not a fee or cost; it is a risk security deposit used to absorb losses arising from adverse market movements. The Client understands that the ability to maintain open positions is directly dependent on maintaining sufficient Equity in the Account, and that the Company has the right to close positions if Equity becomes insufficient.

8.2. Margin Calculation and Monitoring

The Client agrees that Margin is calculated continuously based on current market pricing, not on the price at which the position was opened. Therefore, Margin requirements may increase or decrease as market conditions, volatility profiles, or leverage settings change. The Client remains solely responsible for monitoring their Equity and Margin ratios through the trading platform.

To clarify the status of Margin obligations:

1. The Client must maintain Equity above the required Margin at all times.
2. The Company is not required to notify the Client when Margin becomes insufficient.
3. The absence of a Margin Call does not limit the Company’s right to liquidate positions.

8.3. Margin Call and Risk Warning Procedure

A Margin Call occurs when Equity approaches the minimum level required to sustain open positions. The Margin Call level depends on the Client’s account type. The Margin Call serves as a courtesy alert and not as a contractual obligation on the part of the Company. The Client acknowledges that, during fast market conditions, a Margin Call may not occur before liquidation.

8.4. Stop-Out and Automatic Liquidation

If Equity falls to or below the Stop-Out Level, the Company has the immediate and unilateral right to begin closing open positions to protect the Account from further loss. Stop-Out is triggered automatically by the trading platform, without requiring Client approval, communication, or intervention.

The Client understands and expressly agrees that:

1. The Company may liquidate one or several positions, in whole or in part.
2. The Company may choose which positions to close first, typically those with the largest loss exposure or highest margin consumption.
3. Liquidation is executed at the next available price, which may differ from displayed or requested prices.
4. The Client may incur losses faster than platform displays update in volatile markets.

8.5. Sequencing of Liquidation

The Company’s liquidation process is designed to reduce total exposure and prevent further negative balance, and is generally performed in the following operational sequence:

• Reduction of largest loss-bearing positions first;
• Reduction of positions consuming the highest margin;
• Full liquidation of the Account if Equity continues to fall after partial reduction.

This sequence is procedural, not guaranteed or required by contract. The Company may alter liquidation ordering based on liquidity, volatility, system load, or other execution conditions.

8.6. Negative Balance and Client Liability

The Client acknowledges that, under certain market conditions (including but not limited to gaps, slippage, and illiquidity), Stop-Out may not prevent the Account from falling into a negative balance. Unless the Client qualifies for and falls under the Company’s Negative Balance Protection Policy, the Client shall be fully responsible for repaying the negative balance owed to the Company.

8.7. No Obligation to Reimburse Losses

The Company does not compensate the Client for losses incurred as a result of Stop-Out, spread widening, slippage, latency, news events, liquidity gaps, or execution delays. These are inherent characteristics of leveraged OTC derivatives trading, and the Client accepts such risks as part of entering CFD transactions with the Company.

8.8 Margin Calculation Currency

The Client acknowledges that all Margin, Equity, Balance and Profit/Loss calculations are performed in the Base Currency of the Trading Account. Where financial values are denominated in a different currency, the Company shall convert such values into the Trading Account’s Base Currency at the applicable exchange rate determined by the Company or its Liquidity Providers at the time of calculation.

8.9 Prohibition on Pledging Margin

The Client agrees that any Margin or funds deposited in the Trading Account may not be pledged, assigned, or used as collateral to any third party. Such funds are solely dedicated to supporting and maintaining open positions and obligations arising under this Agreement.

8.10 Automatic Leverage and Margin Adjustments

The Client acknowledges that the Company may, at its sole discretion, adjust Leverage levels and Margin Requirements without prior notice in situations including, but not limited to:

• High market volatility
• Major economic news events
• Weekends and public holidays
• Market gaps or low-liquidity sessions
• Sudden increases in trading exposure or account risk

These adjustments may apply to both new and existing open positions, and the Client is responsible for ensuring sufficient funds are available to maintain open positions.

8.11 Stop Out and Risk Control

If the Client’s Equity falls below the Stop Out threshold defined in the Contract Specifications, the Company is entitled to automatically liquidate open positions, partially or in full, without prior notice, in order to protect the Trading Account from further losses. The Client understands that Margin Calls are not guaranteed, and the responsibility to monitor the Trading Account rests solely with the Client.

8.12 Protection Against High-Risk Trading Practices

The Company reserves the right to restrict, suspend, or close trading activity where the Client engages in trading practices considered high-risk or abusive, including but not limited to:

• Latency arbitrage
• News-event scalping with high leverage
• Price feed manipulation
• Systematic exploitation of slippage or execution delays

Such measures may include modification of leverage, restriction of instruments, trade cancellation, or account closure, as deemed necessary by the Company’s risk management policies.

8.13 Leverage Adjustment Policy

8.13.1 General Provisions
The Client acknowledges and agrees that the Company reserves the right, at its sole discretion, to adjust the Leverage and/or Margin Requirements applicable to the Client’s Trading Account and to any specific financial instrument at any time. Such adjustments may apply to both new orders and existing open positions without prior notice, in accordance with the Company’s risk management framework and market conditions.

8.13.2 Circumstances Under Which Leverage May Be Adjusted
The Company may adjust Leverage and Margin Requirements under, but not limited to, the following circumstances:

1. a) High-Volatility Market Conditions, including economic data releases, monetary policy announcements, geopolitical events, and extraordinary market movements.
   b) Low Liquidity Periods, including weekends, market holidays, trading session gaps, or extended market closures.
   c) Product-Specific Volatility, particularly affecting high-risk instruments such as precious metals (e.g., Gold), cryptocurrencies, and certain indices.
   d) High Exposure or Position Concentration, where the Client’s open volumes or trading behavior increases the risk profile of the Account.
   e) Risk of Negative Equity, or where the Company identifies elevated probability of loss exceeding Account balance.
   f) Force Majeure or abnormal market conditions as defined in this Agreement.

8.13.3 Automatic Tiered Leverage Adjustment Based on Exposure
The Company may implement tier-based leverage scaling, whereby higher trade volumes or aggregate exposure result in lower effective leverage. The applicable tiers may vary across instruments and are defined in the Contract Specifications published on the Company’s Website.

8.13.4 Effect of Leverage Adjustment on Margin Requirements
Where Leverage is reduced, the required Margin for maintaining open positions increases automatically. The Client is solely responsible for ensuring that sufficient funds are available in the Account to support all open positions at all times. The Company shall not be liable for any losses, liquidation, or Stop Out resulting from leverage changes.

8.13.5 No Obligation to Provide Prior Notice
The Company is not obliged to notify the Client in advance of Leverage adjustments. Any Leverage modification shall be considered effective immediately, and the Client acknowledges that monitoring Margin and Equity levels is their exclusive responsibility.

8.13.6 Stop Out and Position Liquidation
If, following a Leverage adjustment, the Client’s Equity falls below the Stop Out level specified in the Contract Specifications, the Company is entitled to automatically close open positions, partially or in full, without prior notice or consent, in order to protect both the Client and the Company from further financial exposure.

8.13.7 Prohibition of Claims and Liability
The Client understands and agrees that no claims, compensation demands, or disputes shall be accepted for losses, forced liquidation, or trading limitations arising due to:

• Leverage reductions
• Increased Margin Requirements
• Slippage or spread widening associated with volatility
• Stop Out events triggered during or after leverage adjustments

The Client accepts full responsibility for managing trading risk under dynamic leverage conditions.

8.13.8 Publication and Transparency
Information regarding instrument-specific Margin Requirements, Stop Out levels, and applicable leverage tiers shall be made available in the Contract Specifications on the Company’s Website. It is the Client’s responsibility to review such specifications regularly.

9. Fees, Commissions, Swaps and Account Costs

9.1. General Fee Structure

The Client acknowledges that trading CFDs involves certain costs, including but not limited to spreads, commissions, overnight financing charges (swaps), conversion fees, administrative charges as specified in the Contract Specifications, which are published on the Company’s Website. The Client is responsible for reviewing these costs prior to engaging in any trading activity. These costs are part of the normal commercial structure of derivative instruments and arise from liquidity sourcing, trade execution, and risk management operations performed by the Company.

The Company reserves the right, at its sole discretion, to amend, modify, or update the commissions, spreads, swap rates, margin requirements, or any other fees at any time. Any such changes will be deemed effective upon publication on the Company’s Website and such publication shall constitute due notice to the Client.

9.2. Spreads

The Company quotes floating (variable) spreads. Spread levels depend on market conditions, liquidity depth, volatility, trading session, and the Client’s account type. Spreads may widen significantly during:

• Market openings/closures,
• High-impact news events,
• Low liquidity periods,
• Systemic market stress.

The Client understands that spread widening may affect Equity and may contribute to triggering Margin Call or Stop-Out events.

9.3. Commissions

For account types in which commissions are applicable (e.g., ECN, ECN Pro), the commission is charged per transaction based on total trade volume. Commissions are automatically debited from the Account at the time the position is opened and/or closed as specified in the Account specifications available on the Platform.

9.4. Swap / Overnight Financing

CFD positions held beyond daily market rollover time are subject to financing adjustments (known as Swap or Overnight Rollover). Swaps may be positive (credited) or negative (debited), depending on:

• The direction of the trade (long/short),
• The interest rate differential or cost-of-carry of the underlying market,
• Liquidity and rollover conditions at the time of calculation.

The Client acknowledges that swap rates are not fixed, may change daily without notice, and may differ from publicly published interest rate references due to liquidity and risk conditions in OTC swap markets.

9.5. Swap-Free / Islamic Accounts

If the Client is approved for a swap-free (Islamic) account, positions may be exempt from standard swap charges. However, the Company may apply administrative financing adjustments on positions held for multiple days to prevent misuse of swap-free conditions for arbitrage, interest rate carries strategies, or long-term rollover advantage. The Client acknowledges that swap-free accounts are not free of cost and may incur alternative sustainable fees.

9.6. Inactivity Fees

Where the Client’s Trading Account has no trading activity for a continuous period of six (6) months, the Company may apply an inactivity maintenance fee of up to 5 USD (or equivalent) per month, which will be deducted from the Client’s Trading Account balance until the account is reactivated or reaches a zero balance.

In the event the Client requests a withdrawal from the Trading Account without any trading activity following the deposit, the Company reserves the right to charge a withdrawal processing fee equal to the actual transaction costs incurred by the Company.

9.7. Currency Conversion

If the Client transacts in a currency different from their Account base currency, the Company may apply a conversion adjustment at a commercially reasonable market rate. Conversion spreads are applied to cover settlement and liquidity sourcing costs.

9.8. Fee Disclosure and Updates

All fees applicable to the Client are defined in the trading conditions and Account specification documents accessible on the Platform and the Company website. The Company reserves the right to modify fees, spreads, commissions, or financing charges at any time to reflect changes in liquidity conditions, market structure, or operational expenditure.

To clarify the nature of fee adjustments:

1. Fee changes do not require prior notice when market-driven.
2. The Client is responsible for reviewing applicable fees on an ongoing basis.
3. Fee changes do not affect trades already closed; they apply prospectively.

9.9. No Refunds

Fees charged for executed transactions, account administration, withdrawal processing, or financing adjustments are non-refundable, unless required by Applicable Law.

9.10. IB, Affiliate or Partner fee

Where the Client has been introduced to the Company through an Affiliate, IB, or Partner, the Client acknowledges that such third party may receive compensation from the Company based on the Client’s trading activity. This compensation does not result in any additional fee charged to the Client. Further details may be provided upon written request.

The Client is solely responsible for any tax obligations, reporting requirements, or governmental charges arising from their trading activity. The Company does not provide tax advice and shall not be responsible for calculating or withholding taxes on behalf of the Client.

9.11 Prohibition of Artificial Turnover / Wash Trading

The creation, facilitation, or attempted creation of artificial, non-genuine, or manipulative trading volume for the purpose of generating IB commissions is strictly prohibited. This includes, but is not limited to:

1. Opening or closing transactions with abnormal or non-economic trade volumes without a genuine trading intention;
2. Any prearranged coordination between the IB and its clients, sub-affiliates, or related accounts for the purpose of producing artificial turnover or commission cycling;
3. Executing trades that lack reasonable risk management, or trades that do not pursue legitimate profit/loss objectives, and instead serve solely to inflate trading activity;
4. Any other conduct or trading pattern that the Broker’s Monitoring, Risk, or Compliance Department determines, in its sole discretion, to constitute artificial turnover, wash trading, self-trading, or volume manipulation.

Such activities constitute a material breach of this Agreement.

9.11.1 Broker’s Rights and Enforcement Measures

Upon detection or reasonable suspicion of such activity, the Broker reserves the unrestricted right to:

1. Void, cancel, reclaim, or refuse to pay any IB commissions, rebates, or other remuneration—whether already paid or pending;
2. Suspend, deactivate, or permanently terminate the IB account without prior notice;
3. Remove any directly or indirectly related trading accounts from the IB partnership program;
4. Exclude any suspicious trades from being considered eligible for rebate or commission;
5. Freeze or restrict accounts where necessary to conduct internal investigations, in accordance with applicable anti-fraud, AML, and compliance obligations.

9.11.2 Final Determination

The final and binding determination as to whether any trading activity constitutes artificial turnover shall rest solely with the Broker’s Risk Management and Compliance Department. By entering into this Agreement, the IB expressly acknowledges, accepts, and agrees to be bound by this discretionary authority.

10. Market Abuse and Prohibited Trading Policy

10.1. Purpose and Scope
The Client acknowledges and agrees that all trading services offered by the Company are provided on an over-the-counter (OTC) basis, where pricing, liquidity, and execution conditions are determined by the Company’s internal pricing architecture and liquidity framework. Accordingly, the integrity, fairness, and stability of the trading environment must be maintained at all times.

The Client undertakes to act in good faith, observe fair dealing, and refrain from any behavior that constitutes market abuse, illicit advantage, or any prohibited trading practice, whether executed directly, indirectly, manually, through automated systems, or via third parties.

This Policy forms an integral and fully enforceable part of the Client Agreement and applies to all accounts, platforms, instruments, orders, and trading activities under the Client’s control or influence.

10.2. Definition of Market Abuse

Market Abuse refers to any act, pattern, or trading behavior that seeks to:

• Manipulate normal price formation,
• Create artificial or misleading market conditions,
• Exploit system, pricing, or execution inefficiencies,
• Obtain unfair or risk-free financial advantage, or
• Violate applicable financial conduct or anti-manipulation regulations.

Examples include, without limitation:

1. Trading based on non-public or insider information;
2. Unauthorized disclosure or dissemination of confidential market data;
3. Manipulative practices intended to influence market price or liquidity;
4. Coordinated, staged, or synchronized trading activity across one or more accounts;
5. Entering offsetting or circular transactions to create false volume, artificial price behavior, or remove economic risk.

The Client is responsible for understanding and complying with all applicable anti-market-abuse laws in their jurisdiction.

10.3. Prohibited Trading Practices

The following activities are strictly prohibited and constitute a serious breach of this Agreement:

1. Exploitation of Technical Latency or Price Delay
   Any attempt to benefit from pricing delays, execution lags, feed desynchronization, or temporary quotation irregularities for the purpose of extracting risk-free or guaranteed profit is prohibited and constitutes abusive arbitrage.
2. Risk-Free Hedging and Opposing Position Structures
   Opening long and short positions simultaneously within the same instrument or across multiple accounts (whether owned or coordinated) for the purpose of removing economic exposure, offsetting loss, or transferring equity is prohibited.
3. Aggressive High-Frequency Scalping for System Exploitation
   Opening and closing positions in rapid succession solely to exploit system latency, liquidity refresh cycles, or internal pricing thresholds is not permitted.
4. Abuse of Swap-Free / Islamic Accounts
   Swap-free accounts exist exclusively for clients who qualify on religious grounds. Using such accounts to avoid financing costs or obtain interest-related advantage is prohibited.
   If misuse is identified, the Company may:

• Remove swap-free status,
• Recalculate and debit historical swaps,
• Withdraw profits obtained through misuse,
• Restrict, suspend, or terminate the Account.

5. Manipulation or Interference with Trading Infrastructure
   Attempting to alter, reverse-engineer, disrupt, overload, or otherwise interfere with platform, price feed, API, server, or trading infrastructure is prohibited.
6. Concealment of Identity, Residency, or Jurisdiction
   Use of VPN, proxy, VPS, or technical routing is permitted only when not intended to conceal identity or circumvent regulatory, residency, or compliance restrictions.
7. Abuse of Bonuses, Credits, or Promotional Programs
   Unfair use of promotional credits, including transferring bonus value across accounts or structuring trading solely to withdraw promotional value, is prohibited. The Company may remove bonuses and any profits derived from them.

10.4. OTC Structure Acknowledgment

The Client acknowledges that prices quoted by the Company are proprietary and derived from the Company’s liquidity and risk management systems.
Attempting to profit from price differences between brokers, data vendors, or execution venues is not a legitimate trading strategy and is prohibited.

10.5. Monitoring and Investigation

The Company continuously monitors trading behavior, order flow patterns, device identifiers, network signatures, and account linkages to detect prohibited activity.
The Company’s determination of abuse is final, does not require proof of intent, and is binding.

10.6. Remedial Measures and Enforcement

Upon reasonable suspicion or confirmation of prohibited activity, the Company may, without prior notice, take one or more of the following actions:

• Close or void open and closed trades,
• Adjust executed prices to reflect fair market rates,
• Remove profits or credits obtained through abuse,
• Reapply swaps and financing charges retroactively,
• Modify leverage, margin requirements, or trading conditions,
• Limit, suspend, or permanently close the Account,
• Freeze or delay withdrawals,
• Offset damages using funds in the Account,
• Report activity to regulatory or legal authorities.

All such decisions are final, immediately enforceable, and not subject to appeal.

10.7. Client Confirmation

By continuing to use the Company’s trading services, the Client acknowledges that they:

• Have read and understand this Policy,
• Accept full responsibility for compliance,
• Understand that violations may result in immediate Account suspension, closure, or legal action.

11. Conflicts of Interest and Best Execution Framework

11.1. Nature of Conflicts in OTC Trading

The Client acknowledges that, due to the structure of over-the-counter (“OTC”) derivatives markets and the Company’s role as the contractual counterparty to Client trades, certain conflicts of interest may arise between the Client and the Company. Such conflicts are inherent to all principal-based OTC trading systems where the service provider executes trades for its own account while simultaneously providing execution services to clients.

The existence of such conflicts does not imply improper conduct. However, it is essential that the Client understands the framework under which the Company manages and mitigates these conflicts in accordance with international standards of fair dealing and operational transparency.

11.2. Execution as Principal, Not Agent

When the Client enters into a CFD trade, the Company acts as principal, not as agent or fiduciary. This means the Company is the direct counterparty to the Client’s transaction. The Client does not trade directly with interbank liquidity venues, exchanges, or institutional markets.

This structure enables:

• Continuous pricing and liquidity provision, even in fast or fragmented markets
• Immediate order execution without requiring third-party order routing approval
• Internal hedging and risk-management flexibility to maintain orderly markets

11.3. Pricing and Best Execution Commitment

The Company maintains a pricing and execution environment that is designed to provide fair, tradable, and competitive prices consistent with prevailing market liquidity conditions. The Company does not guarantee the best price available in the market at any moment, but commits to executing Client orders at the best available price provided by its liquidity feed at the time of execution, subject to liquidity depth, volatility, speed of price movement, and order type.

11.4. Managing Conflicts of Interest

The Company employs a range of operational, technological, and supervisory controls to ensure that Client interests are treated fairly and that conflicts are prevented or minimized. These include:

1. Independent liquidity sourcing from multiple suppliers to avoid unilateral price dependency.
2. Pre-trade and post-trade monitoring to ensure pricing consistency and execution fairness.
3. Segregation of duties between risk management, dealing, and client relationship functions.
4. Restrictions on employee trading to prevent misuse of confidential information.
5. Periodic review of execution quality, slippage patterns, and pricing distribution.

These measures are designed to maintain a trading environment in which pricing and execution outcomes are consistent with professional OTC market practices.

11.5. No Duty to Advise or Act in the Client’s Best Interest

The Company does not provide investment advice or portfolio recommendations. Any communication regarding market conditions, trade ideas, or general information is not tailored to the Client’s personal circumstances and does not constitute advice.
The Client remains solely responsible for all trading decisions and the assessment of risks associated with trading CFDs.

11.6. Client Acknowledgment of Risk and Independence

By entering into this Agreement, the Client confirms that they:

• Understand the structural nature of OTC CFD trading
• Accept that the Company may act as counterparty to their transactions
• Agree that the Company is not required to act in the Client’s best interest
• Understand that execution outcomes depend on market conditions and liquidity

This acknowledgment forms an essential basis of the trading relationship.

11.7 Conflicts of Interest

The Client acknowledges and accepts that conflicts of interest may arise in the course of the Company’s business. Such conflicts may occur when the Company, its directors, employees, affiliates, service providers, or other Clients have interests that may compete with or differ from the interests of the Client.

Situations in which a conflict of interest may arise include, without limitation:

1. The Company acting as Principal to the Client’s Transactions;
2. The Company maintaining positions in the same financial instruments as those traded by the Client;
3. The Company executing Transactions for other Clients whose interests may conflict with the Client’s interests;
4. The Company receiving remuneration, rebates, or other benefits from liquidity providers or third parties in connection with the execution of Client Transactions.

The Company may execute Transactions either on its own account or on behalf of other Clients and may match the Client’s Transactions with those of another Client. The Client accepts that such arrangements do not of themselves constitute unfair treatment and form part of the ordinary operation of the over-the-counter (OTC) trading environment.

The Company shall ensure that its employees and representatives act independently and conduct themselves with integrity and shall not allow personal or financial interests to improperly influence the handling of Client instructions or the performance of its duties. Any market commentary, research materials, analytical reports, trading suggestions, or other informational content provided by the Company are:

1. Intended for general information purposes only.
2. Not to be considered personal investment advice or recommendations.
3. Provided without guarantee of accuracy, completeness, or timeliness;
4. Used by the Client at their own discretion and risk, without liability to the Company.

12. Liability, Indemnity, Force Majeure and Limitation of Claims

12.1. No Liability for Trading Losses
The Client acknowledges that all trading performed under this Agreement is undertaken at the Client’s own risk. The Company shall not be liable for any losses, damages, or claims arising from the Client’s trading decisions, market movements, price volatility, margin calls, stop-outs, or the closing of positions, whether manually or automatically.
Trading CFDs involves the risk of losing the entire investment. The Company provides execution, not advice, and therefore assumes no responsibility for the financial consequences of the Client’s actions.

12.2. No Liability for Platform or Connectivity Interruptions
The Company shall not be responsible for delays, interruptions, errors, or failures in the operation of the trading platform or related systems when such issues arise from factors outside the Company’s direct control, including but not limited to:

• Internet connectivity failures on the Client’s side,
• Device, hardware, software, or network malfunctions,
• Third-party hosting, infrastructure, or data transmission issues,
• Telecommunication outages or global routing disruptions.

Where reasonably possible, the Company will use commercially appropriate measures to restore platform functionality, but execution outcomes during such periods cannot be guaranteed.

12.3. Price Feed, Market Data, and Latency Disclaimer
The Client acknowledges that pricing, market data, charts, and order books displayed on the Platform may differ from pricing or data available on other brokers, liquidity venues, or trading platforms. The Company does not guarantee continuous, error-free, synchronized, or delay-free price display.
The Company’s quoted price is the official and binding execution price, regardless of external comparisons.

12.4. Indemnification
The Client agrees to indemnify and hold the Company harmless from all claims, damages, liabilities, losses, costs, and expenses (including legal fees) arising out of:

1. The Client’s breach of this Agreement,
2. Provision of false, misleading, or incomplete information,
3. Unauthorized or improper use of the trading platform,
4. Violation of Applicable Law,
5. Third-party claims made as a result of the Client’s actions.

This indemnity survives termination of the Agreement.

12.5. Force Majeure Events
The Company shall not be liable for any delay, failure, or inability to fulfill its obligations under this Agreement due to circumstances beyond its reasonable control, including but not limited to:

• Market suspension or exchange disruption,
• War, terrorism, geopolitical instability, or civil disturbance,
• Natural disasters or catastrophic events,
• Government intervention, sanctions, or regulatory directives,
• Banking system failures or liquidity crises.

During such events, the Company may suspend trading, restrict execution, refuse orders, adjust pricing, or close positions if necessary to preserve orderly market conditions.

12.6. Limitation of Claims and Remedies
The Client agrees that, to the fullest extent permitted by Applicable Law:

• The Company’s total liability to the Client shall not exceed the total amount of funds deposited and remaining in the Client’s Account at the time the claim is made.
• The Company shall not be liable for indirect, incidental, consequential, special, punitive, or exemplary damages, including lost profits, loss of opportunity, or reputational harm.

This limitation applies regardless of the claim cause or legal theory asserted.

13. Termination, Account Closure and Contract Survival

13.1. Right to Terminate by the Company
The Company may, at its sole discretion and without obligation to provide a reason, suspend, restrict, or terminate the Client’s Account and this Agreement at any time where it considers such action necessary to protect its commercial, regulatory, operational, or reputational interests. Such termination may take effect immediately and without prior notice where required for legal compliance, risk mitigation, or preservation of market integrity.

13.2. Grounds for Immediate Termination
Without limiting the Company’s general right to terminate, the Company may close the Account immediately in circumstances that include, but are not limited to:

• Suspicion or confirmation of prohibited, abusive, or manipulative trading activity;
• Failure to comply with KYC/AML/EDD verification requirements;
• Submission of false, misleading, or fraudulent documents;
• Chargeback, payment recall, or withdrawal dispute attempts;
• Operating multiple accounts to circumvent trading rules or risk controls;
• Violation of Applicable Law or sanctions restrictions;
• Internal or external regulatory request requiring account closure.

Termination under this clause may occur without prior notification to the Client where circumstances require urgent action.

13.3. Effect of Termination
Upon termination:

1. All open positions may be closed at the prevailing execution price at the time of termination.
2. All pending orders will be cancelled.
3. All withdrawal requests may be subject to full compliance review prior to release of any remaining balance.
4. The Company may hold funds if required to comply with legal, regulatory, or financial investigation procedures;
5. Any negative balance remains immediately due and payable by the Client.

13.4. Client’s Right to Terminate
The Client may terminate this Agreement by submitting a written request to the Company, provided that:

• All open positions are closed;
• All outstanding obligations, including fees and negative balances, are settled;
• Required identity and withdrawal verification documentation is provided.

Account closure requests are processed once all compliance obligations are satisfied.

13.5. Dormant and Inactive Accounts
If an Account remains inactive for a continuous period specified by the Company’s policies, it may be classified as Dormant. Dormant accounts may be suspended or closed, and maintenance fees may apply.
If funds remain unclaimed after a legally permitted period, the Company may take action consistent with applicable unclaimed property regulations.

13.6. Survival of Terms After Termination
Termination of this Agreement does not affect the validity of clauses relating to:

• Liability and indemnity (Section 12),
• Prohibited trading and enforcement rights (Section 10),
• Settlement of financial obligations,
• Dispute resolution and jurisdiction,
• Any rights accrued prior to termination.

These clauses remain legally enforceable even after the Account is closed.

13.7 Amendment and Termination

13.7.1 Right to Amend Terms
The Client acknowledges and agrees that the Company may, at its sole discretion and at any time, modify, update, revise, or replace any part of this Agreement, the Contract Specifications, fees, trading conditions, or any other policies governing the relationship between the Client and the Company. Such amendments may be made in response to regulatory obligations, risk management considerations, market conditions, operational requirements, or business judgment.

13.7.2 Method of Notification
Any amendment or change to this Agreement shall be considered valid and binding upon being published on the Company’s Website or communicated through the Client Portal, Trading Platform notifications, or via email to the Client’s registered email address. The Company is not required to obtain the Client’s signature or explicit consent for amendments.

13.7.3 Acceptance of Updated Terms
Continued access to or use of the Trading Account, Trading Platform, or any of the Company’s services after the effective date of an amendment shall constitute the Client’s full and unconditional acceptance of the updated terms. If the Client does not agree to the revised terms, the Client must immediately discontinue use of the Company’s Services and request account closure.

13.7.4 Client’s Right to Terminate
The Client may request to terminate the Trading Account and relationship with the Company at any time by submitting written notice through the official withdrawal and account closure request procedures. Prior to termination, the Client must:
a) Close all open positions
b) Settle any outstanding obligations or negative balances
c) Submit any required compliance documents
Only after these conditions are fulfilled will the Company process the release of any remaining real funds.

13.7.5 Company’s Right to Suspend or Terminate
The Company reserves the right, at its sole discretion, to suspend, restrict, or permanently terminate the Client’s Trading Account without prior notice, if:
a) The Client breaches this Agreement or any operational policy
b) Fraud, chargeback, identity mismatch, or AML concerns are identified
c) Trading activity is deemed abusive or manipulative
d) The Client engages in prohibited strategies (e.g., latency arbitrage, quote manipulation, promotional abuse)
e) The Company is required to act under legal, regulatory, or risk-management directives

13.7.6 Effect of Termination on Funds and Account Balance
Upon termination, any non-withdrawable balances, including but not limited to promotional credits, tournament prizes, bonus funds, or any profit derived directly from such credits, shall be cancelled. The Client shall only be entitled to withdraw verified, real deposited funds and eligible realized profits remaining after all compliance and security checks are completed.

13.7.7 Post-Termination Obligations
All rights, responsibilities, indemnity protections, and outstanding financial obligations outlined in this Agreement shall survive the termination of the Client’s Account. Account closure does not release the Client from liability related to fraud, chargebacks, regulatory breaches, or financial damage caused to the Company.

14. Governing Law and Jurisdiction

14.1. Governing Law
This Agreement, and all rights, obligations, transactions, and legal relationships between the Client and the Company, shall be governed by and construed in accordance with the laws of Saint Lucia, as applicable to international commercial contracts. The Client acknowledges that the Company is incorporated and operates legally under the International Business Companies Act of Saint Lucia, and that this legal framework shall apply regardless of the Client’s country of residence or the location from which the trading platform is accessed.

14.2. International Commercial Interpretation
In addition to the laws of Saint Lucia, the interpretation and enforcement of this Agreement shall be guided by generally accepted principles of international commercial law, including relevant standards of fairness, contractual performance, and dispute resolution derived from recognized international legal doctrine (including but not limited to UNCITRAL principles).

This provision ensures the Agreement remains globally enforceable and consistent with the commercial norms of cross-border OTC financial services.

14.3. Jurisdiction and Venue
The Client agrees that any dispute, claim, or controversy arising from or in connection with this Agreement shall be subject to the exclusive jurisdiction of the competent courts of Saint Lucia, unless the Company elects, at its sole discretion, to bring proceedings in another court of competent jurisdiction where the Client resides or where enforcement is sought.

This means:

• The Company may choose the legal venue that provides the most efficient or effective enforcement.
• The Client may not unilaterally choose an alternative venue.

14.4. Right of International Enforcement
The Company retains the right to initiate enforcement, collection, or injunctive proceedings in any jurisdiction where the Client may have assets, banking relationships, residence ties, or commercial activities. The Client agrees to fully cooperate with any such enforcement process.

14.5. Language
This Agreement is drafted in English. If translated into another language, the English version shall prevail in all legal and interpretive matters.

15. Risk Disclosure Statement

15.1. General Trading Risk
The Client acknowledges that trading Contracts for Difference (CFDs) is highly speculative and involves a significant risk of financial loss. CFDs are leveraged instruments, meaning that a relatively small movement in the price of the underlying asset can result in disproportionately large gains or losses. The Client understands that it is possible to lose the entire amount deposited into the trading Account.

15.2. No Guarantee of Profit
The Company does not guarantee the performance of any trade or trading strategy. Past performance of financial instruments, markets, or trading strategies does not indicate or guarantee future results. The Client makes all trading decisions independently and bears full responsibility for the outcomes.

15.3. Leverage Risk
Leverage can magnify market exposure. While leverage may increase potential profit, it also increases potential loss, including losses that may exceed the initial invested capital. The Client must carefully assess leverage settings and understands that high leverage significantly increases the probability of margin calls and stop-outs.

15.4. Market Volatility and Price Gaps
Prices of financial instruments may fluctuate rapidly due to market conditions, news releases, economic events, or liquidity changes. Such price movements may cause orders (including Stop Loss) to execute at a price less favorable than the level specified by the Client (known as slippage). Price gaps or discontinuities may also occur during market closure or reduced liquidity periods.

15.5. No Ownership of Underlying Assets
The Client acknowledges that CFD trading does not involve the acquisition of the underlying asset. The Client does not receive shareholder rights, dividend rights, commodity delivery, or any ownership interest when trading CFDs.

15.6. Technical and System Risk
Trading through an electronic platform involves risks related to connectivity, latency, hardware failure, software malfunction, or communication delays. The Company is not liable for losses arising from such issues when they are outside the Company’s reasonable control.

15.7. Regulatory and Jurisdictional Risk
Financial regulations may change at any time, which may affect trading conditions, margin requirements, or the availability of certain instruments. The Client is responsible for understanding and complying with any restrictions applicable in their jurisdiction.

15.8. Suitability
CFDs are not suitable for all investors. The Client confirms that they have evaluated their financial situation, investment objectives, level of experience, and risk tolerance. The Client further confirms that they can bear the risk of losing their entire investment.

16. LIMITATIONS OF LIABILITY AND INDEMNITY

16.1 General Trading Risk Acknowledgment
The Client acknowledges and accepts that trading leveraged financial instruments including, but not limited to, Forex, Commodities, Indices, Cryptocurrencies, and CFDs involves a high level of risk and may result in the partial or total loss of the Client’s invested capital. The Client confirms that they voluntarily engage in trading and assumes full responsibility for the risks associated with such activity.

16.2 No Guarantees of Profit or Performance
The Company does not guarantee, represent, or warrant any trading performance, profit generation, execution outcome, or investment success. Past performance, market commentary, analysis, educational materials, or signals do not constitute investment advice or a promise of future results.

16.3 No Liability for Client’s Trading Decisions
All trading decisions made through the Client’s Trading Account are executed solely at the discretion of the Client. The Company shall bear no responsibility for any losses incurred due to the Client’s trading choices, strategies, emotional decisions, or reliance on third-party advice.

16.4 Market Conditions, Slippage, and Execution Variability
The Client understands that order execution may be influenced by market volatility, liquidity fluctuations, platform load, network delays, or price gaps. Orders may execute at the best available market price, which may differ from the requested price (slippage). Such occurrences are inherent to trading and do not constitute grounds for compensation, refunds, or cancellation of executed trades.

16.5 Client-Side Technical Failures
The Company shall not be held liable for losses resulting from the Client’s device malfunction, network instability, internet interruption, software failure, power outage, negligent trading setup, or improper use of trading tools, including but not limited to Expert Advisors, signal systems, or external automation tools.

16.6 Third-Party Recommendations, Signals, and Account Management
If the Client relies on any third-party signal provider, account manager, influencer, IB, advisor, or any other intermediary, whether compensated or not, the Client acknowledges that such third parties operate independently and are not agents or representatives of the Company. The Company is not responsible for the actions, advice, performance, or losses resulting from third-party involvement.

16.7 Platform Availability and Maintenance
The Company will make reasonable efforts to maintain operational functionality of the Trading Platforms. However, the Company shall not be liable for temporary service interruptions, scheduled or emergency maintenance, server delays, data transmission failures, or disruptions arising from Force Majeure conditions.

16.8 Limitation of Liability
To the fullest extent permitted by law, the Company’s liability to the Client shall be strictly limited to the actual amount of funds deposited and held in the Client’s Trading Account(s) at the time of claim. The Company shall not be liable for any indirect, incidental, special, consequential, punitive, reputational, or opportunity losses, including but not limited to loss of profit, trading time, market opportunity, or emotional damages.

16.9 Client’s Duty to Indemnify the Company
The Client agrees to indemnify, protect, and hold harmless the Company, its directors, employees, partners, service providers, and affiliates against any claims, damages, penalties, legal fees, chargeback costs, regulatory fines, or financial losses arising from:

1. a) Client breach of this Agreement or Company policies
   b) Use of fraudulent or unauthorized payment instruments
   c) Attempted abuse of bonuses, promotions, tournaments, or reward programs
   d) False claims, chargebacks, or dispute manipulation
   e) Violations of AML/Compliance requirements
   f) Any activity intended to harm the Company’s operations, reputation, systems, or regulatory standing

16.10 Survival of Indemnity and Limitation Rights
All obligations under this Section survive the termination of the Client’s Account and this Agreement. Closure of the Trading Account does not release the Client from financial, legal, or indemnity responsibilities.

17. COMMUNICATIONS AND WRITTEN NOTICE

17.1 Official Communication Channels
The Client acknowledges and agrees that all communications between the Client and the Company shall be conducted through the official contact methods designated by the Company, which may include:
a) Email correspondence to and from the Client’s registered email address
b) Notifications and messages delivered within the Client Portal
c) Notifications transmitted via the Trading Platform
d) Announcements published on the Company’s Website

Communications through informal channels (including but not limited to social media, messaging apps, or personal conversations) shall not be considered official and may not be acted upon by the Company.

17.2 Validity of Email and Digital Communications
Any written notice or communication sent by the Company to the Client’s registered email address shall be deemed delivered and received at the time of sending, regardless of whether the message is read, opened, blocked, filtered, misplaced, or deleted by the Client. The Client is solely responsible for ensuring ongoing access to and monitoring of their registered email account.

17.3 Client’s Duty to Maintain Accurate Contact Information
The Client agrees to maintain accurate, up-to-date personal contact information at all times, including email address, phone number, and residential address. The Company shall not be liable for any loss, delay, or misunderstanding resulting from the Client’s failure to update such information promptly.

17.4 Website and Platform Announcements Constitute Notice
The Client acknowledges that the Company may provide notice of updates to trading conditions, market schedules, margin requirements, spreads, fees, leverage adjustments, system maintenance, or other operational changes by publishing announcements on the Company’s Website or Trading Platform. Such notice shall be considered legally binding and fully sufficient.

17.5 Client Requests and Instruction Requirements
Requests concerning withdrawals, account changes, password resets, account closure, or complaints must be submitted in writing through the designated Client Portal functions or via the Company’s official support email.
Verbal instructions, chat messages, or social media communications shall not be considered valid and will not obligate the Company to act.

17.6 Recording and Monitoring
The Client hereby consents to the Company recording, storing, or monitoring communications, including telephone conversations, chat messages, emails, and account instruction submissions, for the purposes of verification, compliance, dispute resolution, and security. These records may be used as evidence in resolving disputes.

17.7 No Liability for Communication Failure
The Company shall not be held liable for any delay, interruption, or failure of communication caused by:
a) Internet service disruption
b) Power or hardware failure
c) Spam filtering or mailbox storage limits
d) Firewall or network restrictions
e) Device malfunction or incompatibility

The Client understands and agrees that maintaining reliable internet access, devices, and software required for trading is their sole responsibility.

17.8 Time of Receipt and Effective Action
Unless otherwise specified, written notices provided by the Company shall be considered effective:

• Immediately, when delivered electronically
• At the time of posting, for Website or Platform announcements
• Within 48 business hours, if sent by registered mail (if applicable)

18. CONFIDENTIALITY AND WAIVER

18.1 Confidential Information
For the purposes of this Agreement, “Confidential Information” includes all personal, financial, trading, transactional, technological, and communication data exchanged between the Client and the Company, including but not limited to: account identifiers, balances, transaction history, platform data, communication records, business strategies, operational procedures, and any information not publicly accessible.

18.2 Company Duty of Data Protection
The Company shall take reasonable measures to store, secure, and safeguard Client information in accordance with applicable data protection, privacy, and financial service regulations. The Company shall restrict access to Confidential Information to authorized personnel and service partners who require such information to fulfill operational, regulatory, or technical responsibilities.

18.3 Permitted Disclosure of Client Information
The Client acknowledges and agrees that the Company may disclose Confidential Information without prior notice to the Client where such disclosure is:
a) Required by law, regulation, authority, or court order
b) Requested by banks, payment processors, auditors, risk assessors, or financial institutions involved in transaction processing
c) Necessary for fulfilling AML/CTF, compliance, fraud detection, or security monitoring obligations
d) Necessary for providing trading access, execution, platform hosting, liquidity services, or back-office support
Any such disclosure shall be limited to the information necessary for the prescribed purpose.

18.4 Disclosure to Third-Party Service Providers
The Client acknowledges that the Company may engage regulated and reputable third-party service providers for KYC verification, risk scoring, payment clearing, liquidity routing, platform operation, or data hosting. The Client consents to the controlled transfer of relevant information strictly for these operational needs.

18.5 Client Responsibility to Safeguard Account Credentials
The Client is solely responsible for maintaining the confidentiality of login credentials, trading platform passwords, authentication codes, wallet access information, and any security devices. The Company shall not be liable for any loss, damage, trading loss, or unauthorized transactions resulting from the Client’s failure to protect access credentials.

If any unauthorized access is suspected, the Client must notify the Company immediately. Failure to report such incidents promptly may result in permanent loss of funds or data without liability to the Company.

18.6 Prohibition on Unauthorized Public Disclosure
The Client agrees not to disclose, publish, transmit, or distribute, whether privately or publicly, any internal Company communication, operational procedures, pricing feeds, compliance correspondence, or support interaction records, whether for the purpose of complaint publication, defamation, commercial advantage, competitive analysis, or any similar intent.
Such disclosure constitutes a material breach and may result in account suspension, legal action, and compensation claims.

18.7 Waiver of Confidentiality Objections in Compliance Situations
The Client waives any right to object to the lawful disclosure of information made in accordance with this Section. The Company shall not be liable for any alleged loss, inconvenience, or damage arising from disclosures made under regulatory, compliance, fraud-prevention, or law enforcement obligations.

18.8 Survival of Confidentiality Obligations
The obligations outlined in this Section survive the termination of the Client’s relationship with the Company. Closing or deactivating a Trading Account does not eliminate or reduce confidentiality obligations or the Client’s liability for breach.

19. TIME OF ESSENCE

19.1 Importance of Timely Action
The Client acknowledges that the nature of financial markets and leveraged trading requires immediate and timely action, and that any delay in performing obligations under this Agreement may result in financial consequences. Therefore, time shall be of the essence with respect to all duties, instructions, requests, notifications, margin requirements, and compliance procedures outlined herein.

19.2 Margin and Liquidation Timing
The Client understands that when the Account Equity approaches the Stop Out level specified in the Contract Specifications, the Company is entitled to automatically close positions without prior notice. The Company is not required to wait for additional deposits, instructions, or communications from the Client.
The responsibility for monitoring margin levels and ensuring sufficient funds is solely the Client’s.

19.3 Immediate Compliance Requests
If the Company requests documents or information for identity verification, source of funds verification, anti-money laundering (AML) review, fraud screening, or regulatory compliance, the Client must provide such information promptly.
Failure to respond within the timeframe designated by the Company may result in:

• Account suspension
• Restriction of trading activity
• Delay or rejection of withdrawal requests
• Termination of the Client’s Account

19.4 No Liability for Client Delays
The Company shall not be held liable for any loss, missed trading opportunity, liquidation, delay in execution, or adverse financial result arising from the Client’s failure to act in a timely manner, including but not limited to:

• Delayed reactions to margin requirements
• Slow response to Company communication
• Internet, device, software, or platform access issues on the Client’s side
• Hesitation, emotional delay, or decision-making delay by the Client

19.5 Communications and Time-Stamped Validity
Any notification issued by the Company through the Client Portal, Trading Platform, Website, or the Client’s registered email address shall be deemed delivered at the time of sending or posting, regardless of when, or whether, the Client reads or reviews the message.
The Client is responsible for actively monitoring communication channels at all times.

19.6 Survival of Time-Based Obligations
The obligations established under this Section remain in effect at all times, including during market volatility, technical maintenance periods, or pending withdrawal or account closure requests.

20. REPRESENTATIONS AND WARRANTIES

20.1 Legal Capacity and Eligibility
The Client represents and warrants that they are at least 18 years of age, possess full legal capacity to enter into binding financial agreements, and are not prohibited or restricted under the laws of their country of residence from using the Company’s services or engaging in leveraged trading activities.

20.2 Accuracy of Information Provided
The Client confirms that all personal, financial, identification, and contact information provided to the Company during account registration or at any later stage is true, accurate, complete, and authentic. The Client agrees to promptly notify the Company of any changes to such information and acknowledges that failure to do so may result in account suspension or service restrictions.

20.3 Client Acting on Own Behalf
The Client represents that they are opening and operating the Trading Account on their own behalf, and not as an agent, nominee, or representative of any third party, unless prior written authorization has been approved by the Company. The Client further confirms that all funds deposited originate from lawful and legitimate sources belonging to the Client.

20.4 Understanding of Risks
The Client acknowledges that trading leveraged financial instruments carries significant risk, including the possible loss of all invested capital. The Client confirms that they have read, understood, and accepted the Company’s Risk Disclosure Statement, and that they have the necessary knowledge, financial capability, and willingness to accept the risks associated with such transactions.

20.5 No Reliance on Advice
The Client agrees that the Company does not provide investment, financial, tax, legal, or trading advice, and that any market commentary, analysis, educational content, or third-party signals made available by the Company or its partners shall be considered general informational material. The Client acknowledges that all trading decisions are made independently and at their own discretion, and that the Company bears no responsibility for the outcome of such decisions.

20.6 Compliance with Laws and Tax Obligations
The Client is solely responsible for ensuring that their use of the Company’s services complies with applicable laws and regulations in their country of residence, including tax reporting and payment obligations. The Company shall not be held liable for the Client’s failure to comply with such obligations.

20.7 Platform and Execution Disclaimer
The Client acknowledges that the Company provides access to trading platforms and execution systems on an “as is” and “as available” basis. The Company does not guarantee uninterrupted platform availability, fixed spreads, execution certainty, or protection from market volatility, gaps, slippage, or liquidity fluctuations.

20.8 Survival of Representations and Warranties
The Client’s representations and warranties under this Section shall remain in full force and effect for the entire duration of the Client’s relationship with the Company and shall continue to apply following the termination of the Trading Account to the extent necessary to resolve outstanding obligations or disputes.

21. MISCELLANEOUS

21.1 Entire Agreement
This Agreement, together with all policies, schedules, disclosures, and Contract Specifications published on the Company’s Website, constitutes the entire and exclusive agreement between the Client and the Company regarding the provision of the Company’s services. Any prior discussions, representations, proposals, or understandings, whether verbal or written, are hereby superseded and have no legal effect.

21.2 No Reliance on External Representations
The Client acknowledges that no statement, assurance, promise, or representation made by any third party, including but not limited to Introducing Brokers, affiliates, signal providers, account managers, social media promoters, or acquaintances, shall bind the Company unless expressly confirmed in writing by the Company. In case of conflict, the terms of this Agreement shall prevail.

21.3 Severability
If any provision of this Agreement is determined to be invalid, unlawful, or unenforceable under applicable law, such provision shall be enforced to the maximum extent permissible, and the remaining provisions shall continue in full force and effect without impairment.

21.4 Non-Waiver
Failure, delay, or omission by the Company to exercise or enforce any right, power, or provision under this Agreement shall not be considered a waiver of such right or provision. The Company retains the full right to enforce any clause at any time.

21.5 Assignment and Transfer
The Client may not assign, transfer, sell, or delegate their rights or obligations under this Agreement to any third party without the prior written consent of the Company.
The Company may assign or transfer this Agreement, wholly or partially, to another regulated entity, service partner, technology provider, or affiliate, where such transfer does not adversely affect the Client’s rights.

21.6 Governing Law and Jurisdiction
This Agreement shall be governed and interpreted in accordance with the laws and regulatory framework applicable in the jurisdiction in which the Company is registered. Any dispute arising out of or related to this Agreement shall be resolved exclusively through the dispute resolution procedures specified by the Company, which may include arbitration, regulatory mediation, or court jurisdiction in the Company’s operating country.

21.7 Language Priority
This Agreement may be made available in multiple languages for convenience. In the event of any inconsistency or conflict, the English version shall prevail and be deemed legally binding.

21.8 Headings
Headings used in this Agreement are for organizational convenience only and shall not affect the interpretation or legal meaning of the underlying provisions.

22. CONFIRMATIONS

22.1 Execution Confirmations
Upon execution of any order, the Trading Platform shall automatically generate a transaction confirmation, which shall display the order type, traded instrument, volume, execution price, timestamp, and any applicable fees. Such confirmation shall be considered final, accurate, and binding on the Client, unless the Client provides evidence of a proven technical error in accordance with this Agreement.

22.2 Account Statements and History
The Client may review their account balance, open positions, closed positions, swaps, commissions, pending orders, margin levels, and transaction history through the Trading Platform or Client Portal. These records constitute the authoritative and official record of the Client’s trading activity. The Company is not required to provide printed or manually prepared statements, except where required by applicable regulation.

22.3 Client Responsibility to Review Records
The Client is solely responsible for regularly reviewing all confirmations, account statements, and balance adjustments. If the Client believes any information is inaccurate, they must notify the Company in writing within two (2) business days from the date of issuance.
Failure to report discrepancies within this timeframe shall constitute full acceptance of the records as correct.

22.4 Priority of Server-Side Records
In the event of any discrepancy between data displayed on the Client’s device and the data stored on the Company’s server infrastructure, including execution logs and liquidity feed data, the Company’s server-side data shall prevail and shall serve as the final and conclusive evidence of the trade execution, pricing, and account balances.

22.5 Finality of Executed Transactions
Once an order has been executed, the Client may not request cancellation, reversal, or modification based on:
a) User input error or mistaken trade placement
b) Change of trading intention or strategy
c) Device malfunction or internet disruption on the Client’s side
d) Delayed reaction to market conditions
All executed trades are considered final, subject only to confirmed, verifiable technical execution errors as determined by the Company.

22.6 Dispute Evaluation and Evidence Requirements
Any dispute relating to execution, Stop Loss or Take Profit behavior, spreads, swaps, or slippage shall be evaluated purely on the basis of:

• Server-based execution records
• Platform transaction logs
• Liquidity provider price feeds
• Market data snapshots recorded at execution time

Screenshots, third-party charts, external broker prices, or client-side data will not be accepted as evidence in the dispute review process.

INTRODUCTION

1.1. General Statement

This Risk Disclosure Statement (hereinafter referred to as the “Statement”) is issued by NPE Market Limited, a company duly registered under the laws of Saint Lucia with registration number 2024-00497, having its registered office at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros Islet, Saint Lucia, and its operational office located at 24th Floor, The One Tower, Barsha Heights, P.O. Box 390114, Dubai, United Arab Emirates (hereinafter referred to as the “Company”, “NPE Market”, “we”, “us”, or “our”).

This Statement forms an integral part of the contractual framework between the Client and the Company and shall be read in conjunction with the Client Agreement, the Terms of Business, and any other legal or policy documents published by the Company from time to time.

1.2. Purpose of the Statement

The purpose of this Statement is to ensure that each prospective and existing client (hereinafter referred to as the “Client”, “you”, or “your”) is duly informed and aware of the nature and level of risks involved in trading financial instruments offered by the Company, including but not limited to foreign exchange (“Forex”), contracts for difference (“CFDs”), precious metals, commodities, indices, cryptocurrencies, and shares (collectively referred to as the “Financial Instruments”).

The Client hereby acknowledges and agrees that this Statement is provided for informational purposes only and does not constitute investment advice, recommendation, solicitation, or inducement to engage in any trading activity.

1.3. Regulatory Context

This Statement has been prepared in accordance with internationally recognized principles of investor protection and disclosure applicable to over-the-counter (“OTC”) derivatives trading. It does not purport to enumerate every possible risk that may arise in connection with transactions undertaken with or through the Company.

The Client is strongly advised to seek independent legal, tax, and financial advice before entering into any transaction with the Company, and to ensure that the risks described herein are fully understood, compatible with their financial circumstances, and acceptable to their risk appetite.

1.4. High-Risk Nature of Trading

Trading in leveraged Financial Instruments such as Forex and CFDs is highly speculative and involves a substantial risk of loss. The use of leverage may work both to your advantage and disadvantage. A small movement in the market price of the underlying asset may have a disproportionate impact on your trading account, potentially resulting in the loss of your entire invested capital or even in a negative balance.

The Client should not engage in trading unless they fully understand the risks involved and are able to bear such losses without jeopardizing their financial stability or lifestyle.

1.5. Binding Effect

By opening a trading account and/or using any of the Company’s platforms or services, the Client acknowledges that they have carefully read, understood, and accepted this Statement in its entirety, and that they voluntarily assume all risks arising therefrom.

2. 
   DEFINITIONS AND SCOPE OF APPLICATION

2.1. Definitions

For the purposes of this Risk Disclosure Statement, unless the context otherwise requires, the following terms shall bear the meanings assigned to them below:

1. a) “Company” shall mean NPE Market Limited, its subsidiaries, affiliates, directors, officers, employees, and authorized representatives.
   b) “Client” shall mean any natural or legal person who has applied for, been accepted by, and maintains a trading account with the Company.
   c) “Financial Instruments” shall mean the derivative and non-derivative products offered by the Company, including but not limited to foreign exchange (“Forex”), contracts for difference (“CFDs”), precious metals, commodities, indices, cryptocurrencies, and equities.
   d) “Leverage” shall mean the ratio between the amount of margin required to open a position and the notional value of such position, enabling the Client to control a larger exposure with a smaller capital deposit.
   e) “Margin” shall mean the amount of funds required to open and maintain a trading position as determined by the Company for each Account type.
   f) “Stop-Out Level” shall mean the threshold at which the Company is entitled to close one or more of the Client’s open positions due to insufficient equity in the account.
   g) “Margin Call Level” shall mean the level of equity at which the Client will be notified that additional funds are required to maintain existing positions.
   h) “Trading Platform” shall mean the electronic system(s) provided by the Company, currently MetaTrader 5 (MT5), through which the Client executes transactions.
   i) “Hybrid Execution Model” shall mean the execution methodology whereby the Company may act as a market maker or transmit orders to third-party liquidity providers, depending on market conditions and internal risk management.
   j) “OTC” (Over-the-Counter) shall mean transactions concluded directly between the Client and the Company and not executed on a regulated exchange.

2.2. Scope of Application

1. a) This Statement applies to all Clients and to every transaction or series of transactions undertaken with or through the Company, irrespective of account type, trading platform, or Financial Instrument.
   b) The provisions contained herein are of a general nature and do not constitute, nor should they be interpreted as, exhaustive disclosure of all risks or contractual terms associated with trading in Financial Instruments.
   c) In the event of any inconsistency between this Statement and the Client Agreement, the latter shall prevail to the extent of such inconsistency.
   d) This Statement shall form an inseparable component of the legal relationship between the Client and the Company and shall remain in full force and effect for as long as the Client maintains an account or open positions with the Company.
2. 
   RISKS OF TRADING IN FINANCIAL INSTRUMENTS

3.1. General Risk Acknowledgment

The Client expressly acknowledges that trading in leveraged Financial Instruments such as Forex, CFDs, metals, indices, cryptocurrencies, stocks, and commodities involves a high degree of risk. Such trading is not suitable for all investors. The Client may lose all or part of the funds deposited with the Company, and, due to the absence of negative balance protection, may incur losses exceeding their initial capital, resulting in a negative balance owed to the Company.

By entering into transactions with the Company, the Client confirms that they understand and accept all the risks described herein and that they have sufficient knowledge, experience, and financial capacity to bear such risks.

3.2. Nature of OTC Transactions

1. a) All transactions between the Client and the Company are concluded on an Over-the-Counter (OTC) basis and not on a regulated exchange.
   b) As a result, positions opened with the Company are not transferable or tradable with any other entity.
   c) The prices quoted by the Company for Financial Instruments may differ from those quoted elsewhere and are determined in accordance with the Company’s pricing and execution policy.
   d) The Client acknowledges that the absence of centralized pricing and market supervision may expose them to increased market, liquidity, and counterparty risks.

3.3. Leverage Risk

1000. a) The use of leverage allows the Client to control large positions with a relatively small amount of invested capital; however, it also magnifies both potential profits and potential losses.
      b) On Standard Accounts, the leverage ratio may reach 1:1000. On ECN and ECN Pro Accounts, leverage may reach 1:200.
      c) Even small price fluctuations in the underlying market may result in substantial gains or losses, possibly exceeding the Client’s deposit.
      d) The Client should therefore monitor their positions at all times and ensure that sufficient margin is maintained in the account.

3.4. Margin and Stop-Out Risk

1. a) The Client’s positions are subject to continuous margin requirements. Failure to maintain adequate margin may result in the automatic closure of open positions without prior notice.
   b) The applicable margin call and stop-out levels for each account type are as follows:

1. c) The Company is under no obligation to issue a margin call prior to liquidating positions.
   d) The Client shall be fully liable for any resulting deficit and shall promptly settle any outstanding balance owed to the Company.

3.5. Market Risk

1. a) Market risk refers to the possibility of losses resulting from adverse movements in market prices, interest rates, exchange rates, or other financial variables.
   b) Volatile or illiquid market conditions may render it difficult or impossible to execute orders at the desired price.
   c) Sudden economic or geopolitical events may cause sharp and unpredictable market movements, leading to significant losses for the Client.

3.6. Liquidity Risk

1. a) Certain Financial Instruments, particularly those linked to emerging markets or low-volume assets, may experience reduced liquidity, resulting in widened spreads, price slippage, or delayed execution.
   b) Under extreme market conditions, the Company may suspend quoting or execution temporarily if liquidity from its counterparties becomes unavailable.

3.7. Counterparty Risk

1. a) As all OTC transactions are executed directly with the Company, the Client is exposed to counterparty risk — the risk that the Company or its liquidity providers may default on their obligations.
   b) The Client acknowledges and accepts that, in the event of such default, any claims against the Company shall be limited to the extent permitted under the applicable laws of Saint Lucia.

3.8. Interest Rate and Currency Risk

1. a) Interest rate fluctuations may affect the value of certain Financial Instruments or the cost of holding positions overnight (swap or rollover charges).
   b) Trading in currency pairs or instruments denominated in a currency other than the Client’s base currency exposes the Client to exchange rate fluctuations, which may result in gains or losses independent of the underlying position’s performance.

3.9. No Guarantee of Profit

1. a) There are no guarantees of profit or assurances of avoiding loss when trading with the Company.
   b) Past performance of any trading strategy, signal, or analysis does not constitute a reliable indicator of future performance.
   c) The Client alone bears the full responsibility for evaluating the risks and merits of any investment decision.
2. 
   MARGIN REQUIREMENTS, STOP-OUT PROCEDURES, AND ACCOUNT DEFICITS

4.1. Margin Requirements

1. a) Prior to entering into any transaction, the Client must ensure that sufficient margin is available in their trading account to support the open position(s).
   b) The amount of margin required to open or maintain a position shall be determined exclusively by the Company in accordance with its internal policies, account type, and prevailing market conditions.
   c) The Company reserves the right, at its sole discretion and without prior notice, to amend margin requirements temporarily or permanently in response to market volatility, economic announcements, or other relevant factors.
   d) The Client acknowledges that margin requirements published on the Company’s website or platform are indicative only and may vary for specific instruments or under special trading conditions.

4.2. Maintenance of Margin

1. a) The Client is obliged to maintain the required margin at all times. The Client’s responsibility to monitor their account balance is continuous and independent of any notification that may or may not be issued by the Company.
   b) Should the Client’s equity fall below the applicable Margin Call Level, the Company may, but is not obligated to, notify the Client to deposit additional funds.
   c) If the equity continues to decline and reaches or falls below the Stop-Out Level, the Company shall have the right, but not the obligation, to close one or more open positions without any prior notice in order to protect the account from further losses.

4.3. Stop-Out Procedures

1. a) Stop-Out procedures shall operate automatically through the trading platform. Once the account equity reaches the designated Stop-Out percentage, the system will begin closing open positions, starting with the largest loss-making positions, until the account equity exceeds the Stop-Out threshold or all positions are closed.
   b) The execution of Stop-Out procedures may occur under conditions of extreme market volatility, where the liquidation price obtained could differ materially from the quoted or expected price. The Client acknowledges and accepts this risk.
   c) The Company shall not be liable for any losses incurred as a result of delayed or partial liquidation, slippage, or market gaps during the Stop-Out process.

4.4. Absence of Margin Calls

1. a) The Company is under no obligation to issue margin calls prior to closing positions and generally does not provide intraday margin credit.
   b) The Client hereby waives any right to prior notice or demand before liquidation and accepts that liquidation may occur at any time the Company deems necessary to preserve its interests or maintain market integrity.
   c) Any such liquidation will be deemed final and binding, and the Client shall have no right to contest the order or sequence in which positions were closed.

4.5. Account Deficits and Client Liability

1. a) Should the liquidation of positions result in a negative balance, the Client shall remain fully and unconditionally liable to the Company for the total amount of the deficit, together with any related costs, expenses, commissions, or legal fees incurred in recovering such deficit.
   b) The absence of negative balance protection under the Company’s trading framework means that losses may exceed the total amount deposited by the Client.
   c) The Client must promptly remit any outstanding amounts upon demand. Failure to do so may result in legal proceedings and the suspension or termination of all trading privileges.

4.6. Adjustments, Fees, and Deductions

1. a) The Company may deduct from the Client’s account all applicable commissions, swaps, and other charges associated with maintaining open positions.
   b) Such deductions may affect the amount of available equity and may trigger margin calls or automatic stop-outs.
   c) The Client acknowledges that overnight adjustments, fees, or credits will be applied in accordance with the Company’s fee schedule as published on its website.

4.7. Rights of the Company

Without prejudice to any other rights contained in the Client Agreement or under applicable law, the Company shall have the right, in its sole discretion and without prior notice:

1. To close or partially close any or all open positions;
2. To refuse new orders or suspend account activity;
3. To offset any Client obligations against available balances;
4. To amend leverage or margin levels during abnormal market conditions; and
5. To take any other action deemed necessary to safeguard the Company’s or its clients’ interests.

5. TECHNICAL, OPERATIONAL, AND SYSTEMIC RISKS

5.1. General Provisions

1. a) The Client acknowledges and accepts that trading in Financial Instruments through electronic platforms involves technological and operational risks beyond the Company’s reasonable control.
   b) The Client further acknowledges that such risks may lead to delays, execution failures, misquotations, or the inability to access the trading platform, and that the Company shall not be held liable for losses arising therefrom, except in cases of proven gross negligence or willful misconduct.

5.2. Platform and Communication Failures

1. a) Transactions are executed through electronic communication networks and servers that may be subject to interruptions, system overload, or hardware/software malfunctions.
   b) Such failures may prevent orders from being transmitted, executed, or confirmed, and may cause discrepancies between displayed prices and actual market conditions.
   c) The Client agrees that, in such cases, the Company’s records and server logs shall constitute conclusive evidence of executed transactions.
   d) The Client shall maintain adequate internet connectivity, updated software, and compatible devices in order to ensure uninterrupted access to the trading platform.

5.3. Delays and Latency Risk

1. a) Transmission of orders over the internet may be subject to delays due to network latency, congestion, or routing inefficiencies.
   b) During volatile market conditions or high-impact economic events, such delays may lead to price slippage between the intended execution price and the price at which the order is actually filled.
   c) The Client acknowledges that latency and slippage are inherent features of online trading and accepts all related consequences.

5.4. Data and Security Risk

1. a) The Client bears full responsibility for maintaining the confidentiality of all login credentials, passwords, and account information.
   b) Any transaction executed using the Client’s credentials shall be deemed valid and binding on the Client, whether authorized or unauthorized.
   c) The Client acknowledges that data transmitted electronically, including by email or instant messaging, may be susceptible to interception, unauthorized access, or corruption.
   d) The Company employs reasonable security measures to protect Client data; however, it cannot guarantee absolute protection against cyber threats or third-party intrusion.

5.5. Software Risk

1. a) The trading platform and associated software are provided “as is.” The Company does not guarantee that they will be free from defects or errors.
   b) The Client accepts the risk of executing unintended or duplicated transactions resulting from platform malfunction, human error, or repeated order submission.
   c) In the event of technical errors or malfunctions, the Company reserves the right to void or adjust affected transactions to reflect the fair market value at the time such error occurred.

5.6. Force Majeure and External Events

1. a) The Company shall not be held liable for losses, damages, or failure to perform any obligation arising directly or indirectly from force majeure events, including but not limited to natural disasters, wars, terrorist acts, governmental restrictions, power failures, pandemics, strikes, civil unrest, or extreme market disruptions.
   b) In such circumstances, the Company may, without prior notice:

1. Suspend trading or access to its platform;
2. Cancel or adjust orders and positions;
3. Modify margin requirements or leverage ratios; or
4. Take any other measures deemed necessary to preserve its operational integrity.

5.7. Systemic and Counterparty Risk

1. a) Systemic risk refers to the potential collapse of the entire financial system or a segment thereof, which may prevent the execution or settlement of Client transactions.
   b) The Client acknowledges that the failure or insolvency of a liquidity provider, clearing counterparty, or financial institution may have a material adverse impact on open positions and account balances.
   c) The Company shall not be responsible for losses arising from such systemic failures beyond its direct control.

5.8. Operational Risk

1. a) Operational risk refers to the possibility of losses resulting from human error, internal process failure, or external events.
   b) The Client accepts that operational risk exists both within the Company’s systems and within the Client’s own operational environment.
   c) The Company shall maintain reasonable internal controls, but the Client remains responsible for verifying trade confirmations, statements, and account balances regularly to detect and report discrepancies in a timely manner.
2. 
   MARKET, LIQUIDITY, AND VOLATILITY RISKS

6.1. Market Risk

1. a) Market risk refers to the possibility that fluctuations in market prices, exchange rates, interest rates, or other market variables will adversely affect the value of open positions held by the Client.
   b) The Client acknowledges that the prices of Financial Instruments offered by the Company are influenced by numerous factors including, but not limited to, macroeconomic developments, geopolitical events, governmental actions, central bank interventions, and general market sentiment.
   c) Movements in the underlying market may be sudden and substantial, and may result in significant financial loss to the Client, including losses exceeding the amount originally deposited.
   d) The Client further understands that the Company has no control over market movements and makes no representations as to the likelihood of profit or loss.

6.2. Volatility Risk

1. a) Volatility refers to the magnitude and frequency of price changes within a specific period. High volatility may result in rapid and substantial changes in the price of a Financial Instrument, thereby increasing the likelihood of slippage and execution at prices different from those requested.
   b) Volatility can be caused by a wide range of factors, including economic announcements, political instability, technological incidents, or market speculation.
   c) During volatile conditions, the Client’s pending orders, including stop-loss and take-profit orders, may not be executed at the expected levels.
   d) The Client acknowledges that volatile markets may also result in temporary suspension of pricing, widened spreads, or partial unavailability of liquidity from counterparties.

6.3. Liquidity Risk

1. a) Liquidity risk arises when a Financial Instrument cannot be traded quickly enough in the market to prevent or minimize a loss.
   b) Certain instruments, such as minor currency pairs, exotic CFDs, or cryptocurrencies, may experience limited market depth or periods of illiquidity, especially outside regular trading hours.
   c) Under such circumstances, the Client may be unable to close an existing position, may be forced to close it at a less favorable price, or may experience delays in execution.
   d) The Company shall not be liable for any financial losses resulting from the Client’s inability to liquidate a position due to insufficient market liquidity.

6.4. Price Gaps and Market Discontinuity

1. a) A price gap refers to a situation in which the price of a Financial Instrument opens significantly higher or lower than its previous closing price, often caused by news events or weekend developments.
   b) In the event of a gap, stop orders and pending orders may be executed at the next available market price, which may differ considerably from the price specified by the Client.
   c) The Client accepts that price gaps are inherent to leveraged markets and that such occurrences may cause significant losses, including the possibility of account deficits.

6.5. Execution Risk

1. a) Execution risk arises from the possibility that orders may be executed at a price different from the one quoted or requested due to market conditions, latency, or slippage.
   b) The Client understands that all orders placed on the trading platform are subject to available liquidity and that execution at requested prices cannot be guaranteed.
   c) During periods of extreme volatility, the Company may, at its discretion, refuse to accept new orders, modify spreads, or temporarily suspend quoting.

6.6. Hybrid Execution and Conflict of Interest

1. a) The Company operates under a Hybrid Execution Model, which allows it to either act as a counterparty to the Client’s transactions (market-maker model) or to transmit orders to external liquidity providers (agency model).
   b) The Client acknowledges that, in certain cases, the Company may benefit from Client losses or maintain an opposite position for hedging or risk-management purposes.
   c) The Company undertakes to manage such potential conflicts of interest in accordance with its internal policies and applicable legal obligations.

6.7. Market Closure and Limited Hours

1. a) The Client acknowledges that markets may close or suspend trading for specific instruments due to holidays, regulatory decisions, or extraordinary events.
   b) During such closures, the Client may be unable to open or close positions or to modify pending orders.
   c) The Client remains fully responsible for the risks associated with holding open positions during market closures, including overnight or weekend exposure.
2. 
   SPECIFIC PRODUCT RISKS

7.1. Foreign Exchange (“Forex”) Risk

1. a) Trading in Forex involves exposure to significant fluctuations in exchange rates between one currency and another.
   b) Exchange rates may be influenced by interest rate variations, monetary policies, geopolitical developments, capital flows, market sentiment, and unexpected economic announcements.
   c) Leverage available on Forex instruments, particularly at ratios up to 1:1000 on Standard Accounts, considerably amplifies both potential gains and potential losses.
   d) The Client acknowledges that sharp intraday price movements, especially around macroeconomic releases, may result in partial fills, slippage, or execution at unfavorable prices.

7.2. Contracts for Difference (“CFDs”) Risk

1. a) CFDs are complex, leveraged Financial Instruments that derive their value from an underlying asset without granting the Client ownership of such asset.
   b) CFD pricing is determined by the Company based on market conditions, liquidity, and its internal execution model, and may differ from prices quoted on regulated exchanges.
   c) The Client acknowledges that:

• Small market movements may have disproportionate effects on account equity;
• Stop-loss orders may not fully limit losses under volatile conditions;
• Wide spreads may apply during illiquid or news-driven periods.
  d) The Client accepts full responsibility for monitoring their positions and ensuring that adequate margin is maintained.

7.3. Precious Metals Risk (Gold, Silver, etc.)

1. a) Trading in metals (e.g., gold, silver) is highly sensitive to global economic conditions, interest rate changes, inflation expectations, and geopolitical tensions.
   b) Precious metals markets may become extremely volatile during economic uncertainty or major political developments.
   c) Liquidity may vary significantly depending on the instrument and time of day, particularly for non-gold metals.
   d) Price gaps and sudden market discontinuities may occur frequently, and may result in substantial losses.

7.4. Indices Risk

1. a) Trading index-based CFDs exposes the Client to risks associated with the performance of a basket of underlying equities.
   b) Market-moving news, corporate earnings, political developments, or economic indicators affecting major companies may cause abrupt index movements.
   c) Trading sessions and pricing for indices may be affected by holidays, partial market closures, or interruptions in underlying exchange operations.
   d) Indices may experience sharp volatility at market open due to accumulated overnight news, potentially resulting in slippage or rejections.

7.5. Cryptocurrency CFD Risk

1. a) Cryptocurrencies are highly speculative assets subject to extreme price volatility, regulatory uncertainty, technological risk, and low institutional oversight.
   b) Cryptocurrencies may experience extreme market swings, flash crashes, forks, protocol changes, or liquidity shortages without warning.
   c) Due to their decentralized and unregulated nature, cryptocurrency prices may be influenced by limited liquidity, exchange outages, hacking incidents, or manipulative behavior.
   d) The Client acknowledges that the Company’s cryptocurrency CFDs do not involve actual ownership of the underlying digital asset.
   e) Trading crypto CFDs during weekends or periods of exchange instability may significantly increase execution risk.

7.6. Commodities Risk (Energy, Agriculture, etc.)

1. a) Commodity markets (including oil, natural gas, and agricultural products) are influenced by supply-demand dynamics, weather conditions, geopolitical events, OPEC decisions, natural disasters, and transportation disruptions.
   b) Commodities often exhibit gap risks, especially during geopolitical conflicts or inventory report releases.
   c) Certain commodities may be highly illiquid outside standard trading hours, resulting in wide spreads and potential execution at significantly adverse prices.

7.7. Shares and Equity CFD Risk

1. a) Trading share CFDs exposes the Client to the risks inherent in the performance of individual companies, including earnings reports, corporate actions, and management decisions.
   b) Share CFDs may be subject to unique risks such as low liquidity, trading halts, unexpected corporate announcements, or delisting of the underlying stock.
   c) Corporate events such as dividends, stock splits, or mergers may affect pricing and swap adjustments applied to open share CFD positions.
   d) Execution and spreads on share CFDs may vary substantially during pre-market and post-market trading sessions.

7.8. Overnight and Weekend Risk

1. a) Holding positions overnight or over weekends exposes the Client to the risk of price gaps between trading sessions.
   b) The opening price on the following trading day may differ significantly from the previous session’s closing price.
   c) Swap or rollover charges may apply and may affect the Client’s equity, potentially triggering margin calls or stop-outs.

7.9. Special Note on Bonus and Credit Risks

1. a) The Company may, at its discretion, offer bonuses or trading credits, including the 20% Equity Bonus applicable to the Client’s first real trading account deposits until the total credit reaches USD 3,000.
   b) Trading with credit or bonus funds involves increased risk, as bonus equity may be removed if withdrawal conditions or bonus terms are violated.
   c) Removal of bonus funds may reduce free margin and cause immediate stop-outs.
   d) The Client acknowledges that bonus terms form a separate contractual obligation and must be read and understood in full before accepting any promotional offer.
2. 
   8. CONFLICTS OF INTEREST, NO INVESTMENT ADVICE, AND ABSENCE OF GUARANTEES

8.1. Conflicts of Interest

1. a) The Client acknowledges that the Company operates under a Hybrid Execution Model, whereby it may act either as principal (market maker) or agent (routing orders to external liquidity providers).
   b) When acting as principal, the Company may be the direct counterparty to the Client’s transactions. In such cases, the Client understands and accepts that:

1. The Company may benefit from Client losses;
2. Pricing may be determined in accordance with the Company’s internal pricing models; and
3. The Company may engage in hedging or risk-management transactions that may conflict with the Client’s interests.
   c) The Company undertakes to identify, manage, and disclose conflicts of interest in accordance with its internal Conflict of Interest Policy, which forms part of the Client’s legal documentation.
   d) The Client confirms that they have read and understood the Company’s Conflict of Interest Policy and that they accept the potential existence of such conflicts as an inherent component of OTC trading.

8.2. No Investment Advice or Fiduciary Duty

1. a) The Company does not provide personalized investment advice, portfolio management services, or financial recommendations of any kind.
   b) Any market commentary, research, analysis, economic information, or other communication provided by the Company is issued for general informational purposes only and shall not be construed as:

1. An offer or solicitation to buy or sell any Financial Instrument;
2. A recommendation to enter into a particular transaction;
3. A guarantee of expected return or protection from loss; or
4. A fiduciary duty owed by the Company to the Client.
   c) The Client alone bears full responsibility for evaluating the risks and merits of any decision before executing transactions.
   d) The Company shall not be liable for any losses suffered as a result of the Client relying on any commentary, research, analysis, or information provided by the Company or third parties.

8.3. No Trading Guarantees

1. a) There are no guarantees of profit, no guarantees of avoiding loss, and no guarantees of success in trading leveraged Financial Instruments.
   b) The Client acknowledges that:

1. No representative of the Company is authorized to make guarantees or assurances regarding trading outcomes;
2. Past performance, hypothetical performance, or back-tested results are not reliable indicators of future performance;
3. Any claims of “guaranteed profits,” “risk-free trading,” or “assured returns” are misleading and must be disregarded;
4. The Company does not guarantee the execution of any order at the price requested by the Client; and
5. The Client’s capital is fully at risk at all times.
   c) The Company shall not be held responsible for any losses resulting from the Client’s reliance on verbal or written statements not expressly included in the Client Agreement or this Statement.

8.4. No Tax or Legal Advice

1. a) The Company does not provide tax, legal, accounting, or regulatory advice.
   b) The Client is solely responsible for determining whether trading activities are permissible under the laws of their jurisdiction and for complying with all applicable tax obligations.
   c) The Company shall not be liable for any consequences arising from the Client’s tax status, reporting obligations, or regulatory restrictions in their country of residence.

8.5. Client’s Independent Judgment

1. a) The Client acknowledges that all trading decisions are made independently, based on their own judgment, financial circumstances, and risk appetite.
   b) The Company makes no representation as to whether Financial Instruments are suitable or appropriate for the Client.
   c) By proceeding with trading, the Client confirms that they fully understand and voluntarily assume all associated risks.
2. 
   9. REGIONAL RESTRICTIONS, LEGAL LIMITATIONS, AND ELIGIBILITY TO TRADE

9.1. Jurisdictional Restrictions

1. a) The services and Financial Instruments offered by the Company are not intended for distribution to, or use by, any person in any jurisdiction where such distribution or use would be contrary to local law or regulation.
   b) Without limiting the generality of the foregoing, the Company expressly prohibits the opening of trading accounts or the provision of services to residents or citizens of:

• The United States of America,
• The Democratic People’s Republic of Korea (North Korea), and
• Any jurisdiction in which the trading of Contracts for Difference (“CFDs”) or leveraged OTC derivatives is unlawful, criminalized, prohibited, or restricted to the extent that the Company cannot legally provide such services.
  c) The Company reserves the right, at its sole discretion, to refuse or terminate services if it determines that a Client’s residency or citizenship renders the provision of services legally or operationally impracticable.

9.2. Client Responsibility for Legal Compliance

1. a) The Client is solely responsible for ensuring that their use of the Company’s services complies with all applicable laws, regulations, and restrictions in their country of residence, citizenship, or tax domicile.
   b) The Client acknowledges that the Company makes no representation regarding the legality of leveraged trading in any specific jurisdiction.
   c) The Client represents and warrants that they are not accessing the Company’s services from a jurisdiction where such services are restricted or prohibited.

9.3. Eligibility to Open an Account

1. a) To open a trading account, the Client must meet the Company’s onboarding and verification requirements, including but not limited to:

1. Completion of the Client onboarding form;
2. Provision of identity and address documents in accordance with AML/KYC policies;
3. Confirmation of legal age (minimum 18 years or higher if required by local law);
4. Confirmation of sufficient trading knowledge and experience;
5. Confirmation of the legality of leveraged trading in their jurisdiction.
   b) The Company reserves the right to reject any application at its sole discretion, without providing a reason.

9.4. Right to Request Additional Information

1. a) The Company may, at any time, request additional documentation or information to verify the Client’s identity, residency status, source of funds, or compliance with applicable regulations.
   b) Failure to provide such information in a timely manner may result in:

1. Suspension of trading privileges;
2. Restriction of withdrawals;
3. Closure of open positions;
4. Termination of the Client relationship.

9.5. Termination Due to Regulatory Requirements

1. a) The Company may, at its sole discretion and without prior notice, suspend or terminate services to any Client if it becomes aware of:

1. Regulatory prohibitions affecting the Client’s jurisdiction;
2. Legal or compliance risks threatening the Company’s regulatory standing;
3. Changes in law or policy rendering service provision unlawful;
4. The Client’s engagement in fraudulent, prohibited, or suspicious activities.
   b) In such circumstances, the Company may close open positions, restrict access to the trading platform, or require the Client to withdraw remaining balances.

9.6. No Agency or Residency Assurances

1. a) The Company does not represent or warrant that:

1. Its services comply with the laws of every jurisdiction;
2. Clients may legally open accounts in their respective jurisdictions; or
3. Local regulators endorse or recognize the Company’s activities.
   b) The Client is solely responsible for determining whether opening and maintaining an account with the Company contravenes any law applicable to them.

10. 
    TRADING PLATFORM, ORDER EXECUTION, AND PRICING RISKS

10.1. Trading Platform Functionality

1. a) The Company provides access to trading services exclusively through electronic trading platforms, currently including MetaTrader 5 (MT5) (hereinafter the “Trading Platform”).
   b) The Client acknowledges that the Trading Platform is a third-party software system with its own technical and operational limitations and that the Company cannot guarantee uninterrupted availability, error-free operation, or system perfection.
   c) All instructions transmitted by the Client through the Trading Platform shall be deemed to have been placed by the Client and are binding even if such orders were submitted unintentionally, inaccurately, or as a result of system malfunction.

10.2. Order Execution Procedures

1. a) All Client orders are executed according to the Company’s Order Execution Policy, which forms an integral part of the Client’s legal documentation.
   b) The Company shall make reasonable efforts to execute orders at the best available price; however, execution is subject to:

1. Market liquidity.
2. Price volatility.
3. Latency.
4. Connection quality.
5. Server response times.
6. Availability of quotes from liquidity providers.
   c) The Company does not guarantee that orders will be executed at the price preferred, requested, or displayed on the Trading Platform.

10.3. Slippage and Partial Fills

1. a) Slippage may occur during periods of high volatility, during market opening, after major news releases, or due to low liquidity.
   b) Orders may be executed at a price significantly different from the price indicated at the time the Client placed the order.
   c) In certain conditions, an order may be partially executed if sufficient liquidity is not available at the requested volume.

10.4. Requotes and Rejections

1. a) A requote may occur when the price at which the Client attempts to execute an order is no longer available.
   b) The Client understands that requotes are inherent to fast-moving markets and shall not hold the Company liable for such occurrences.
   c) The Company reserves the right to reject any order if:

1. The price is no longer valid.
2. The order violates the Company’s risk limits.
3. The order conflicts with trading rules or platform integrity.
4. Abnormal market conditions are detected.

10.5. One-Click Trading and Immediate Order Transmission

1. a) The Trading Platform may offer a “one-click trading” feature, enabling order transmission with a single action.
   b) The Client acknowledges and accepts that:

1. Orders transmitted via one-click trading cannot be cancelled once submitted.
2. No review or confirmation window may appear prior to execution.
3. Erroneous or unintended orders remain the Client’s sole responsibility.
   c) The Company strongly advises the Client to practice on a demo environment prior to using one-click trading on a real account.

10.6. Order Types and Execution Behaviour

1. a) Stop orders (including stop-loss orders) do not guarantee execution at the stop price but will trigger execution at the next available price, which may be materially different during volatile or illiquid conditions.
   b) Limit orders may not be executed if the market fails to reach the specified limit price.
   c) Pending orders may be subject to expiration, cancellation, rejection, or modification requirements in accordance with platform rules.

10.7. Pricing and Quotation Risks

1. a) All prices displayed on the Trading Platform are indicative and derived from the Company’s pricing feed, which may differ from prices quoted by banks, exchanges, or other brokers.
   b) The Company reserves the right, at its absolute discretion, to:

1. Suspend pricing during market dislocations.
2. Widen spreads without prior notice.
3. Halt or delay execution when liquidity is unavailable.
4. Correct pricing errors or remove trades executed at clearly erroneous prices.
   c) In the event of a pricing error (“off-market price”), the Company may:
5. Void the affected trade(s).
6. Re-price them at the correct market rate; or
7. Adjust the account balance to reflect the fair market value.

10.8. Platform Disconnections and Downtime

1. a) The Client acknowledges that connectivity issues, server overloads, power failures, or internet interruptions may temporarily prevent access to the Trading Platform.
   b) During disconnections or downtime, the Client may be unable to:

1. Place new orders;
2. Modify or cancel existing orders;
3. Close or manage open positions;
4. View account balances or market data.
   c) The Company shall not be held liable for losses resulting from such events, except in cases of proven gross negligence or willful misconduct.

10.9. Use of Third-Party Tools and Plugins

1. a) The Client may utilize third-party indicators, expert advisors, bots, or trading plugins at their own risk.
   b) The Company is not responsible for:

1. Malfunctioning of third-party software;
2. Execution errors caused by automated systems;
3. Trading losses resulting from algorithmic or automated strategies.
   c) The Company reserves the right to disable or restrict automated trading in the event of system misuse, excessive order flow, or suspicious activity.

11. 
    BONUS, CREDIT, PROMOTION, AND INCENTIVE RISKS

11.1. General Provisions on Bonuses and Promotional Programs

1. a) The Company may, at its sole discretion, offer bonuses, trading credits, promotional incentives, or other non-withdrawable benefits (hereinafter referred to as “Bonus” or “Credit”) to eligible Clients, subject to specific terms and conditions issued by the Company from time to time.
   b) Bonuses and Credits are not considered Client funds and may be removed, cancelled, or adjusted at any time if the Client breaches the Bonus Terms or any other contractual obligation.
   c) By accepting any Bonus or Credit, the Client agrees to the full scope of the applicable Bonus Terms, which form an integral and binding component of the contractual relationship.

11.2. Specific Risk Associated with the Company’s Bonus Scheme

1. a) The Company offers a 20% Equity Bonus applicable to deposits made into the Client’s first Real Trading Account, up to a maximum Credit cap of USD 3,000.
   b) The Bonus is added to the Client’s equity and may increase free margin; however, such Bonus is not withdrawable and may be removed if withdrawal or trading conditions are not satisfied.
   c) Removal or adjustment of the Bonus may lead to a sudden reduction in free margin, which may cause:

1. Immediate margin calls;
2. Stop-outs of open positions;
3. Rapid depletion of account equity;
4. A potential account deficit.

The Client acknowledges that acceptance of a Bonus significantly alters risk dynamics and may expose the account to increased stop-out likelihood.

11.3. Trading Risks Associated with Bonus or Credit

1. a) Trading with Bonus or Credit funds increases leverage and may magnify gains as well as losses.
   b) The Client understands that:

1. Bonus funds can be removed without prior notice if Terms are violated;
2. Removal may trigger liquidation of positions if margin becomes insufficient;
3. Losses may exceed the Client’s own deposited funds due to the absence of negative balance protection;
4. The Company may, at its discretion, reject Bonus requests or adjust Bonus parameters under abnormal market conditions.
   c) The Company shall not be liable for losses arising from the Client’s acceptance or misuse of Bonus or Credit offerings.

11.4. Restrictions on Withdrawals, Transfers, and Account Changes

1. a) Withdrawal of funds from an account that contains an active Bonus may be subject to specific conditions imposed by the Company, including minimum trading volume requirements, time-based restrictions, or verification obligations.
   b) If the Client initiates a withdrawal before meeting the Bonus criteria, the Company may remove:

1. The entire Bonus amount;
2. Any profits deemed to have been generated directly from Bonus funds; or
3. All open positions (where required to maintain integrity of margin rules).
   c) The Company may restrict internal transfers between accounts if such transfers would breach Bonus Terms or disrupt margin conditions.

11.5. Prohibited Trading Behaviors

To protect the Company against Bonus abuse, the following activities are strictly prohibited:

1. a) Hedging positions between multiple accounts with or without Bonus funds;
   b) Coordinated trading or arbitrage between related parties;
   c) Use of automated systems specifically designed to exploit Bonus mechanics;
   d) Intentional drawdown strategies to convert Bonus into withdrawable balance;
   e) High-frequency or abusive trading methods inconsistent with normal market behavior;
   f) Opening and closing large-volume simultaneous trades for the purpose of Bonus extraction.

Violation of prohibited behaviors may result in:

1. Immediate Bonus removal;
2. Profit cancellation;
3. Account suspension or termination;
4. Legal actions where necessary.

11.6. Company’s Rights Regarding Bonus Adjustments

The Client acknowledges and agrees that the Company may, at its absolute and sole discretion:

1. a) Modify, suspend, or terminate any Bonus program without prior notice;
   b) Reject Bonus applications;
   c) Remove Bonuses from inactive accounts;
   d) Adjust margin requirements on Bonus-funded accounts;
   e) Recalculate account equity in cases of Bonus misuse;
   f) Reverse trades executed under fraudulent Bonus strategies.

The Client shall have no right to claim compensation for Bonus removal or modification.

12. 
    TAX IMPLICATIONS, FINANCIAL OBLIGATIONS, AND CLIENT RESPONSIBILITIES

12.1. Client’s Sole Responsibility for Tax Obligations

1. a) The Company does not provide tax advice, tax reporting services, or guidance regarding the Client’s personal or corporate tax obligations.
   b) The Client is solely responsible for determining:

1. Whether any transaction conducted through the Company is subject to taxation;
2. The applicable tax treatment under the laws of the Client’s jurisdiction;
3. All reporting, filing, declaration, and payment requirements arising from trading activities;
4. The effect of capital gains, losses, income, VAT, or other taxes.
   c) The Company shall not be held liable for any financial consequences, penalties, or sanctions arising from the Client’s failure to comply with applicable tax laws.

12.2. Currency Conversion and Related Risks

1. a) Transactions executed by the Client may be denominated in currencies other than the base currency of the Client’s trading account.
   b) Currency conversions may be required for the purposes of:

1. Deposits or withdrawals;
2. Realizing profits or losses;
3. Charging fees, commissions, or swaps;
4. Recording account values.
   c) The Client acknowledges that foreign exchange rates fluctuate and that such fluctuations may materially affect the value of their equity, gains, or losses.
   d) The Company shall determine conversion rates at its discretion, based on market prices available to the Company at the time of conversion.

12.3. Client’s Obligation to Maintain Sufficient Funds

1. a) The Client is required to ensure that their trading account contains sufficient funds to support open positions and to meet all applicable margin requirements.
   b) Failure to maintain adequate equity may result in:

1. Margin calls (where applicable);
2. Automatic stop-outs;
3. Liquidation of one or more positions;
4. Account deficits.
   c) The Client remains fully liable for all obligations arising from trading operations, including negative balances, commissions, fees, and adjustments.

12.4. Client’s Responsibility to Monitor Account Activity

1. a) The Client agrees to regularly monitor their trading account, including but not limited to:

1. Margin levels and free margin;
2. Open positions and exposure;
3. Pending orders;
4. Swaps and overnight financing charges;
5. Account statements and trade confirmations.
   b) The Company shall not be responsible for notifying the Client of losses, margin deficiencies, or account risks beyond automated platform alerts.
   c) The Client acknowledges that failure to monitor account conditions constitutes an assumption of risk.

12.5. Reporting and Verification Obligations

1. a) The Client must provide accurate and up-to-date personal information, including identity, address, and contact details.
   b) The Client must promptly notify the Company of any material changes, including:

1. Change of domicile or residency;
2. Change of banking or payment details;
3. Change in legal status (for corporate accounts);
4. Any event affecting the Client’s eligibility to trade.
   c) The Company may request additional verification documents at any time to comply with AML/CTF regulations. Failure to provide such documents may result in account restriction or termination.

12.6. Prohibition of Fraudulent, Illegal, or Abusive Activity

1. a) The Client shall not engage in any fraudulent, deceptive, illegal, or manipulative trading behavior, including but not limited to:

1. Use of stolen identities or funds;
2. Fraudulent chargebacks;
3. Platform manipulation or exploitation of latency;
4. Arbitrage between accounts in a manner that undermines fair market operation;
5. Trading behavior intended to exploit bonuses or credit in violation of Bonus Terms.
   b) The Company reserves the right to take legal action, freeze funds, or terminate the Client relationship in the event of suspected misconduct.

12.7. Financial Capacity and Suitability

1. a) By entering into a Client Agreement with the Company, the Client warrants that they possess sufficient financial capacity to bear the risks of trading leveraged Financial Instruments.
   b) The Client acknowledges that:

1. They may lose all or part of the capital deposited;
2. Losses may exceed deposits due to the absence of negative balance protection;
3. They should trade only with funds that they can afford to lose;
4. They have the financial ability to meet all resulting obligations.
   c) The Company may request financial information to assess the Client’s suitability but is not responsible for ensuring that trading activities align with the Client’s financial situation.

12.8. Client’s Duty to Understand Risk

1. a) The Client confirms that they have read, understood, and accepted this Risk Disclosure Statement in its entirety.
   b) The Client further acknowledges that they:

1. Understand the high-risk nature of leveraged trading;
2. Are aware that no profit is guaranteed;
3. Understand that trading involves the risk of rapid and substantial financial loss;
4. Have not been induced to trade by promises of profitability or minimal risk;
5. Have sufficient knowledge or have sought independent advice where necessary.

13. FORCE MAJEURE, EXTRAORDINARY MARKET CONDITIONS, AND SUSPENSION OF SERVICES

13.1. Definition of Force Majeure Events

For the purposes of this Statement, a “Force Majeure Event” shall include, without limitation:
a) Natural disasters (including earthquakes, floods, hurricanes, fires, and storms);
b) Wars, armed conflicts, rebellions, civil disturbances, riots, insurrections, or acts of terrorism;
c) Governmental actions, regulatory restrictions, changes in legislation, embargoes, sanctions, capital controls, or monetary interventions;
d) Pandemics, epidemics, public health emergencies, or quarantines;
e) Widespread technical failures, power outages, cyberattacks, or infrastructure disruptions affecting communications, data centers, or payment systems;
f) Market disruptions, extreme volatility, liquidity collapse, or failures of exchanges and liquidity providers;
g) Any other circumstance beyond the Company’s reasonable control that materially impairs its ability to provide services.

13.2. Company Rights During Force Majeure Events

Upon the occurrence of a Force Majeure Event, the Company may, without prior notice, take any action it deems necessary to safeguard its interests and those of its Clients, including but not limited to:

1. a) Suspending, delaying, or restricting access to the Trading Platform;
   b) Disabling order placement, modification, or execution;
   c) Refusing to accept new Client instructions;
   d) Cancelling, adjusting, or partially filling Client orders;
   e) Amending margin requirements, leverage ratios, or risk controls;
   f) Closing out positions at prevailing market prices;
   g) Suspending or withholding withdrawals or transactions where necessary to maintain operational stability;
   h) Amending pricing or spreads due to disrupted liquidity conditions.

All actions taken by the Company under this clause shall be final and binding.

13.3. Extraordinary Market Conditions

1. a) Extraordinary Market Conditions (“EMC”) may occur during periods of extreme volatility, market gaps, flash crashes, sudden news events, or disruptions in primary markets.
   b) During EMC, the Client acknowledges that:

1. Prices may change rapidly or become temporarily unavailable;
2. Market depth may decline sharply, resulting in widened spreads or no quoting;
3. Stop-loss orders may be executed at materially different prices (slippage);
4. Pending orders may be rejected or executed at the next available price;
5. Certain trading instruments may experience trading halts or suspensions.
   c) The Company shall not be liable for losses incurred due to EMC beyond its reasonable control.

13.4. Suspension or Interruption of Platform Services

1. a) The Company reserves the right, at its sole discretion, to suspend, restrict, or terminate access to the Trading Platform or any part thereof when deemed necessary for:

1. System upgrades or maintenance;
2. Prevention of cyberattacks or security breaches;
3. Regulatory or legal compliance;
4. Market integrity protection;
5. Force Majeure Events;
6. Extraordinary Market Conditions.
   b) The Company will endeavor, but is not obligated, to give prior notice of planned or unplanned service interruptions.
   c) The Client acknowledges that platform downtime may prevent the management of open positions and may result in substantial financial loss, for which the Company shall not be held liable unless caused by proven gross negligence.

13.5. Impact of Market Closure and Non-Trading Hours

1. a) When underlying markets are closed, whether due to weekends, holidays, or emergency suspensions, the Client may be unable to close, open, or modify positions.
   b) Prices may reopen at significantly different levels (gaps), which may trigger immediate stop-outs or substantial losses.
   c) The Client accepts the risks associated with holding positions during periods of market closure.

13.6. No Liability for Force Majeure or Extraordinary Events

1. a) The Company shall not be liable for any loss, damage, claim, cost, or expense arising directly or indirectly from a Force Majeure Event or Extraordinary Market Conditions.
   b) The Client hereby waives any right to bring a claim against the Company for losses relating to:

1. Inability to execute orders;
2. Execution at unfavorable or delayed prices;
3. Liquidation of positions;
4. Delays in deposits or withdrawals;
5. Platform downtime or communication failures;
6. Pricing errors caused by market dislocation or liquidity collapse.
   c) Any actions taken by the Company under Force Majeure or Extraordinary Market Conditions shall be deemed lawful and necessary.

13.7. Restoration of Normal Operations

1. a) Following the cessation of a Force Majeure Event or Extraordinary Market Condition, the Company shall restore normal trading operations as soon as reasonably practicable.
   b) The Company shall not be obligated to compensate the Client for losses arising during the event or during the restoration period.
   c) The Company may adjust account balances, pricing, or transaction records if required to reflect fair and orderly market conditions.
2. 
   ACCOUNT MONITORING, COMMUNICATION RISKS, AND CLIENT ACKNOWLEDGMENTS

14.1. Duty to Monitor Account and Positions

1. a) The Client acknowledges that trading leveraged Financial Instruments requires active and continuous monitoring.
   b) The Client is solely responsible for reviewing their trading account at all times, including but not limited to:

1. Margin level and free equity;
2. Open positions and unrealized profits or losses;
3. Pending orders and execution status;
4. Swap rates, commissions, and applied charges;
5. Account statements and historical activity;
6. Platform notifications and alerts.
   c) The Company is under no obligation to provide personal reminders, alerts, or warnings regarding margin levels, losses, or account risks beyond automatic platform notifications.

14.2. Communication Channels and Associated Risks

1. a) The Company may communicate with the Client through various channels, including email, the Trading Platform, the Client Portal, or messaging applications.
   b) The Client accepts all risks associated with electronic communications, including but not limited to:

1. Message delays or failures;
2. Interception or unauthorized access;
3. Data corruption or loss;
4. Spam-filter misclassification;
5. Technical issues affecting message delivery.
   c) The Company shall not be liable for any losses arising from the Client’s failure to receive communications due to email filtering, outdated contact information, or technical faults.

14.3. Accurate and Up-to-Date Client Information

1. a) The Client must ensure that all personal details, including contact information, address, residency status, and identification documents, remain accurate and up to date.
   b) The Client agrees to notify the Company promptly of any changes that may affect their eligibility, account operation, or legal obligations.
   c) The Company may rely on the last known contact details provided by the Client, and such contact shall be deemed valid for all communications.

14.4. Misunderstandings and Ambiguous Instructions

1. a) All communications and instructions provided by the Client to the Company must be clear, precise, and unambiguous.
   b) The Company shall not be held liable for losses resulting from unclear, incomplete, or mistaken instructions.
   c) If the Company identifies ambiguous instructions, it may, at its sole discretion:

1. Request clarification;
2. Refuse to execute the instruction; or
3. Execute the instruction in accordance with its interpretation of the Client’s intent.

14.5. Limitations of the Company’s Communication Obligations

1. a) Communications from the Company shall not be construed as:

1. Personalized investment advice;
2. A guarantee of execution or performance;
3. A confirmation of market direction or trends;
4. A substitute for the Client’s own research.
   b) The Company shall not be responsible for delays or failures caused by:
5. The Client’s equipment or software;
6. Internet outages;
7. Device malfunction;
8. Server congestion;
9. Third-party service interruptions.

14.6. Confirmation of Trade Execution

1. a) Trade confirmations are provided through the Trading Platform or Client Portal.
   b) The Client is responsible for reviewing confirmations immediately upon execution and notifying the Company of any discrepancies within a reasonable timeframe.
   c) Failure to report errors promptly shall be deemed acceptance of all executed trades as correct and final.

14.7. No Guarantee of Timely Communication During Market Events

1. a) During periods of high volatility, the Company may experience delays in issuing updates, notifications, or confirmations.
   b) The Client acknowledges that communication delays may impact their ability to manage positions effectively and may result in substantial losses.
   c) The Company shall not be liable for delays caused by market congestion, data provider interruptions, or other factors beyond its control.

14.8. Client Acknowledgment of Trading Risks

By opening and maintaining an account with the Company, the Client expressly acknowledges and agrees that:

1. a) They understand the full scope of risks associated with trading leveraged Financial Instruments;
   b) They have the necessary experience, knowledge, and financial capacity to independently evaluate the risks;
   c) They have not relied upon representations or verbal assurances from the Company or its representatives;
   d) They have read, understood, and accepted this Risk Disclosure Statement, the Client Agreement, and all supplementary policies;
   e) They agree that trading is entirely at their own risk and that the Company shall not be liable for losses except as expressly provided under applicable law.

14.9. Client Responsibility for Platform Usage

1. a) The Client is responsible for familiarizing themselves with platform functionality, order types, execution behavior, and trading mechanisms.
   b) The Company shall not be held liable for losses resulting from the Client’s lack of understanding or incorrect usage of the Trading Platform.
   c) The Client acknowledges that failure to understand the platform increases the likelihood of unintended trades or losses.
2. 
   CONFIDENTIALITY, DATA PROTECTION, AND INFORMATION SECURITY RISKS

15.1. Protection of Client Information

1. a) The Company is committed to maintaining the confidentiality, security, and integrity of Client information in accordance with its Privacy Policy and applicable data protection standards.
   b) The Client acknowledges that the Company may collect, process, store, and transmit personal and financial information necessary for the execution of contractual obligations, compliance with regulatory requirements, and the provision of trading services.

15.2. Risks Associated with Electronic Data Transmission

1. a) The Client understands and accepts that electronic communications and data transfers, including but not limited to email, web portals, trading platforms, and messaging systems, may be vulnerable to:

1. Interception by unauthorized third parties;
2. Delays, disruptions, or loss of data;
3. Corruption of files or incomplete transmission;
4. Hacking, phishing, malware, spyware, and other cyber threats.
   b) The Company shall not be held liable for any loss arising from the interception or manipulation of electronic communications unless caused directly by the Company’s proven gross negligence.

15.3. Cybersecurity and System Protection

1. a) The Company employs reasonable administrative, technical, and physical safeguards designed to protect Client data and operational systems against unauthorized access or cyberattacks.
   b) Despite such efforts, the Client acknowledges that:

1. No system can be guaranteed fully secure;
2. Cyberattacks may disrupt the Company’s operations;
3. Trading platform performance may be affected by security incidents;
4. The Company may suspend services temporarily to protect system integrity.
   c) The Company shall not be liable for losses resulting from cyber incidents beyond its reasonable control.

15.4. Client’s Responsibility for Security of Account Access

1. a) The Client is solely responsible for ensuring the confidentiality and security of their login credentials, passwords, PINs, authentication devices, and any other access information.
   b) The Client agrees to:

1. Use strong and unique passwords;
2. Change passwords regularly;
3. Enable two-factor authentication where available;
4. Safeguard devices used to access trading services;
5. Ensure that unauthorized persons do not access their account.
   c) Any order or transaction executed using the Client’s credentials shall be deemed valid and binding, irrespective of whether it was authorized by the Client.

15.5. Risks of Using Public or Shared Devices

1. a) The Client acknowledges the risks associated with using public or shared devices or networks to access the Trading Platform, including but not limited to:

1. Exposure to keyloggers, malware, or spyware;
2. Unauthorized access by third parties;
3. Insufficient encryption or unsecured connections.
   b) The Company shall not be liable for losses incurred due to the Client’s use of unsecured or compromised devices or networks.

15.6. Disclosure of Information Under Legal or Regulatory Requirements

1. a) The Company may be required to disclose Client information to regulatory authorities, law enforcement agencies, courts, or other competent bodies as required by applicable laws or upon valid request.
   b) Such disclosure may occur without prior notice to the Client where legally permissible.
   c) The Client acknowledges that such disclosure does not constitute a breach of confidentiality.

15.7. Data Retention and Storage Risks

1. a) The Company shall retain Client records and trading data for the period required under applicable laws and internal policies.
   b) The Client acknowledges the risk that stored electronic data may be:

1. Subject to corruption or loss due to systems failure;
2. Compromised due to hardware failure or cyber incidents;
3. Inaccessible due to maintenance or technical disruptions.
   c) The Company shall implement reasonable measures to mitigate such risks but cannot guarantee complete protection.

15.8. Third-Party Service Providers

1. a) The Company may use third-party service providers for hosting, data processing, payment services, identity verification, market data feeds, liquidity provision, and other operational functions.
   b) The Client acknowledges that:

1. Such third parties may have access to certain personal or financial information;
2. The Company shall not be liable for security breaches or failures attributable to third-party providers beyond its reasonable control;
3. The Company conducts due diligence but cannot guarantee the absolute security of third-party systems.

15.9. Client Acknowledgment of Information Security Risks

By entering into a Client relationship with the Company, the Client expressly acknowledges and agrees that:

1. a) They understand the inherent risks associated with electronic trading and data transmission;
   b) They accept responsibility for securing their devices, login details, and internet connection;
   c) They recognize that despite the Company’s security measures, data breaches or cyber incidents remain possible;
   d) They shall not hold the Company liable for losses arising from external attacks, device compromise, or unauthorized access beyond the Company’s control.
2. 
   LEGAL FRAMEWORK, GOVERNING LAW, AND LIMITATIONS OF LIABILITY

16.1. Legal Status of the Company

1. a) NPE Market Limited is a company duly registered under the laws of Saint Lucia with registration number 2024-00497, having its registered office at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros Islet, Saint Lucia.
   b) The Client acknowledges that the Company operates as an Over-the-Counter (OTC) derivatives provider and that all transactions are governed by the applicable laws of Saint Lucia and the contractual documents issued by the Company.

16.2. Governing Law

1. a) This Risk Disclosure Statement, the Client Agreement, and all other legal documents governing the contractual relationship between the Client and the Company shall be governed by and construed under the laws of Saint Lucia, without regard to principles of conflict of laws.
   b) Any dispute, controversy, or claim arising out of or in connection with the Client’s relationship with the Company shall be resolved exclusively under the jurisdiction and legal framework applicable to the Company in Saint Lucia, unless explicitly agreed otherwise in writing.

16.3. Limitation of Liability

The Client acknowledges and agrees that, except in cases of proven gross negligence or willful misconduct:

1. a) The Company shall not be liable for:

1. Losses resulting from market volatility, price gaps, slippage, or execution delays;
2. Losses resulting from margin calls, stop-outs, or insufficient equity;
3. Technological failures, system downtime, communication delays, or outages;
4. Incorrect, incomplete, or misunderstood Client instructions;
5. Losses due to Force Majeure or Extraordinary Market Conditions;
6. Losses arising from unauthorized access to the Client’s account due to compromised credentials;
7. Acts, omissions, or failures of third-party service providers, including liquidity providers and payment processors;
8. Losses from reliance on research, analysis, or commentary issued by the Company;
9. Losses related to bonus removal, credit adjustments, or promotional changes;
10. Any indirect, consequential, incidental, special, or punitive damages.

1. b) The Company’s total aggregate liability to the Client for any claim shall not exceed the total amount of the Client’s available balance at the time the claim arose.

16.4. Client Liability

1. a) The Client shall be fully liable for all losses, damages, costs, or expenses arising from:

1. Failure to maintain adequate margin;
2. Holding leveraged positions during high-risk market periods;
3. Improper or negligent use of the Trading Platform;
4. Unauthorized or fraudulent use of their credentials;
5. Violation of Bonus Terms, trading rules, or internal policies;
6. Breach of this Statement or the Client Agreement.
   b) The Client shall promptly indemnify the Company for any negative balance or account deficit that may arise following liquidation of positions.

16.5. No Waiver of Rights

1. a) No delay, omission, or failure by the Company to exercise any right or remedy shall constitute a waiver of such right or remedy.
   b) A waiver of one breach shall not constitute a waiver of any subsequent breach.

16.6. Severability

1. a) If any provision of this Statement is deemed unlawful, invalid, or unenforceable by a competent authority, such provision shall be severed, and the remaining provisions shall remain in full force and effect.
   b) The Company may amend or replace invalid provisions in order to maintain legal consistency.

16.7. Entire Agreement

1. a) This Statement forms part of the broader contractual framework between the Client and the Company and must be read in conjunction with:

1. The Client Agreement;
2. Terms of Business;
3. Order Execution Policy;
4. Privacy Policy;
5. AML/KYC Policy;
6. Bonus Terms and Conditions;
7. Any other policy or document published by the Company.
   b) Together, these documents constitute the entire agreement between the Parties concerning the services provided by the Company.

16.8. Amendments and Modifications

1. a) The Company reserves the right to amend, modify, or update this Risk Disclosure Statement at any time, with or without prior notice, in order to reflect:

1. Changes in regulatory, operational, or market conditions;
2. Internal risk management adjustments;
3. Updates to trading conditions or financial instruments;
4. Improvements in legal clarity.
   b) Continued use of the Company’s services after publication of amendments constitutes the Client’s acceptance of the updated terms.

17. 
    FINAL ACKNOWLEDGMENTS, ACCEPTANCE OF RISK, AND CLIENT DECLARATION

17.1. Comprehensive Acknowledgment of Risk

By opening an account with NPE Market Limited, the Client expressly acknowledges and declares that they:

1. a) Have carefully read, understood, and fully accepted the entirety of this Risk Disclosure Statement;
   b) Understand that trading Forex, CFDs, metals, indices, cryptocurrencies, commodities, and equities involves high levels of risk, including the risk of losing all deposited funds;
   c) Understand that, due to the absence of negative balance protection, losses may exceed deposited funds, resulting in a negative balance;
   d) Have evaluated their financial situation and confirmed that they possess the financial capacity to bear such losses without compromising their financial stability;
   e) Understand the operational, technological, market, leverage, liquidity, and credit risks inherent in OTC trading.

17.2. Independent Decision-Making

The Client represents and warrants that:

1. a) All investment and trading decisions are made independently and solely by the Client;
   b) They have not relied on any promise, representation, forecast, guarantee, or assurance provided by the Company or its representatives regarding the performance of any Financial Instrument;
   c) They understand that past performance, hypothetical simulations, or market commentary do not guarantee future results;
   d) They have sought independent financial, legal, or tax advice where necessary.

17.3. No Guarantee of Profit or Protection from Loss

The Client understands and accepts that:

1. a) Leveraged trading is speculative and carries significant risk;
   b) The Company does not guarantee profit, capital protection, or risk elimination;
   c) No system, strategy, or algorithm can ensure consistent profitability;
   d) Any claim suggesting guaranteed returns or risk-free trading is misleading and must be disregarded.

17.4. Acceptance of Platform Terms and Execution Behavior

By trading through the Company’s Trading Platform, the Client acknowledges that:

1. a) Order execution is subject to slippage, latency, liquidity availability, and market volatility;
   b) Pending orders do not guarantee execution at requested prices;
   c) Stop-loss orders may be filled at significantly different prices during volatile or illiquid conditions;
   d) The Client remains fully responsible for all transactions executed under their login credentials.

17.5. Acceptance of Margin and Liquidation Procedures

The Client confirms that they:

1. a) Understand margin requirements and the implications of leverage;
   b) Accept that failure to maintain sufficient equity may result in automatic liquidation of positions (stop-out) without prior notice;
   c) Are aware of the specific margin call and stop-out levels applicable to Standard, ECN, and ECN Pro accounts;
   d) Accept full liability for any negative balance resulting from liquidation.

17.6. Confirmation of Eligibility and Compliance

The Client declares that:

1. a) They are legally permitted to trade leveraged OTC derivatives under the laws of their jurisdiction;
   b) They are not a resident or citizen of a prohibited jurisdiction, including the United States or North Korea;
   c) They will provide accurate, complete, and up-to-date documentation and information in accordance with AML/KYC requirements;
   d) They will notify the Company promptly of any changes affecting their legal or regulatory status.

17.7. Binding Effect

1. a) This Risk Disclosure Statement constitutes a legally binding component of the contractual relationship between the Client and the Company.
   b) By acknowledging and accepting this Statement (electronically or otherwise), the Client agrees to all terms, conditions, and provisions herein.
   c) The Client’s continued use of the Company’s services shall be deemed continuing acceptance of all risks disclosed herein.

17.8. Client Declaration

The Client hereby declares that:

1. a) They fully understand the nature and risks of trading the Financial Instruments offered by the Company;
   b) They have not been coerced, misled, or induced into trading by any unauthorized representation;
   c) They knowingly, voluntarily, and irrevocably assume all risks associated with leveraged OTC trading;
   d) They agree to use the Company’s services in accordance with applicable legal documents, including:

• The Client Agreement;
• The Terms of Business;
• The Order Execution Policy;
• The AML/KYC Policy;
• The Privacy Policy;
• The Bonus Terms and Conditions;
• Any supplementary policies issued by the Company.

17.9. Final Acceptance

By clicking “I Agree,” opening an account, placing a trade, or continuing to use the Company’s services, the Client confirms that they accept all risks described in this Statement and assume full responsibility for all consequences arising from their trading activities.

1. INTRODUCTION

1.1 This Anti-Money Laundering and Counter-Terrorist Financing Policy (“AML/CFT Policy”, “Policy”) has been developed by NPE Market Limited, a company registered in Saint Lucia under registration number 2024-00497, having its registered office at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros Islet, Saint Lucia, and its operational office at The One Tower, 24th Floor, Barsha Heights, Dubai, UAE (hereinafter the “Company”).

1.2 The Company is an international provider of online trading services in Foreign Exchange (Forex), Contracts for Difference (CFDs), Metals, Indices, Commodities, Cryptocurrencies and other OTC financial instruments. Due to the nature of these services, the Company is exposed to risks related to money laundering and terrorist financing (“ML/TF”) and therefore adopts strict preventive measures.

1.3 This Policy establishes the Company’s internal framework for identifying, assessing, mitigating, countering, monitoring, preventing, and reporting ML/TF risks. It operationalizes internal controls, procedures, responsibilities, and monitoring mechanisms aligned with international standards.

1.4 The Policy is binding upon:

• All Company directors
• All employees (permanent, temporary, and outsourced)
• All agents, partners, IBs, affiliates
• All service providers directly involved in KYC/AML processes

1.5 The Company maintains zero tolerance toward the use of its products or services for money laundering, terrorism financing, fraud, illegal activity, or abuse.

2. PURPOSE OF THE POLICY

2.1 The main purpose of this Policy is to create a comprehensive AML/CFT regime that aligns with internationally recognized anti-financial crime standards, including but not limited to:

• FATF 40 Recommendations
• Basel AML Index Principles
• Wolfsberg Group Financial Crime Standards
• International best practices for OTC derivatives brokers
• Offshore supervisory norms applicable to financial institutions

2.2 Specifically, this Policy aims to:
a. Prevent the Company from being used for ML/TF or financial crime
b. Ensure a risk-based approach to onboarding, monitoring, and risk-scoring clients
c. Define acceptable and prohibited client activities
d. Establish CDD, SDD, and EDD procedures
e. Establish sanctions screening procedures
f. Ensure timely submission of Suspicious Activity Reports (SARs)
g. Implement strong record-keeping standards
h. Ensure constant staff training
i. Support effective internal audits and AML governance

3. LEGAL & REGULATORY FRAMEWORK

Although registered in Saint Lucia, the Company voluntarily aligns with the highest global AML/CFT standards because it operates internationally, serves clients globally, and uses international banking and payment systems.

The Company’s AML/CFT framework is aligned with:

3.1 FATF (Financial Action Task Force) Standards

Including risk assessments, customer due diligence, record-keeping, beneficial ownership identification, sanctions compliance, and reporting obligations.

3.2 International AML Best Practices

Including Wolfsberg Principles, Basel AML Index methodologies, and global brokerage industry AML norms.

3.3 Local Obligations

The Company complies with the AML expectations applicable under Saint Lucia’s relevant FIU guidelines, as well as general offshore AML norms required for financial entities.

3.4 Guidance from Other International Regulators

Although not regulated by CySEC, ASIC, FCA, DFSA, or MFSA, the Company voluntarily follows the highest standards across these frameworks to ensure operational integrity, payment-processor acceptance, and global compliance.

4. COMPANY-WIDE AML/CFT GOVERNANCE STRUCTURE

4.1 Overall Responsibility
The Company acknowledges that the ultimate responsibility for the prevention of money laundering and terrorist financing rests with the Board of Directors. The Board approves the AML/CFT framework, sets the risk appetite, ensures adequate resources (human, technological and financial), and receives regular reports on the effectiveness of the AML/CFT controls.

4.2 Board of Directors
The Board is responsible for establishing and maintaining a strong compliance culture. It must review and approve the AML/CFT Policy, oversee its implementation, and ensure that systems, processes, and personnel are sufficient to identify, manage, and mitigate ML/TF risks. The Board monitors AML performance through periodic reporting, key risk indicators, and internal/external audit findings.

4.3 AML Compliance Officer (AMLCO)
The Company appoints a qualified AML Compliance Officer at management level, who acts as the central point of contact on AML/CFT matters. The AMLCO is responsible for:

• Implementing and maintaining the AML/CFT framework.
• Monitoring adherence to this Policy.
• Reviewing and approving high-risk customer relationships and enhanced due diligence cases.
• Assessing and investigating unusual or suspicious activities.
• Determining whether a Suspicious Activity Report (SAR) should be filed.
• Reporting regularly to the Board on AML/CFT issues.
• Ensuring that staff receive relevant training.
• Keeping up to date with changes in laws, regulations and best practices and updating the Policy accordingly.

4.4 Compliance Department
The Compliance Department, under the AMLCO, executes day-to-day AML tasks, including performing customer due diligence checks, sanctions screening, transaction monitoring, documentation review, and maintenance of AML files. The department ensures that all onboarding and ongoing monitoring processes conform to this Policy and internal procedures.

4.5 Operational Departments
Departments such as Customer Support, Payments, IB/Partnerships and Back-Office play a critical role in AML/CFT. They are required to follow internal procedures, promptly escalate red flags, and cooperate with the AMLCO and Compliance Department during investigations.

4.6 Independent Audit / Internal Audit Function
Where applicable, the Company ensures that its AML/CFT systems and controls are subject to independent audit or internal review at regular intervals. The purpose is to test the effectiveness of policies, procedures, monitoring tools, and staff awareness. Findings must be documented, reported to the Board, and remedial actions implemented within defined timelines.

4.7 Employee Responsibilities
Every employee, regardless of role, has a duty to be vigilant and to report promptly any suspicion or unusual activity to the AMLCO or the designated AML reporting channel. Failure to comply with AML obligations may result in disciplinary measures, up to and including termination of employment.

5. 
   RISK-BASED APPROACH (RBA)

5.1 Principle of RBA
The Company adopts a Risk-Based Approach to identify, assess, and manage ML/TF risks. This means resources are allocated proportionately: higher-risk customers, products, or channels are subject to more intensive due diligence and monitoring, while genuinely low-risk situations may attract simplified measures.

5.2 Firm-Wide Risk Assessment (FWRA)
The Company performs a Firm-Wide Risk Assessment on a periodic basis (at least annually or upon material changes). The FWRA considers, inter alia:

• Customer types (individuals, corporates, high-risk sectors);
• Products and services (Forex, CFDs, leverage levels, funding methods);
• Geographic exposure (countries of residence, source of funds, i.e. high-risk jurisdictions);
• Delivery channels (online onboarding, IBs, affiliates);
• Payment methods (bank transfer, cards, e-money, payment processors);
• Emerging typologies and regulatory findings.
  The FWRA identify inherent risks, evaluates existing controls, and determines residual risk, which informs the design of AML/CFT controls and risk appetite.

5.3 Customer Risk Assessment and Scoring
Each customer is assigned a risk rating (e.g. Low, Medium, High) based on objective and qualitative criteria such as nationality, residence, occupation, SOF/SOW, PE/PEP status, transaction behaviour, and product use. The risk rating determines the depth of due diligence and the intensity of ongoing monitoring.

5.4 Review and Updating of Risk Assessment
Risk assessments are not static. The Company periodically reviews risk models, thresholds, and parameters, especially where:

• New products or payment methods are introduced;
• New markets or jurisdictions are targeted;
• Regulatory or FATF publications indicate new risks;
• Internal incidents or suspicious patterns are identified.

6. 
   CUSTOMER ACCEPTANCE POLICY (CAP)

6.1 General Principle
The Company will only establish business relationships with customers whose identity is satisfactorily verified and whose activities can reasonably be expected to be legitimate. The Company reserves the absolute right to refuse to onboard any customer, or to terminate an existing relationship, based on AML/CFT grounds and internal risk appetite.

6.2 Prohibited Customers
The Company will not accept customers who:

• Fail or refuse to provide required identification documents;
• Provide forged, altered or otherwise unreliable documents;
• Are listed on applicable sanctions lists or are known to be associated with terrorism or organized crime;
• Are residents of jurisdictions that are subject to embargoes, international sanctions, or identified as high-risk and non-cooperative by FATF or similar bodies;
• Seek to maintain anonymous or fictitious accounts;
• Insist on unusual secrecy or avoidance of normal communication channels.

6.3 Customer Acceptance Criteria
Before accepting a customer, the Company ensures that:

• Full CDD has been conducted and documented;
• The client’s SOF/SOW is plausible and commensurate with expected activity;
• There is no positive match in sanctions or negative media screening;
• Any identified risk factors can be adequately mitigated through enhanced controls.

Where high or unmanageable risk is identified, the account will not be opened or will be closed.

7. CUSTOMER DUE DILIGENCE (CDD)

7.1 Purpose of CDD
Customer Due Diligence is the process of identifying and verifying the identity of a client and understanding their economic profile in order to assess ML/TF risk. CDD is applied before establishing a business relationship and, where appropriate, throughout the course of that relationship.

7.2 Standard CDD Measures
Standard CDD includes:

• Identifying the customer’s full name, date of birth, nationality, and residential address;
• Verifying identity using reliable, independent documents (e.g. passport, ID card, driving licence);
• Verifying address with acceptable proof (e.g. recent utility bill, bank statement);
• Obtaining information on occupation, employer, and approximate income level;
• Collecting information on the intended use of the trading account (e.g. personal trading, hedging, investment);
• Determining the source of funds (e.g. salary, business income, savings) and, where necessary, source of wealth.

7.3 Timing of CDD
As a general rule, CDD must be completed before activating the trading account or allowing any trading or withdrawal activity. In strictly controlled cases, the Company may permit limited account functions while verification is in progress, subject to conservative thresholds (e.g. low deposit limits, no withdrawals) and strict timeframes. Failure to complete CDD within such timeframes will result in account suspension or closure.

7.4 Ongoing CDD and Profile Refresh
CDD is not a one-off event. The Company periodically reviews and updates customer information, especially when:

• Significant changes occur in trading volume or funding patterns.
• The client updates key profile details.
• Alerts or red flags are raised by monitoring systems.
• Regulatory expectations require re-verification (e.g. after expiry of ID document).

8. 
   ENHANCED DUE DILIGENCE (EDD)

8.1 Situations Requiring EDD
Enhanced Due Diligence is applied where the risk is higher, such as:

• Customers from high-risk jurisdictions.
• Politically Exposed Persons (PEPs), their relatives and close associates.
• Customers operating in high-risk industries (e.g. money service businesses, crypto-related firms).
• Unusually complex corporate structures.
• Customers with large or inconsistent transaction volumes relative to their stated profile.

8.2 EDD Measures
EDD may include one or more of the following:

• Obtaining additional identification documents or certifications.
• Requesting detailed SOF/SOW evidence (e.g. salary slips, tax returns, business financials, sale contracts).
• Confirming corporate ownership and control structures, including UBOs.
• Conducting deeper adverse media screening and open-source intelligence checks.
• Requiring that first payments originate from a bank account in the customer’s name with a reputable financial institution.
• Seeking senior management approval before establishing or continuing the relationship.

8.3 Approval and Documentation
All EDD decisions must be documented in the customer file, including the rationale for the risk classification, the additional measures applied, and the final decision (acceptance, rejection, or termination). EDD cases must be reviewed by the AMLCO and, where necessary, escalated to senior management.

9. 
   SIMPLIFIED DUE DILIGENCE (SDD)

9.1 Conditions for SDD
Simplified Due Diligence may be applied only in strictly defined circumstances where the ML/TF risk is demonstrably low and there is no suspicion of money laundering or terrorist financing. Even under SDD, the Company must still identify the customer and retain essential information.

9.2 Scope of SDD
SDD may involve fewer verification steps or reduced frequency of review but does not mean that CDD is completely waived. It may apply, for example, to certain low-risk customers in low-risk jurisdictions with modest transaction volumes and clear SOF/SOW.

9.3 Prohibition of SDD in High-Risk Situations
SDD is not permitted where:

• The client is a PEP or related to a PEP.
• The client is from a high-risk or sanctioned jurisdiction.
• The client’s activity is inherently risky or complex.
• There is any suspicion or reasonable doubt.

10. 
    BENEFICIAL OWNERSHIP IDENTIFICATION

10.1 Requirement to Identify Beneficial Owners
For legal persons and arrangements (e.g. companies, partnerships, trusts), the Company must identify and, where applicable, verify the ultimate beneficial owner(s) (“UBO”), being the natural person(s) who ultimately own or control the customer or on whose behalf a transaction is being conducted.

10.2 Methods of Determination
The Company obtains corporate documents (certificate of incorporation, share registers, memorandum and articles, etc.) and, where necessary, declarations from directors to establish the ownership structure. All natural persons with a significant ownership or control interest (e.g. ≥10% or as per internal threshold) must be identified and, where required, KYC performed on them individually.

10.3 Complex Structures and Control Through Other Means
Where ownership structures are layered, involve nominees, or use offshore entities, the Company must take reasonable steps to trace the ownership to the ultimate natural person(s). Beneficial ownership is not limited to legal shareholding; it may also arise through control rights, voting rights, contractual arrangements, or other means. Relationships that cannot be properly understood or explained may be declined or terminated.

11. 
    ONGOING MONITORING OF BUSINESS RELATIONSHIPS

11.1 Purpose
Ongoing monitoring is essential to ensure that customer transactions remain consistent with the Company’s knowledge of the customer, their business and risk profile, including, where necessary, the source of funds.

11.2 Monitoring Methods
The Company uses a combination of automated and manual monitoring techniques that may include:

• Threshold-based alerts;
• Pattern recognition (e.g. unusual trading or transfer patterns);
• Behavioural monitoring (e.g. sudden spikes in activity, frequent funding/withdrawal cycles);
• IP address and device monitoring.

11.3 Examples of Monitoring Criteria
The Company pays particular attention to:

• Sudden and unexplained increases in deposits or trading volume;
• Frequent deposits followed by immediate withdrawals with little or no trading activity;
• Use of multiple payment methods or accounts not previously declared;
• Repeated attempts to bypass or delay KYC/EDD;
• Activity that does not correspond to the customer’s stated profile, occupation or SOF/SOW.

11.4 Review and Escalation
Where monitoring flags unusual or potentially suspicious activity, the case is escalated to the Compliance Department and/or AMLCO for review. Additional information may be requested from the customer, transactions may be delayed or blocked, and, where justified, an internal suspicion report may be raised.

12. 
    TRIGGER EVENTS FOR MANUAL REVIEW

12.1 Definition of Trigger Events
Trigger events are circumstances or patterns that warrant a manual review of the customer relationship and activity. These events may indicate increased risk, changes in circumstances, or potential misuse of the account.

12.2 Examples of Trigger Events
Trigger events include, but are not limited to:

• Change of residence to a higher-risk jurisdiction;
• Change in beneficial ownership or corporate structure;
• Significant increase in trading, deposit or withdrawal volume without clear economic rationale;
• Receipt of negative media information about the customer;
• Use of VPNs, proxies or other obfuscation tools to hide location in a suspicious manner;
• Requests for unusual withdrawal routing (e.g. different currencies, multiple third parties);
• Internal or external requests for information from regulatory, law enforcement, or banking partners.

12.3 Handling Trigger Events
Upon a trigger event, the Company conducts enhanced review, which may include:

• Re-confirmation of identity and address;
• Requesting updated SOF/SOW evidence;
• Imposing temporary restrictions on account activity;
• Re-assessment of risk rating;
• Decision whether to continue, restrict or terminate the relationship.

13. 
    SUSPICIOUS ACTIVITY REPORTING (SAR)

13.1 Duty to Report
Any employee who identifies or suspects that funds or activity may be linked to money laundering, terrorist financing, fraud, or any other financial crime must report the suspicion without delay to the AMLCO or the designated reporting channel, in accordance with internal procedures. This duty exists regardless of transaction amount.

13.2 Assessment of Suspicion
The AMLCO examines internal reports, reviews supporting documentation, and determines whether the suspicion is justified. Where appropriate, the AMLCO may request additional information from internal systems or from the customer, provided that such request does not amount to “tipping-off”.

13.3 Filing SARs with Authorities
If the AMLCO reasonably believes that activity may be linked to ML/TF or related offences, a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) is submitted to the relevant Financial Intelligence Unit or competent authority in accordance with applicable law. The customer must not be informed of the SAR filing.

13.4 Post-Reporting Measures
Following SAR submission, the Company may:

• Freeze or restrict the customer’s account;
• Decline to process further transactions;
• Terminate the business relationship;
• Co-operate fully with law enforcement.

14. PROHIBITED ACTIVITIES AND PRACTICES

14.1 Anonymous or Fictitious Accounts
The Company strictly prohibits anonymous, fictitious, or numbered accounts. All relationships must be fully identifiable and documented.

14.2 Third-Party Payments (Unjustified)
Deposits or withdrawals from/to unrelated third parties are generally not permitted unless specifically justified, documented, and approved under EDD procedures (e.g. corporate accounts, verified related parties). Suspicious third-party payments are rejected and may be reported.

14.3 Use of the Trading Account as a Payment Channel
The trading account may not be used as a general payment/transfer facility. The Company does not permit customers to route unrelated third-party funds via its accounts without genuine trading activity.

14.4 Use of False or Forged Documents
The provision of false, altered, or counterfeit documents is strictly prohibited and may result in immediate account closure, SAR filing, and possible reporting to authorities.

14.5 Use of High-Risk Payment Methods Without Transparency
Deposits via high-risk payment methods, including opaque e-wallets or crypto channels, may be limited, restricted, or prohibited, particularly when traceability and SOF are unclear.

15. 
    RECORD KEEPING

15.1 Retention Period
The Company keeps all AML relevant records for a minimum of five (5) years after the end of the business relationship or the date of the last transaction, whichever is later, or longer if required by applicable legislation or for the defence of legal claims.

15.2 Scope of Records
Records include, but are not limited to:

• KYC documents and verification evidence;
• Economic profile and risk assessment;
• Transaction and trading history;
• Payment details (deposits/withdrawals);
• Internal reports and SAR documentation;
• Correspondence with the customer relating to AML/CFT issues;
• Training records and AML program reports.

15.3 Format and Accessibility
Records may be held in physical or electronic form, provided they are secure, accurate and retrievable in a timely manner for regulatory, audit, or investigative purposes. The Company implements appropriate safeguards against unauthorized access, alteration, or destruction.

16. 
    PERSONNEL EDUCATION AND TRAINING

16.1 Objective of Training
The Company ensures that all relevant staff understand ML/TF risks, their personal responsibilities, internal procedures, and the consequences of non-compliance. Training enables employees to recognize red flags and handle customer interactions in compliance with AML/CFT obligations.

16.2 Scope of Training
Training programs cover, at minimum:

• Basic concepts of money laundering and terrorist financing;
• Relevant legal and regulatory obligations;
• Company policies and procedures;
• Customer acceptance and CDD/EDD requirements;
• Identification of suspicious activities and red flags;
• Reporting channels and protection of reporters;
• Sanctions compliance;
• Case studies and practical scenarios.

16.3 Frequency and Tailoring
New staff receive induction training upon joining. Thereafter, refresher training is provided at regular intervals (e.g. annually) or when material changes occur in laws, regulations, products, or risk exposure. Training content is tailored to departmental roles (e.g. support, payments, IB management, IT).

16.4 Records of Training
The Company maintains records of all training sessions, including dates, participants, topics covered, and materials used, for audit and supervisory review.

17. 
    INDEPENDENT REVIEW / AUDIT

17.1 Purpose
An independent review or internal audit of the AML/CFT framework is carried out periodically to assess whether policies, procedures and controls are adequate and effective in managing ML/TF risks.

17.2 Scope
The review assesses:

• Compliance with this Policy;
• Quality of CDD/EDD documentation;
• Effectiveness of sanctions screening and monitoring tools;
• Quality and timeliness of suspicious activity reporting;
• Adequacy of training and awareness;
• Implementation of previous audit recommendations.

17.3 Reporting and Remediation
Findings from the review are communicated to the Board and AMLCO, and an action plan is prepared to address any weaknesses identified. Progress on remediation is monitored until completion.

18. TECHNOLOGY, SYSTEMS AND CONTROLS

18.1 Use of Technology
The Company employs technological solutions to support efficient and effective AML/CFT controls, including automated KYC tools, sanctions screening engines, transaction monitoring systems, and risk-scoring models.

18.2 System Calibration and Maintenance
Systems are calibrated to reflect the Company’s risk appetite and updated regularly to address emerging threats, regulatory changes, and new products. Parameters such as thresholds, risk indicators, and alert rules are periodically reviewed and tested.

18.3 Human Oversight
Technology does not replace human judgement. Alerts and system outputs are reviewed by trained staff, and decisions on high-risk or complex matters are escalated to senior compliance personnel or the AMLCO.

19. 
    RELATIONSHIP WITH INTRODUCING BROKERS (IBs) AND PARTNERS

19.1 Role of IBs and Partners
IBs and partners may introduce customers to the Company. However, IBs and partners do not relieve the Company of its responsibility to perform its own AML/CFT obligations.

19.2 Due Diligence on IBs
The Company performs due diligence on IBs and partners to understand their business, reputation, regulatory status (if any), and AML controls. High-risk IBs may be rejected or subject to additional oversight.

19.3 Responsibilities of IBs
IBs must:

• Not engage in any activity that facilitates ML/TF;
• Not misrepresent the Company’s services;
• Not handle client funds unless explicitly authorized and properly regulated;
• Co-operate fully with the Company’s AML/CFT requirements;
• Immediately report any suspicious conduct by their referred clients.

19.4 Monitoring and Termination
The Company monitors IB-related activity for unusual patterns (e.g. clusters of high-risk clients, repeated bonus or promotion abuse). The Company reserves the right to suspend or terminate IB agreements where AML/CFT concerns arise.

20. 
    REFUSAL OR TERMINATION OF BUSINESS RELATIONSHIPS

20.1 Right to Refuse
The Company reserves the right to refuse to open an account or to provide services where AML/CFT concerns cannot be mitigated, or where the customer fails to satisfy CDD/EDD requirements.

20.2 Right to Restrict or Terminate
The Company may freeze, restrict, or terminate an existing relationship if:

• There is a suspicion of ML/TF;
• The customer refuses to provide additional information or documents;
• The customer is identified on a sanctions list;
• The customer engages in abusive, fraudulent or deceptive behaviour;
• Requests of competent authorities require such action.

20.3 Non-Liability
To the maximum extent permitted by applicable law, the Company bears no liability for losses or damages incurred by any person as a result of measures taken in good faith to comply with AML/CFT obligations, including refusal, restriction, or termination of services.

21. REVIEW AND AMENDMENT OF THIS POLICY

21.1 Periodic Review
This AML/CFT Policy is reviewed at least annually, or more frequently if required by changes in business model, regulatory expectations, FATF guidance, or identified deficiencies.

21.2 Amendments
The Board approves material changes to this Policy, based on recommendations from the AMLCO and senior management. Updated versions are communicated internally and, where relevant, made available to stakeholders.

1. INTRODUCTION

1.1 This Privacy Policy (“Policy”) is issued by NPE Market Limited, a company registered under the laws of Saint Lucia, registration number 2024-00497, having its registered office at Ground Floor, The Sotheby Building, Rodney Village, Rodney Bay, Gros Islet, Saint Lucia, and operational office at 24th Floor, The One Tower, Barsha Heights, P.O. Box 390114, Dubai, United Arab Emirates (“NPE Market”, “Company”, “we”, “us”, “our”).

1.2 The purpose of this Policy is to describe how the Company, acting as a data controller with respect to personal information under its possession, collects, processes, stores, transfers, and protects information pertaining to natural persons (“Client”, “you”, “your”, “data subject”) in connection with the Company’s provision of Forex, CFDs, commodities, indices, metals, cryptocurrencies, and other OTC derivatives trading services.

1.3 This Policy applies to:

• Current Clients

• Prospective Clients

• Website visitors

• Users of the NPE Market trading platform

• IBs, affiliates, and partners

• Former Clients whose data is retained for compliance or legal purposes

1.4 By registering on our website, submitting documents, opening an account, using our platform, or interacting with the Company, you acknowledge that you have read and understood this Privacy Policy and that you consent to the data processing practices described herein.

1.5 This Policy does not apply to any third-party websites or services linked from our website, payment providers, or external parties not under our direct control.

2. DEFINITIONS

For purposes of this Policy:

• “Personal Data” means any information relating to an identified or identifiable natural person.

• “Processing” means any operation performed on personal data including collection, storage, use, transfer, disclosure, modification, or deletion.

• “Data Controller” means the entity that determines the purposes and methods of processing personal data.

• “Data Subject” means an individual whose personal data is processed.

• “Third Parties” means service providers, partners, banks, payment processors, regulatory bodies, or affiliates to whom the Company may disclose personal information.

While certain terminology originates from GDPR, the Company is not subject to EU GDPR unless explicitly required by client jurisdiction.

3. CATEGORIES OF PERSONAL DATA WE COLLECT

In order to provide our services, comply with regulatory standards, and ensure the integrity of our operations, NPE Market collects a range of personal information. Each category serves a specific legal, operational, or compliance purpose, and is processed in strict accordance with this Policy.

3.1 Identification and Verification Data
To establish a business relationship and verify your identity as required by Know-Your-Customer (KYC) and anti-money laundering (AML) regulations, we collect identification data such as your name, date of birth, nationality, residential address, and other demographic details. We also request copies of government-issued identification documents, including passports, national IDs, and driving licenses. Proof of address documents—such as utility bills or bank statements—are collected to confirm residency. In some cases, we may use video or biometric verification to authenticate your identity. This information ensures that we meet regulatory obligations, prevent illicit activity, and protect both the Company and clients from fraud or impersonation.

3.2 Contact Information
We collect contact data including your email address, phone number, and communication preferences. This information is used to contact you regarding account activity, verification procedures, platform updates, security alerts, or any obligations arising from our contractual relationship. Accurate contact information is essential for us to maintain effective communication and provide timely notifications related to your trading activities.

3.3 Financial and Trading Information
To deliver trading services, process transactions, and prevent financial abuse, we collect information relating to your trading accounts and financial activity. This includes account numbers, balances, positions, deposits, withdrawals, and trade history. We may collect details about your payment methods and bank accounts; however, we do not store sensitive card details. This data enables us to execute your trades, provide statements, ensure proper functioning of your account, and comply with regulatory requirements related to trade monitoring, audit trails, and financial reporting.

3.4 AML, KYC, and Regulatory Compliance Data
In accordance with international AML/CTF standards and the Company’s legal obligations, we collect information intended to assess financial risk and verify the legitimacy of your funds. This may include your employment status, source of wealth, source of funds, tax residency, financial profile, FATCA or CRS information, and PEP (Politically Exposed Person) status. These data points help us identify potential risks, detect suspicious activity, and fully comply with anti-money-laundering regulations applicable to OTC financial service providers.

3.5 Technical and Platform Usage Data
When you access our websites, trading platforms, or mobile applications, we collect technical data such as IP addresses, device identifiers, operating systems, browser types, access times, and platform usage logs. We use this information for cybersecurity, fraud prevention, platform optimization, session management, and identification of unusual login activity. Technical data is essential to ensure the security and stability of our trading environment and to protect both users and the Company from unauthorized or malicious activity.

3.6 Optional and Voluntarily Submitted Data
From time to time, you may provide additional personal information through surveys, feedback forms, marketing opt-ins, or participation in promotions. You may also provide preferences regarding trading instruments, educational content, or communication methods. Submission of such data is optional and is processed only with your consent for customer experience enhancement or product development.

4. LEGAL BASES FOR PROCESSING PERSONAL DATA

Although NPE Market is an offshore entity and not legally bound by GDPR, we voluntarily adopt internationally recognized principles that help define the legal foundations on which personal data is processed. Doing so increases transparency, supports best business practices, and enhances client trust.

4.1 Processing Necessary for Performance of a Contract
When you open an account or register with NPE Market, you enter into a contractual relationship with the Company. To fulfill our obligations under that agreement, we must process your personal data to verify your identity, operate your trading account, process your deposits and withdrawals, execute trades, and provide access to our trading platforms and support services. Without this information, we cannot deliver the products and services you request.

4.2 Processing Necessary for Compliance with Legal Obligations
As a financial services provider, we are subject to AML, CTF, fraud prevention, taxation, and financial reporting regulations. These obligations require us to collect, verify, store, and analyze personal data for purposes such as identity verification, risk assessment, sanctions screening, transaction monitoring, and maintaining records for regulatory inquiries. Failure to collect this data would place the Company in breach of mandatory compliance standards.

4.3 Processing for Legitimate Interests
We may process personal data to advance our legitimate business interests, provided these interests do not override your rights. Such interests include protecting our systems, preventing unauthorized access, enhancing cybersecurity, maintaining platform performance, investigating suspicious activity, improving customer service, developing new features, performing analytics, and defending legal claims. These activities are essential for the stability, reliability, and lawful operation of our business.

4.4 Processing Based on Consent
Where required, such as in the case of marketing communication or certain optional features, we process personal data only after obtaining your explicit consent. You retain the right to withdraw this consent at any time. Withdrawal of consent does not affect the lawfulness of prior processing carried out before the withdrawal.

5. PURPOSES OF DATA PROCESSING

We process personal data for clearly defined purposes aligned with our business operations and regulatory obligations. These purposes are intentional, necessary, and consistent with best practices in financial services.

5.1 Establishing and Managing Your Account
We use personal data to review your application, confirm your identity, assign an account number, configure account settings, and provide you access to trading environments. Without processing your identification and financial information, we cannot engage in a contractual relationship or legally permit trading activity.

5.2 Delivering and Improving Our Services
Data is used to execute your trades, assess market exposure, maintain account security, process deposits and withdrawals, and manage ongoing operations of the trading platform. We may analyze platform usage to improve stability, optimize features, and enhance user experience.

5.3 Ensuring Legal and Regulatory Compliance
We process data to comply with AML/CTF regulations, monitor for suspicious behavior, produce required reports, prevent fraud, respond to regulatory inquiries, meet audit obligations, and uphold industry standards for dealing with financial crime.

5.4 Safeguarding the Platform and Your Account
Technical data helps us protect the platform from unauthorized access, cyberattacks, and abuse. We monitor access patterns, verify device integrity, assess login behavior, and detect irregularities that may indicate account compromise or misuse.

5.5 Communications and Notifications
We use your personal data to provide important notifications such as account updates, trade confirmations, margin calls, security alerts, service-related messages, or changes to terms. Such communication is essential for safe and effective account management.

5.6 Marketing and Promotions (Optional)
With your consent, we may use your data to send promotional materials, educational content, or product updates. You may opt out at any time using links provided in our communications.

6. COOKIES AND TRACKING TECHNOLOGIES

Cookies are small text files stored on your device that help us improve website functionality, personalize your experience, and analyze performance.

6.1 Purpose of Cookies
Cookies allow us to remember your preferences, maintain login sessions, enhance loading speeds, provide a consistent user experience, and understand how visitors interact with our website. They help identify errors, optimize user journeys, and improve performance of both web and mobile platforms.

6.2 Types of Cookies Used
We may use essential cookies required for platform operation, analytical cookies for performance measurement, preference cookies to remember user settings, and security cookies to detect fraudulent or unauthorized behaviour.

6.3 Managing Cookies
You may disable cookies in your browser settings. However, disabling essential cookies may impair access to the trading platform or reduce website functionality.

7. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

To operate effectively and comply with legal, technical, and regulatory standards, certain personal data must be shared with trusted third parties. We do so carefully, responsibly, and only when necessary.

7.1 Service Providers and Vendors
We may share data with third-party service providers who support our operations, including KYC verification vendors, AML screening firms, payment processors, banks, liquidity providers, cloud hosting services, CRM operators, and technical infrastructure providers. These parties act under binding confidentiality obligations and process data only according to our instructions.

7.2 Legal, Regulatory, and Government Authorities
Where legally required, we may disclose data to courts, law enforcement agencies, financial regulators, tax authorities, or other governmental bodies. Such disclosure occurs only when mandated by law or necessary to protect our legal rights.

7.3 Internal Departments and Affiliates
Access to personal data is restricted to authorized personnel involved in compliance, risk management, payments, IT security, customer support, and senior management. Access is granted strictly on a “need-to-know” basis.

7.4 Protection Against Fraud and Abuse
We may disclose data to fraud prevention agencies, investigation partners, cybersecurity auditors, or other specialized entities for the purpose of preventing or investigating fraudulent activities, market abuse, or platform misuse.

7.5 No Sale of Personal Data
Under no circumstances do we sell or trade personal data for commercial gain.

8. INTERNATIONAL TRANSFERS OF PERSONAL DATA

Because we operate globally, your data may be processed or stored in jurisdictions outside your country of residence. These transfers are necessary for platforms, infrastructure, support services, payment processing, and global operations.

8.1 Jurisdictions Involved
Data may be transferred to data centres or partners located in Saint Lucia, the UAE, the EU, Asia, or the United States. Such jurisdictions may have different levels of data protection, but we ensure that your information is handled securely.

8.2 Safeguards for International Transfers
We only work with third parties who provide adequate data protection standards, contractual safeguards, or recognized information security frameworks. By using our services, you authorize such international transfers as required for the execution of your agreement.

8.3 Operational Necessity
These transfers enable our trading platforms to function efficiently and allow us to provide uninterrupted, high-quality service to clients worldwide.

9. DATA SECURITY MEASURES

Protecting your personal data is a core operational priority. We apply a combination of administrative, technical, and organizational measures to prevent unauthorized access, loss, alteration, or misuse of personal information.

9.1 Technical Protection Measures
We use advanced encryption technologies for data transmission and storage, secure server environments, firewalls, intrusion detection and prevention systems, anti-malware protection, and multi-factor authentication for sensitive access points. We continuously monitor our systems for anomalies, attacks, and unauthorized behavior.

9.2 Organizational and Administrative Controls
Only authorized employees with a legitimate operational need may access personal data. Each employee is bound by confidentiality obligations and trained in data protection practices. Internal procedures govern access permissions, audit trails, data segmentation, and secure disposal of information once retention periods expire.

9.3 Incident Prevention and Response
We implement strict cybersecurity standards to minimize the risk of data breaches or unauthorized access. In the event of a suspected incident, we follow a structured incident response protocol designed to protect affected clients, secure systems, and meet any legal notification obligations in applicable jurisdictions.