Customer Complaint Dated September 2nd 2025

Complaint Matter

Mr. XXX has lodged this complaint with the Financial Commission on the following grounds:

The Client used account # XXX (JPY) for active operations with the financial instruments of the

FX market. On the day of the incident, in the period from 04:51 to 16:37 (server time, UTC+3) the Client performed 58 short-term trades with the financial instrument XAUUSD on the specified account. The total financial outcome of this series of trades was a profit of 283,225 JPY. The Client sometimes attached pending Take Profit / Stop Loss orders to his open positions to secure potential profits / limit potential losses on them.

The incident on the Client’s account occurred on September 2, 2025, in the period between 16:38 and 17:07. At the specified time, the Client opened a new Short position # 5059474106 in the financial instrument XAUUSD with a volume of 2.01 lots, the highest ever recorded. According to the Client, during the period of the incident, there was a serious technical problem with the Broker’s trading platform. The Client claims that during this period, the disputed position could not be closed for an extended period and the platform displayed an error stating “Lot size is incorrect”. At the same time, profit-taking and stop-loss settings also displayed the same error and could not be configured. As a result, the Client was unable to manage his open position and the relevant trade was liquidated by the Broker due to lack of margin.  (Stop Out). The Client alleges that the primary cause of the financial loss totaling 259,052 JPY resulting from the incident was the incorrect operation of the Broker’s platform.

The Client further clarifies that he contacted the Broker about this matter via chat multiple times, but ultimately could not close the disputed position for a long time and suffered losses. Also, shortly after the incident, the Client attempted to open and then immediately close a different position with a lower volume of 0.11 lots (# 5059495351), which was successful.

The Client is not satisfied with the Broker’s decision on this complaint (see below), holds the Broker responsible for the financial losses caused by the incident and requires compensation from the Broker. The Client believes that a fair settlement to the dispute would be a monetary compensation equivalent to the financial loss of 259,052 JPY that resulted from the trading platform disruption.

In this regard, the Client requests that the Dispute Resolution Committee of the Financial Commission verify the integrity of the Broker’s platform, as well as the Broker’s conduct after the incident. The Client has provided the investigation with the screenshot of the platform showing error message “The lot number is incorrect, please re-enter”, the screenshot showing the history of trades performed on the Client’s account, as well as the email / live chat communication with the Broker regarding the incident, as documentary evidence.

In turn, the Broker does not see any grounds for the Client’s complaint, since in their opinion, the Client had full control of their trading activities during the incident period and should therefore bear all risks associated with their chosen trading strategy. According to the Broker, during the period of the incident no errors or failures in the operation of services were registered on the Company’s side. The Broker has provided the investigation with the history of the Client’s trading / non-trading operations, the server log records for the period of the incident, as well as the email communication with the Client regarding the incident, as documentary evidence.

Complaint Response

The decision on this complaint is based on the information provided by the Broker and Mr. XXX.

After a comprehensive analysis of the documentary evidence provided by the Client and the Broker the Dispute Resolution Committee of the Financial Commission has come to the following conclusions:

First of all, it should be noted that, according to the information received from the Broker:

Based on the results of internal investigations, it was found that the Complainant had not tried to place any Stop-Loss or Take-Profit orders and / or close the disputed position, as alleged.

There is no evidence of a platform disruption or systemic malfunction on trading servers during the period in question.

Upon receiving the enquiry, the Company requested the Complainant to provide the account journal on three separate occasions so that it could properly review and assess the allegations.

The Complainant failed to provide any journal or other evidence to support his claim in the the Broker’s investigation.

In the opinion of the Broker, it is possible that the Complainant encountered localised connectivity issues, such as regional ISP routing issues, mobile device instability or firewall configurations, which could affect access to the trading platform intermittently.

Second, the Broker believes that the aforementioned external factors fall outside the scope of the Broker’s infrastructure and are not uncommon in retail trading environments. Therefore, the Broker is certain that the liquidation of disputed position # 5059474106 was caused solely by the Complainant’s failure to maintain sufficient funds in the account and is unrelated to the platform infrastructure or performance. In this regard, in support of its position, the Broker refers to the relevant provisions of their regulatory documents:

Clause 3.6(l)(viii):

The Complainant acknowledges the significant risks associated with trading through Online Services, which rely on computer and telecommunications systems.

…

Clause 3.6(l)(xi):

The Complainant is responsible for maintaining alternative arrangements for executing Orders or accessing services if the Online Services become unavailable or experience failure.

…

Clause 3.6(n):

the Broker is not obligated to ensure uninterrupted, continuous, or error-free access to the Online Services.

…

Clause 4.2(a):

The Complainant must maintain such amounts of Margin as it may require under the Agreement.

…

Clause 4.2(f):

It is the Complainant’s obligation to ensure that the Account is sufficiently funded to cover the required margin. If the Complainant fails to maintain the margin required, the Broker has the right to close out the Complainant’s open positions without prior notice.

Third, according to the information received from the Client, the terminal journal logs that the Broker requested for their internal investigation, could not be obtained from the location described by the Broker. The Client asserts that he informed the Broker about the log extraction issues and they said they would check with the relevant department. Unfortunately, no solution was provided by the Broker and the same conversation occurred again 10 days later. As a proof, the Client has provided the investigation with the screenshots showing the relevant communication with the Broker’s Support Team.

Fourth, the trading terms on the Client’s account suggest a floating spread and a Stop Out at 10% level. This information is clearly defined in the Broker’s regulatory documents / published on the Broker’s official website. By opening a trading account of the selected type, the Client agreed to accept the trading terms provided by the Company. In this regard it should be noted that, according to the information received from the Broker, in the period of the incident, as a result of the unfavorable change in the price of the financial instrument XAUUSD, the Equity / Margin ratio in the Client’s account fell below the critical level. Therefore, due to insufficient margin, the disputed position # 5059474106 was liquidated by the Broker. This fact is confirmed by the server log records provided by the Broker. In the period of the incident the Broker acted in full compliance with the provisions of their Client Agreement:

4.2. MARGIN OBLIGATIONS

…

1. d) The Client must maintain at least the amount of Margin required by the Broker whether or not the Broker gives any notice to the Client to make those payments or the Client has actual notice of the required amount. The required amount of Margin can change continuously, including over the weekend or other non‐trading day.
2. e) It is the Client’s sole responsibility to monitor at all times through the the Broker Trading Platform any notifications that the Broker may, but is not obliged to, provide, the Margin deposited or any Minimum Margin requirement under this Agreement having regard to such matters as:
3. i) your open Positions;
4. ii) the volatility of any relevant Underlying Instrument;

iii) the volatility of the Underlying Market and the markets generally;

1. iv) any applicable Exchange Rate risk; and
2. v) the time it will take for you to remit sufficient cleared funds to the Broker.

Fifth, in order to ensure an objective investigation of the case, the DRC requested historical price data for the financial instrument in the disputed transactions from other independent providers of financial services. Financial Commission uses several different sources, such as Tradeproofer, Tradefora, Verify My Trade, TrueFX, FX Benchmark and some others for the purpose of verifying the quality of trades’ execution. Comparison of the Broker’s quotes offered to the Client with the quotes received from independent sources confirmed the fact that at the time of the Stop Out event (September 2, 2025, at 17:07:31, UTC+3) the quotes on the financial instrument XAUUSD published by the Broker reflected the actual situation on the market.

Finally, the experts of the DRC believe that it is important to emphasize the following. In one of the screenshots provided as documentary evidence attached to his complaint, the Client demonstrates an error message generated by the Broker’s trading app at 22:44 (Japan Time, UTC+9). The indicated time corresponds to the period when the disputed trade was active. However, for the unknown reason, the Client refrained from capturing a video confirming the incorrect operation of the platform. Without such information, it is difficult to determine what caused the relevant error (if any). In this regard, in the event of unstable operation of the broker’s trading platform, the DRC experts recommend that clients record a video to obtain more reliable evidence. Also, another important aspect of the incident should not be overlooked in this case: on the day of the incident, after accumulating certain amount of profits in the series of short-term trades, the Client gradually increased the volume of his trades. Obviously, the Client was ready to risk more in the case of the negative scenario, should the price of the financial instrument XAUUSD moved sharply against his position.

Summarizing all the above the Dispute Resolution Committee has ruled in favor of the Broker. Considering the circumstances of the case, as well as the documentary evidence provided by both parties to the dispute, the experts of the DRC have found that the disputed position # 5059474106 was liquidated correctly. There was no confirmation of any technical problems on the Broker’s side in the period of the incident. Also, the DRC agreed that, in general, the Broker acted in full compliance with the trading rules established by the Company during the incident. Nevertheless, as a gesture of goodwill, the DRC recommends that the Broker offer the Client a non-withdrawable bonus in the amount of the financial losses caused by the incident. The bonus funds can be used to as margin / equity to open / maintain positions, including to generate possible future profits, but will be removed proportionally when the Client chooses to perform withdrawal(s) of accrued profits following the credit of the bonus.

This complaint was reviewed by the members of the Dispute Resolution Committee of the Financial Commission and was processed by the Head of the Committee.

This complaint was reviewed by the members of the Dispute Resolution Committee of the Financial Commission and was processed by the Head of the Committee.

If you have any questions regarding this investigation, please send them to the following address: info@financialcommission.org

Acknowledgement

I certify that all information was considered by the Dispute Resolution Committee of the Financial Commission and hereby confirm that the decision was made fairly, impartially and without interference. I am confident that the information provided in the document is true.

Awards and Orders

• DRC decisions are binding on Brokers. DRC decisions are binding on clients only if they accept them.
• If complainant agrees with DRC’s decision, he’ll need to accept it within 14 days. If the Client does not respond to the DRC’s decision within 14 days the complaint is considered closed.
• Member must award the settlement within 28 days of when the decision was reached.
• If the decision was in favor of the Member, the Client must provide a release for the Member within 7 days of when the decision was made and the complaint is considered closed.
• The Compensation Fund will be only used should a Member refuse to adhere to a judgment from the Financial Commission or if a Member is removed from the Financial Commission without paying their outstanding judgments.
• The Compensation Fund will only cover judgments up to €20,000 per client.