| Complainant | Broker |
| Mr. XXX | The Broker |
| Financial Commission Complaint | # XXXXX |
| Complaint Raising Date | Complaint Filing Date |
| 06/10/2025 | 10/11/2025 |
Complaint Matter
Mr. XXX has lodged this complaint with the Financial Commission on the following grounds:
The Client used account # XXX for active trading operations with CFDs and financial instruments of the FX and cryptocurrency markets. By the time of the incident, the Client has carried 298 transactions with various financial instruments, earning a profit in the amount of 138,628 USD. Also, before the incident, the Client has successfully withdrawn a sum of 152,223 USD from their account.
Shortly before the incident, the Client closed with profits of 46,524 USD a series of profitable trades in the financial instrument BTCJPY, which were established in the period between 12:37 on Saturday, October 4, 2025 and 23:16 on Sunday, October 5, 2025.
The incident on the Client’s account occurred on October 6, 2025, at 10:30 (server time, UTC+3). At the specified time, the Broker reversed a withdrawal request of 40,000 USD submitted by the Client earlier.
The Client indicates that in early October, 2025, they manually executed several day trades via the MT5 smartphone app and generated about 40,000 USD in profits. According to the Client, the relevant trades were not related to scalping, so it did not violate any terms. Despite this circumstance, when they tried to withdraw funds, the Personal Area on the Broker’s official website stopped working. Even after contacting support, the Client only received a template email saying that they were working to resolve the issue.
The Client does not agree with the Broker’s decision (see below) and considers the actions of the Broker to be unfair. According to the Client, the Broker accused them of engaging in suspicious trading activity without providing any evidence. In this regard, the Client requests that the Dispute Resolution Committee of the Financial Commission review the disputed transactions for alleged breaches and requires that the Broker return the withheld funds in the amount of 90,061.02 USD (profits of 40,000 USD and initial deposit of 50,000 USD). The Client has provided the investigation with the screenshots showing the email communication with the Broker regarding the incident, as well as the status of their trading account with a balance of 100,061.28 USD, as documentary evidence.
In turn, the Broker claims that, based on their investigation, the Client’s transactions on account
# XXX violated their trading policies. The Client Agreement expressly prohibits suspicious trading activity, which includes market manipulation.
In support of its decision, the Broker has provided the investigation with the history of all trading and non-trading operations performed on the Client’s trading accounts, 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:
The Complainant opened their trading account # XXX on September 28, 2023.
Over the following two years the Client made multiple deposits totaling USD 110,271 and withdrawals totaling USD 152,223.
The Complainant’s account was flagged by the internal risk team as a loophole abuser engaging in Suspicious Trading Activity.
Therefore, a temporary withdrawal restriction was imposed on a precautionary basis, the Client’s account was placed on a withdrawal blacklist, and subsequent withdrawal requests remain unprocessed pending further review.
Second, the Broker further clarifies that abusive pattern that triggered the flag occurred over the weekend of 4–6 October 2025 and consisted of a deliberate synthetic USDJPY position created via the crypto pairs BTCUSD and BTCJPY while the cash Forex market (USDJPY) was closed.
Specifically, the Client systematically:
Went Long BTCJPY and simultaneously (or within seconds) went Short BTCUSD with precisely calculated lot sizes so that the USD-notional exposure was almost perfectly offset.
The combined position resulted in a synthetic long USDJPY exposure (i.e. betting that USD would strengthen against JPY over the weekend).
Because the cash USDJPY market is closed on weekends, the the Broker’s BTCJPY price continued to be updated from a different liquidity pool than BTCUSD, creating a temporary pricing discrepancy.
On Monday, October 6, 2025 when the cash Forex market reopened, USDJPY gapped sharply higher (driven by a major Japanese news event over the weekend). This gap was immediately reflected in the Broker’s BTCJPY pricing but not yet fully in BTCUSD, generating an instant and essentially risk-free profit of approximately USD 40,000.
Third, according to the Broker, the Client Agreement provides the Broker with discretionary power to take action where abusive, manipulative, or suspicious trading behavior is detected. This authority includes the ability to decline or reverse orders, restrict account access, and terminate the client relationship in appropriate circumstances. In this regard, in support of its position, the Broker refers to the provisions of Clauses 3.6(g), 9.3(b)(iv), 1.4(b) of the Client Agreement:
Clause 3.6(g):
“the Broker can delay, decline or reverse any Order if the Broker reasonably:
- suspects that the transaction might be unlawful or might be associated with financial crime;
- believes that by carrying out the transaction the Broker might breach our compliance obligations; or
iii. believes that the Client is in breach of this Agreement.”
Clause 9.3(b)(iv):
“If the Broker is made aware of or has reason to believe […] that the Client has engaged in Suspicious Trading Activity […] then the Broker at its sole discretion, may terminate this Agreement immediately by Notice to the Client…”
Clause 1.4(b)
“The Company reserves the right to proceed with immediate account termination, with or without prior notification to the client of the said breach… [and] is further entitled to reverse any profits accrued from suspicious trading and/or terminate the trading account and/or any account which can be found to be associated with such practices.”
The Broker states that collectively, these provisions form a robust legal basis for the Broker to take preventative and protective measures when trading behavior triggers internal surveillance alerts.
Fourth, in order to make an objective decision on this case, the DRC has analyzed the Client’s trading activity in their account # XXX:
The following non-trading operations were carried out on the Client’s account:
the total amount of deposits to the Client’s trading account was (+)110,271.00 USD;
the total amount of bonus credit offered by the Broker was (+)20,000 USD;
the total amount of withdrawals requested by the Client account was (-)192,223.00 USD;
the total amount of withdrawals reversed by the Broker was (+)40,000.00 USD;
the total amount of successful withdrawals made by the Client was (-)152,223.00 USD;
the difference between deposits and withdrawals amounted to (-)41,952.00 USD.
Analysis of the nature of the disputed transactions carried out by the Client revealed that:
The Client’s trades were made in the period from 05.07.2024 to 23.10.2025.
The Client’s trades were mostly made with the financial instruments: BTCUSD, XAUUSD, BTCJPY.
The Client’s trades were carried out during the hours of both active and inactive market.
The volume of trades carried out by the Client varied from 0.01 lots to 60 lots.
The duration of the Client’s trades ranged from less than 1 minute to several days.
Analysis of the financial results of transactions performed by the Client revealed that:
After 334 transactions the Client has made net profits in the amount of 138,905.98 USD.
The share of profitable trades was 70.36 % or 235 trades.
The share of unprofitable trades was 29.64 % or 99 trades.
Fifth, the DRC has verified the validity of the Broker’s assertion regarding the Client’s use of the dishonest methods of trading for making profits. For this purpose, the DRC has examined the documentary evidence provided by the Broker, as well as the history of price data on the financial instruments in the disputed transactions, received from independent providers of financial services. To ensure an objective investigation Financial Commission uses several different sources, such as Tradeproofer, Tradefora, Verify My Trade, TrueFX, FX Benchmark and some others for the purpose of verification of the quality of trades’ execution. Analysis of the execution quality of the disputed trades performed on trading account # XXX in the period between 04.10.2025 and 06.10.2025 showed that the vast majority of them were opened and/or closed at acceptable prices.
Finally, the Broker indicates that the Client utilized an illegal market manipulation strategy to generate risk-free profits. The Broker acknowledged that the Client’s strategy was illegal, but the DRC found no evidence that the Client was exploiting vulnerabilities in its software and / or infrastructure for profit. The Broker broadcast quotes for the financial instrument BTCJPY on its trading platform and, as such, has the ability and implied responsibility to hedge its exposure at all times, including the weekend. If the Broker had a risk monitoring system and a risk team on duty, they would have definitely noticed the sudden increase in JPY exposure over the weekend and hedged it, establishing the same position for the Broker’s benefit.
Given that there was a split vote in reaching a final decision on this complaint, the DRC experts believe that it (final decision) should be a compromise and assume partial responsibility of the Broker. In the general opinion of the DRC members, this is the most logical path forward for both maintaining Client goodwill (with a payout) and forcing a necessary, immediate improvement to the Broker’s operational security and liquidity management. As such, the DRC members agreed that the following would be a fair resolution in this case:
Pay the Client 50% of the profit made in a series of the disputed trades.
Either close the Client’s account # XXX, or
Place the Client’s account on A Book (this is a discussion with the Client);
If the account is closed, return the Client’s balance from October 4, 2025 (before the disputed trades were initiated).
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.
| Ruled in Favor | Compensation |
| Mr. XXX | 23,262 USD |
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.
| Signature | Designation | Date |
| Anatoly Bulanov | Head of DRC | 22/01/2026 |
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.