Customer Complaint Dated March 24th 2026

Complaint Matter

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

The Client used account # XXX (USD) for trading operations in the financial instruments of the FX market. Prior to the incident, in the period between 04.03.2026 and 20.03.2026 the Client performed 156 trading operations in the financial instrument XAUUSD and earned a profit of 1,350.37 USD from the relevant trades. Also, in the specified period the Client successfully withdrew a sum of 1,635 USD from their account.

The incident on the Client’s account occurred on 24.03.2026 at 09:55 (server time, UTC+2). At the specified time the Broker applied a cash adjustment to the Client’s account balance. As a result, a sum of 5,243.29 USD was deducted from the relevant account by the Broker. Shortly after, the Client was accused by the Broker of violating the Company’s trading rules via email.

The Client claims that the Broker has blocked their account and confiscated legitimate profits for no apparent reason, as in the Client’s opinion, none of the Broker’s rules have been breached. According to the Client, they made profits through non-fraudulent transactions.

The Client further alleges that they were was asked to pay 500 USDT to a private address ([wallet address redacted]). According to the Client, this sender had full access to their private account details and was aware of the deduction amount made by the Broker. The Client is of the opinion that if this is an official request, then it is a criminal extortion; if it is a scammer, it proves a massive data breach by the Broker.

The Client does not agree with the Broker’s decision on their complaint (see below) and considers the actions of the Broker to be unfair. According to the Client, the Broker deducted USD 5,243.29 from their account without providing any trade evidence or specific logs. 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 funds in the amount of 5,243.29 USD belonging to them. The Client has provided the investigation with screenshots of emails sent from an alleged Trading Support account ([email address redacted]) regarding the dispute, as well as the history of trading/non-trading operations performed on their account # XXX, as documentary evidence.

In turn, the Broker claims that, based on their investigation, the Client’s transactions on trading account # XXX violated their trading policies. The Client Agreement expressly prohibits suspicious trading activity, which includes gap trading. According to the provisions of Section 1.4.b.v of the Client Agreement, the Company reserves the right to withdraw any credit and cancel associated profits where the Complainant is reasonably suspected of engaging in Suspicious Trading Activity:

1.3. DEFINITIONS AND INTERPRETATION

Whenever used in this Agreement, unless inconsistent with the subject matter or context, the following words shall have the following meanings:

Suspicious Trading Activity means any belief or decision of the Broker, in its sole discretion, regardless of whether it has been communicated to the Client or not, that the Client has, either acting alone or with other persons, used the Online Service in a way which affects the integrity or effective functioning of the Online Services or the Broker’s market for CFDs and Margin FX, or the market for the Underlying Asset to which the CFD or Margin FX contract relates whether or not such conduct is also illegal or also constitutes market abuse. Such conduct includes but is not limited to: …

1. f) engaging in any trading behaviors which are deemed exploitative, dishonest, abusive, or a good faith violation.

1.4. CLIENT REPRESENTATIONS AND WARRANTIES …

1. b) The Client represents and warrants to the Broker that: …
2. v) The Client will not, either acting alone or with others, engage in conduct which results in Suspicious Trading Activity as defined in this Agreement. If the Broker has reasonable ground to suspect that the Client engages in Suspicious Trading Activity, the Broker reserves the right to temporarily or permanently suspend the Client’s trading account, recover any losses incurred in connection with the Suspicious Trading from the Client and/or void the Client’s Orders and cancel any associated profits, with immediate effect.

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 account # XXX, as documentary evidence.

Complaint Response

The decision on this complaint is based on the information provided by the brokerage company 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:

1. First of all, it should be noted that according to the information provided by the Broker:
2. a) The Complainant accepted the Client Agreement and associated legal documents at account opening with the Broker.
3. b) The Complainant engaged in trading activity on their account # XXX.
4. c) Following internal Risk Control review, the Risk Team identified prohibited gap trading in the Complainant’s account.
5. d) Consequently, the profits from the relevant trades, which violated the Company’s trading policies, were deducted.
6. Second, the Broker further clarifies that they conducted a detailed assessment of the Complainant’s trading behavior using both transactional data and risk analytics. According to the Broker, trading account # XXX displayed multiple concurrent characteristics that collectively match the Broker’s established criteria for suspected gap trading and abusive trading behavior, including the following:
7. a) Limited instrument diversification The trading statement shows that 100% of trades were executed exclusively on XAUUSD, with no diversification into any other instruments. This extreme concentration is a hallmark of gap- trading strategies that specifically target the volatility and gap characteristics of Gold.
8. b) Trading patterns consistent with gap trading A significant number of positions were opened immediately prior to potential market gaps (including overnight holds, weekend closures, and periods around market close) and closed after the gap materialized, directly capturing price discrepancies. Specific examples include:

• Multiple 0.5-lot Buy/Sell clusters opened on 2026.03.06 (Friday) at approximately 10:14–10:15 around 115.xx and closed on 2026.03.09 / 2026.03.10 (post-weekend), realizing profits from the weekend gap.
• Further 0.5-lot clusters opened on 2026.03.12 around 16:56–17:01 (146–151 range) with some positions held overnight into 2026.03.13 01:01.
• 0.7-lot Buy/Sell clusters opened on 2026.03.13 around 19:29–19:33 (043.xx range) with positions held into 2026.03.16 01:01.

1. c) Repetition of profit-generation cycles Repetitive trade cycles featured clusters of near-simultaneous small-to-medium lot entries (0.01–0.03 early, scaling to 0.5–0.7) at nearly identical prices and timestamps, indicating a systematic rather than discretionary approach.

The Broker asserts that taken together, these factors triggered the Broker’s compliance thresholds for suspicious trading activity and justified the application of corrective measures including profit deduction and account termination. In this regard, in support of its position, the Broker refers to provisions of Clause 1.4 (b)(v), 3.7(d) of the Client Agreement, confirming that the reversal of profits was made in response to abnormal trading activity in breach of the terms and platform policy: Clause 3.7(d):

“the Broker may close all or part of any Hedged Position at any time without notice […] where it constitutes suspicious trading activity.”

The Broker claims that these provisions grant the Broker contractual authority to investigate, restrict, and reverse profits derived from trading activity reasonably believed to be abusive or exploitative, irrespective of whether such conduct is independently illegal.

3. Third, in order to make an objective decision on this case, the DRC has analyzed the Client’s trading activity in their account # XXX.
4. a) 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 (+)2,219.46 USD;
• the amount of cash adjustment made by the Broker was (-)5,243.29 USD;
• the total amount of successful withdrawals made by the Client was (-)2,386.54 USD.

1. b) Analysis of the nature of the disputed transactions carried out by the Client revealed that:

• The Client’s trades were made in the period between 04.03.2026 and 20.03.2026.
• The Client’s trades were made with only one financial instrument: XAUUSD.
• The Client’s trades were carried out during both active and inactive market hours.
• The volume of trades carried out by the Client varied from 0.01 lots to 0.7 lots.
• The duration of the Client’s trades ranged from a few seconds to several days.

1. c) Analysis of the financial results of transactions performed by the Client revealed that:

• After 156 transactions the Client has made net profits in the amount of 1,350.37 USD.
• The share of profitable trades was 51.92 % or 81 trades.
• The share of unprofitable trades was 48.08 % or 75 trades.

4. Fourth, regarding the profits from the disputed positions that the Client claims were unjustly withheld by the Broker, the following should be noted:
5. a) Considering the fact that the Client kept the disputed positions open over the weekend, it’s obvious that the Client chose highly risky trading strategy and was ready to lose the entire balance of their account, under certain circumstances.
6. b) In case of the negative scenario, when the price of the financial instrument XAUUSD moved sharply against the Client, the Long positions ## 165976309, 165976596, 165978126, 165978450, 165978666 opened in the financial instrument XAUUSD at the aggregate volume of 3 lots would have ended by Stop Outs with losses exceeding the Client’s account balance. This circumstance is a confirmation of the fact that the Client was ready to abuse the protection of negative balance offered by the Broker.
7. Finally, it is worth noting that in its decisions, the Financial Commission tries to adhere to the principles of Fair Business Practices, which imply, among other things, the following: reduction in the maximum available leverage prior to weekends. To prevent clients from abusing increased leverage, brokers must issue appropriate warnings in anticipation of increased market volatility caused by the publication of important political news during weekends, and reduce leverage levels accordingly. The clients must be notified of this adjustment in a timely manner, via trading platform and/or announcement on the broker’s official website.

Based on the above, the members of the DRC of the Financial Commission have ruled in favor of the Broker and decided the following:

1. Recognize the disputed trades performed on the Client’s trading account # XXX as voided.
2. Consider the cancellation of the financial results of the disputed trades (+ 5,243.29 USD) by the Broker as lawful.

As such, the Client’s request for withdrawal of withheld funds in the amount of 5,243.29 USD from trading account # XXX should not be satisfied by the Broker, as the Client’s own funds have been withdrawn in full and their profits were obtained in violation of the Broker’s Terms and Conditions.

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.