Customer Complaint Dated March 06th 2026

Complaint Matter

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

The Client used account # XXX (EUR) for trading operations in the financial instruments of the FX and cryptocurrency market. On 05.03.2026, the Client funded their trading account with 200 EUR and received a bonus of 300 EUR from the Broker on the same day. In the period between 05.03.2026 and 06.03.2026 the Client carried out 13 trading operations in the financial instruments XAUUSD, BTCUSD and made profits in the amount of 1,263.36 EUR.

The incident on the Client’s trading account occurred on 06.03.2026, at 04:51 (server time, UTC+3). At the specified time, the Broker reversed two requests for withdrawal of funds in the amount of 200 USD and 1000 USD submitted by the Client. In a couple of days, on 09.03.2026, the Broker applied a cash adjustment to the Client’s account balance by deducting the 100% of profits made by the Client from it. On the same day, the Broker notified the Client that they violated the trading rules established by the Company.

The Client alleges that the Broker has unfairly seized 1,263.36 EUR of their legitimate trading profits from XAUUSD trades. According to the Client, they traded manually and followed the Broker platform’s prices.

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. The Client believes that the Broker has confiscated their legitimate profits for no apparent reason, as in the Client’s opinion, none of the Broker’s rules have been breached. 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 profits in the amount of 1,263.36 EUR. The Client has provided the investigation with the screenshots showing the Broker’s official response to the complaint, 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 (Section 1.3) expressly prohibits suspicious trading activity, which includes bonus abuse. According to 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, reasonably formed or made and whether or not communicated to the Client, 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 grounds 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 trading and non- trading operations performed on the Client’s account # XXX, as well as 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:

1. First of all, it should be noted that according to the information received from the Broker:
2. a) The Complainant onboarded with the Broker on 4 March 2026 and deposited EUR 200, receiving a promotional credit of EUR 300.
3. b) Shortly after, the Complainant engaged in trading activities that generated a net illicit profit of EUR 1,263.36.
4. c) The Complainant’s account was flagged for breaching the Client Agreement due to abusive behavior, specifically external hedging strategies.
5. d) As a result, the illicit profits amounting to EUR 1,263.36 were deducted from the Complainant’s account via cash adjustment, the account was terminated.
6. e) The Complainant was notified of the Company’s decision via Support Ticket # 4698730 on 09.03.2026.
7. Second, the Broker further clarifies that following a review of the Complainant’s trade records, they identified that the trading activity in the Complainant’s account # XXX is consistent with external hedging. External hedging refers to a trading strategy where a trader opens opposing positions on the same or correlated financial instruments across different brokerage accounts or platforms to minimize risk or exploit pricing differences. The hedging pattern identified are as follows:
8. a) The Client traded a single product (XAUUSD) using high leverage (above 250x), in a single direction (Long), while trading on promotional credit. In addition, the Client withdrew profits immediately after profitable trading cycles.
9. b) Profitable positions highly concentrated within specific trading cycles (multiple rapid Long entries of 0.05 lots on XAUUSD opened between approximately 02:16 and 03:00 on 6 March 2026 at prices between 5071.87 and 5082.37, all closed simultaneously at 04:00:07 on 6 March 2026 at 5134.11, generating substantial profits of approximately EUR229 to EUR268 per position).
10. c) This overall trading behavior is consistent with historical patterns previously identified in external hedging cases.

According to the Broker, these patterns fall squarely within the type of conduct contemplated by Clause 1.4(b)(v) of the Client Agreement and prompted their internal escalation protocol. The Agreement expressly prohibit suspicious trading activity which includes hedging and arbitrage-style trading. In this regard, in support of its position, the Broker refers to the provisions of Clauses

1.4(b)(v), 1.3, 3.7 of the Client Agreement. Pursuant to these Clauses, the Broker is entitled to cancel associated profits where the Complainant is reasonably suspected of engaging in Suspicious Trading Activity.

3.7. HEDGED POSITIONS …

“It is hereby agreed that the Company shall exercise its discretion in investigating client’s accounts. Based on the findings it may proceed with notifying client(s) that their account is under investigation whereas the Company reserves the right to proceed with immediate account termination, with or without prior notification to the client of the said breach of the Client Agreement. The Company 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.”

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 (+)200.00 EUR;
• the total amount of bonus credited to the Client’s trading account was (+)300.00 EUR;
• the total amount of withdrawals requested from the Client’s account was (-)1,400.00 EUR;
• the total amount of withdrawals reversed by the Broker was (+)1,200.00 EUR;
• the total amount of cash adjustment made by the Broker was (-)1,263.36 EUR;
• the total amount of successful withdrawals performed by the Client was (-)200.00 EUR.

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 05.03.2026 and 06.03.2026.
• The Client’s trades were mostly made in only one financial instrument: XAUUSD.
• 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 0.05 lots.
• The duration of the Client’s trades ranged from a few minutes to several hours.

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

• After 13 transactions the Client has made profits in the amount of 1,263.36 EUR.
• The share of profitable trades was 92.31 % or 12 trades.
• The share of unprofitable trades was 7.69 % or 1 trade.

4. Finally, it is worth noting that in its decisions the Financial Commission cannot and does not evaluate any Brokers’ bonus programs, since the final decision – whether to participate in such programs or not – always remains with the client. The client himself, based on his own experience, skills, and knowledge, must make a choice – whether this type of bonus program is suitable for him or not. More detailed information on the Commission’s position on this issue can be found here: link

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 specified trades (+1,263.36 EUR) by the Broker as lawful.

As such, the Client’s request for withdrawal of the withheld profits in the amount of 1,263.36 EUR from trading account # XXX should not be satisfied by the Broker, as these 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.