Customer Complaint Dated April 23rd 2026

Complaint Matter

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

The Client used account # XXX (USD) for active operations in the financial instruments of the FX market. On 19.02.2026, the Client funded their trading account with 1,000 USD. In the period between 24.02.2026 and 22.04.2026 the Client carried out 74 trading operations on the specified account. By the time of the incident, the Client had made net profits totaling 1,980.57 USD, and had successfully withdrawn 1,000 USD from their account.

The incident on the Client’s account occurred on 23.04.2026, at 04:54 (server time, UTC+3). At the specified time, the Broker applied a cash adjustment to the Client’s account balance by deducting the 100% of profits made by the Client from it. The Broker accused the Client of violating the Company’s trading rules.

The Client claims that they raised their complaint against the Broker due to unjustified deduction of funds from their trading account. According to the Client, the Broker has accused them of engaging in

“risk-free arbitrage” and violating their trading policies. However, despite multiple requests, the Broker have failed to provide any concrete or verifiable evidence to support this claim.

The Client further clarifies that all responses from the Company were generic and based on statements such as “information received from a liquidity provider,” which cannot be independently verified. The Client emphasizes that they conducted all their trades in good faith under normal market conditions and did not engage in any manipulative or abusive trading practices. Despite this, the Broker proceeded to deduct funds from the account # XXX, as documentary evidence.

The Client does not agree with the Broker’s decision on their complaint (see below) and considers the Broker’s actions to be unfair. The Client believes that the Broker confiscated their legitimate profits for no valid reason, accusing them of engaging in “risk-free arbitrage” 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 violations and requires that the Broker provide clear and verifiable evidence supporting their allegations, or fully restore the deducted funds in the amount of 1,980.57 USD to their account, if such evidence cannot be provided. The Client has provided the investigation with the screenshots showing the email communication with the Broker regarding the incident, as well as the history of trading/non-trading operations performed on the account # XXX, as documentary evidence.

In turn, the Broker claims that upon examination of the Complainant’s trading history, they determined that the Complainant engaged in Suspicious Trading Activity as defined under the Agreement, i.e. Thin Liquidity Scalping. The Broker asserts that the findings of their internal investigation provide reasonable grounds for the Broker’ reasonable suspicion of such activity. According to the Broker, the deduction of the illicit profits, issuance of termination notice, and closure of the account were executed in full compliance with the contractual provisions outlined in Clauses 1.3, 1.4(b)(v) and 3.7 of the Client Agreement.

In support of their decision, the Broker has provided the investigation with the history of trading/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 Ultima Markets 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 registered their account # XXX with the Broker in February 2026.
3. b) During the period February–May 2026 the Complainant conducted a high volume of trading activity primarily on various FX currency pairs, generating profits of USD 1,980.57.
4. c) On April 22, 2026, following internal review by the Risk Team, the illicit profits of USD 1,980.57 were deducted, a termination notice was sent to the Complainant, and their account was terminated.
5. 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 Thin Liquidity Scalping. The patterns identified are as follows:

• The Complainant utilized a pattern of high-volume trading during periods of low market liquidity, systematically exploiting price inefficiencies across various instruments to perform arbitrage-like strategies.
• This trading behavior enabled the Complainant to secure abnormal profits by taking advantage of thin liquidity conditions while exposing the Company to asymmetric and elevated risk, as the market lacks sufficient depth to absorb these trades under normal conditions.
• Such a strategy results in asymmetric risk exposure to the Company, as the Complainant is able to secure low-risk profits by exploiting market discontinuities without bearing the corresponding market risk.
• The Company has therefore classified this account as engaging in Thin Liquidity Scalping (TLS), and the associated trading activities are considered abusive and irregular in nature.

The Broker asserts that their Client Agreement explicitly restricts any form of suspicious trading, including strategies that create asymmetric risk exposure to the Company by exploiting price inefficiencies in low liquidity conditions. In this regard, in support of their position, the Broker refers to the relevant provisions of their regulatory documents:

▪ Clause 1.4(b)(v): “the Client must not, whether acting individually or in collaboration with others, participate in any activity that constitutes Suspicious Trading Activity as defined herein. Should the Broker have reasonable cause to believe that the Client is engaging in such activity, Ultima Markets retains the authority to suspend the Client’s account (temporarily or indefinitely), reclaim any losses linked to the Suspicious Trading Activity, and/or nullify the Client’s orders along with any resulting profits, effective immediately.” ▪ Clause 1.3 outlines Suspicious Trading Activity as follows: “Suspicious Trading Activity means any belief or decision of the Broker… that the Client has… used the Online Service in a way which affects the integrity… including but not limited to: (d) entering into Orders or combination of Orders with intention of exploiting the price gap with over-leveraged position prior to market closure or certain public announcements; and (f) engaging in any trading behaviors which are deemed exploitative, dishonest, abusive, or a good faith violation.” ▪ Additionally, Clause 3.7 concludes with: “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.”

According to the Broker, under these provisions, the Broker is permitted to impose restrictions on the Account and may even revoke associated profits if the Complainant is reasonably suspected of involvement in Suspicious Trading Activity, including Thin Liquidity Scalping 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 (+)1,000.00 USD;
• the amount of cash adjustment made by the Broker was (-)1,980.57 USD;
• the total amount of successful withdrawals from the Client’s account was (-)1,000.00 USD.

1. b) The analysis of the nature of the transactions made by the Client revealed the following:

• The Client’s transactions were made in the period between 24.02.2026 and 22.04.2026.
• The Client’s transactions were made in the financial instruments of the FX Market.
• The Client’s transactions were made during the hours of inactive market (after Rollover).
• The volume of the Client’s transactions ranged from 0.01 lots to 1 lot.
• The duration of the Client’s transactions ranged from a few seconds to over an hour.

1. c) The analysis of the financial results of transactions made by the Client revealed the following:

• After 74 transactions the Client made net profits in the amount of 1,980.57 USD.
• The share of profitable transactions performed by the Client was 82.43% or 61 trades.
• The share of unprofitable transactions performed by the Client was 17.57% or 13 trades.

4. Fourth, the DRC verified the validity of the Broker’s allegation that the Client was taking advantage of thin liquidity conditions for profit. For this purpose, the DRC reviewed the documentary evidence provided by the Broker, as well as the history of price data for the financial instruments in the disputed transactions obtained from independent providers of financial services. To ensure an objective investigation the 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. The analysis of the execution quality of the Client’s trades showed that a significant portion of high-volume short-term trades, with a duration of several seconds to several minutes, were opened and / or closed at prices much better than those available on the market or at non-market prices.

A good example of the above-mentioned abusive strategy utilized by the Client can be a series consisting of several profitable transactions in the financial instrument EURCHFUSD carried out on the Client’s account on 01.04.2026. All of them were short-term trades, ranging from 5 seconds to over 2 minutes, executed in the period of low market liquidity (after the Rollover).

Thus, in the common opinion of the DRC members, the Broker has sufficient grounds to claim that the disputed transactions performed on the Client’s trading account # XXX were executed at lagging / non-market prices. Also, it is highly likely that the Client indeed might have used special technical means (EA) exploiting vulnerabilities in the Broker’s quoting system.

5. Finally, it should also be noted that in its decisions, the Financial Commission tries to adhere to the principles of Fair Business Practices, which imply, among other things, the following: if any problem is detected, its solution should be provided as soon as possible to mitigate the negative impact of this problem on the client. The Financial Commission adheres to the following rule: if the client has made a profit in an unfair way, then such profit must be recognized as illegitimate within 1-5 business days and debited from the client’s trading account. The client must be notified of the violation in a timely manner, and not after several weeks or months, at the stage of withdrawing funds from the client’s trading account.

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 by the Broker as lawful.

As such, in the general opinion of the DRC members, the Client’s request for withdrawal of profits in the amount of 1,980.57 USD 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.