Customer Complaint Dated March 30th 2026

Complaint Matter

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

The Client used account # XXX (EUR) for active trading operations in the financial instruments of the FX market. The Client claims that they raised their complaint against the Broker due to systemic market manipulation, severe technical execution errors, and active intervention by the Broker after their account reached a highly profitable balance.

According to the Client, the Broker had fraudulently manipulated execution prices on trades copied via a third-party Expert Advisor (EA) from a signal provider (connected via MetaCopier) on the XAUUSD instrument. In this regard, the Client set forth the following key allegations:

• Limit Order Breach & Irregular Sizing (Feb 16, 2026): A Sell-Limit order was executed nearly USD

3.00 above the set limit price, which the Client states is technically impossible in a normal market. Furthermore, the 14-lot order size was irregular and suspected to be a technical glitch or unauthorized system order, resulting in damages of USD 4,046.00.

• Unauthorized Pre-emptive Closing & Price Manipulation (Feb 11, 2026): The Broker allegedly closed a position 30 seconds before the Client’s automated “Master Bot” sent the close signal. Additionally, the entry price was artificially worsened by 142 pips, turning a projected profit into a loss. Damages amount to USD 1,651.35.
• Systematic Price Shaving (Jan 20, 2026): Despite having identical timestamps to the bot’s master signal, the Broker provided significantly worse entry and exit prices, resulting in damages of USD 133.30.

The Client does not agree with the Broker’s decision on their complaint (see below) accuses the Broker of misconduct and holds the Broker responsible for the financial losses/unrealized profits caused by poor execution on the Broker’s platform. The Client is of the opinion that the Broker’s execution significantly deviated from the Master signals and breached the integrity of Limit Orders (Take Profit). In this regard, the Client requests that the Dispute Resolution Committee of the Financial Commission verify the execution of the disputed trades, as well as the Broker’s conduct for violations. The Client believes that a fair resolution to the dispute would be a full refund of the unjustified losses and the restoration of the projected profits for the disputed trades totaling 5,830.65 USD, from the Broker. The Client has provided the investigation with the screenshots showing the brief summary and the history of trading operations performed on the account # XXX, the details of the disputed trades ## 55928859, 111898895, 124323890, as well as the full version of the complaint, as documentary evidence.

In turn, the Broker does not see any grounds for the Client’s complaint, since in their opinion, all of the Client’s disputed positions/orders were opened and closed correctly, at actual market prices and in full compliance with the provisions of their regulatory documents and trading rules established by the Company. The Broker has provided the investigation with the history of trading/non-trading operations performed on the Client’s account # XXX, the server log records, the Quote Book with the details of the execution of the disputed trades provided by the Broker’s Liquidity Provider, 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 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 in order to make a decision on this case the DRC has analyzed the Client’s trading activity in their account # XXX registered with the Broker. However, the DRC has not included into its investigation the verification of the Client’s disputed transactions carried out before 12.02.2026, as per clause 16.1 (i) of the Rules and Guidelines of the Financial Commission.
2. Second, according to the information received from the Broker, their internal review of the complete trading history report, order logs, and server data for the Client’s account # XXX confirms there is no evidence of price manipulation, system malfunction or any abnormal activity:

• The three EA-executed trades referenced by the Complainant (# 55928859, # 111898895, # 123082305) and the manual trade (# 124323890) were executed at the best available market prices at the precise moment the orders reached the market.
• The discrepancies between the signal provider’s bot results and the Broker’s executions are solely attributable to market depth slippage caused by the significantly larger lot sizes used (5.05 lots, 5.13 lots, and the 14-lot manual order). As explicitly explained in the earlier response to the Complainant dated 27 February 2026, large orders frequently require filling across multiple price levels when liquidity at the top-of-book price is insufficient. This is a standard, transparent market mechanism.
• The Complainant himself described the 14-lot order as “accidentally executed” (via the mobile app), further confirming it was a client-initiated manual trade.
• The EA is third-party software provided by an external signal supplier. the Broker has no access to, control over, or responsibility for its internal logic, timing, or performance. Any mismatch between the bot’s theoretical results and live executions is outside the Broker’s scope and is a risk the Complainant accepted when choosing to copy signals with increasing volumes.

As such, the Broker is of the opinion that all disputed trades were processed in full compliance with the Broker’s market-execution model and regulatory obligations. In this regard, in support of its position, the Broker refers to the relevant provisions of their regulatory documents:

Client Agreement:

▪ Clause 1.2: the Broker is under no obligation (a) to satisfy ourselves as to the suitability of any Position for the Complainant; (b) to monitor or advise the Complainant on the status of any of his Positions; (c) to prevent the Complainant from trading beyond his means or ability or to protect him; or (d) to close any open Position(s). ▪ Clause 1.1(e): By opening the Account and submitting the Application Form, the Complainant confirmed he had read, understood, and accepted the Agreement and the Risk Disclosure Notice, including the high-risk nature of leveraged derivative products such as CFDs on metals. ▪ Section 3: The platform operates on an execution-only basis; all orders are routed to the real market and filled at prevailing liquidity. the Broker does not control or guarantee the performance of third- party software, signals, or EAs such as the MetaCopier-connected robot used by the Complainant. ▪ Clause 12: the Broker is not responsible for losses arising from market conditions, order execution at available prices, or the use of third-party tools/strategies.

Risk Disclosure Notice:

▪ Section 3: Leverage magnifies both gains and losses; even small adverse price movements may result in substantial losses. Stop-loss / take-profit orders and limit orders are not guaranteed and may be subject to slippage in volatile markets or when liquidity is limited. ▪ Section 8: Market depth slippage occurs when the size of an order exceeds available liquidity at the best quoted price. In such cases, the order is executed across multiple price levels, resulting in a less favourable average execution price than the price displayed on the chart. This is a normal occurrence in financial markets (particularly for larger volumes in instruments such as XAUUSD) and does not indicate any system malfunction or manipulation. ▪ Section 2 and Section 9: Trading in leveraged products such as CFDs on metals carries substantial risk; prices can change rapidly, and clients must fully understand and accept these risks before trading. ▪ Section 13: the Broker does not provide investment advice; the client is solely responsible for all trading decisions, including lot size, use of EAs/signal providers, and risk management.

3. Third, the Broker emphasizes that even in the ordinary course of market operation, slippage between the offered price and the actual price at which the Market order is executed could very well occur and such slippage could be exacerbated by:

Market Volatility: Trades may experience slippage during periods of high volatility, especially when strong market trends are present. Market volatility can be caused by technical or fundamental factors in the market or the release of news or information.

Liquidity Issues: When large orders are triggered, execution fills at the next available price(s) in the Depth of Market, which can be affected by market volatility and liquidity. Trading Volumes: Significant volume can impact execution due to depth of market or the lack thereof.

4. Fourth, to ensure an objective investigation of the case the DRC requested historical data on the financial instrument in the disputed transactions from other independent providers of financial services. 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 quote flow of other companies reveled that:
5. a) At the time the Short position # 124323890 was opened, with a volume of 14 lots (1,400 ounces), the market average Bid price for the financial instrument XAUUSD was 5004.416,

i.e. it was significantly higher than the Broker’s execution price of 5001.78.

5001. b) At the time the Short position # 124323890 was closed, with a volume of 14 lots (1,400 ounces), the market average Ask price for the financial instrument XAUUSD was 5001.646,

i.e. it was significantly lower than the Broker’s execution price of 5004.39.

As such, it is obvious that the quotes for the financial instrument XAUUSD in the Broker’s quotation feed differed significantly from the quotes obtained from other independent financial service providers and, consequently, did not reflect the actual market conditions.

5. Fifth, the Client states that the slippage during the execution of the disputed trades was excessive and did not reflect normal market conditions. For its part, the Broker states that they have confirmed with the Liquidity Provider that no pricing or execution errors occurred at the time of execution of the disputed trades. Furthermore, the Broker notes that the Client’s orders were executed by aggregating liquidity across several price levels in the Depth of Market (DOM). This resulted in execution at the volume-weighted average price (VWAP) indicated in the trading history for the Client’s account. The experts of the DRC considered the Broker’s position to be correct, since large market orders are always executed using the “volume-weighted average price” (VWAP) method: if the required number of lots is not available at the best price (Top of the Book), the system takes what is available and moves on to the next, less favorable price level until the entire volume is filled. This inevitably leads to slippage. In this regard, it should be noted that judging by the documentary evidence received from the Broker’s LP (the Quote Book volumes at the time of the trades in question), the following was confirmed:
6. a) The Sell Market order # 124323890 was executed via the LP in several parts. The order was for 1,400 ounces, and the Quote Book at the time of execution resulted in an average price for the whole order of 5001.78 at open, while the requested top of book quote was 5,004.59.
7. b) The Buy Market order # 124323890 was executed via the LP in several parts. The order was for 1,400 ounces, and the Quote Book at the time of execution resulted in an average price for the whole order of 5,004.39 at close, while the requested top of book quote was 5,001.57.

The analysis of price levels and volumes in the Depth of Market (DOM) for the relevant period, as received from the Broker’s LP, has not identified any significant deviations in the Broker’s prices. The order book logs confirmed a lack of liquidity at the best bid for the required number of lots. Therefore, to fill the Client’s required volume, it was necessary to gather liquidity across several price levels. In other words, the VWAP mechanism functioned correctly.

6. Sixth, with regard to slippage during execution of market orders the following should be noted. The Client should be aware that a Market order is a command to Buy or Sell an asset immediately at the best available current price, prioritizing speed over price precision, ideal for fast entry/exit but risky in volatile markets due to potential slippage. A Market order does not inherently guarantee that the client’s instructions will be executed at the indicated price. Depending on the market situation such order may be executed either precisely at the price indicated by the platform, or at a price better/worse than the indicated one. The client should use Limit Buy /Limit Sell orders to get an execution at a guaranteed price. Furthermore, the Client should be aware that slippage arises from natural market dynamics, particularly in low-liquidity periods. Also, for trades involving larger lot sizes, available liquidity at the requested price level may not fully accommodate the order volume. Consequently, portions of the trade execute at successive price levels, resulting in apparent negative slippage. This phenomenon is standard in low-liquidity, low-volume markets and reflects normal liquidity behavior rather than execution inefficiency.
7. Finally, it is important to note that, by definition, a Take Profit order is executed either at the specified price or at the better price at the time of execution. When using this type of order, a trader understands and expects that the trading order placed with the broker will be guaranteed to be executed at a price no worse than the one requested. The Financial Commission also adheres to this approach, as this is precisely what constitutes the Best Execution practice, which is widely recognized throughout the financial services industry. In this regard the DRC experts believe the following should be noted:
8. a) As can be seen from the trade log entries, the Broker sent the Client’s Take Profit order # 124323890 to the LP as a Market Order rather than a Limit Order. It should be noted that Take Profit orders, like all Limit orders, must be submitted to the market as Limit orders; otherwise, slippage is to be expected.
9. b) This fact means that, on the one hand, the Broker committed to the Client to execute the Take Profit order at a price no worse than the requested one (since this stems from the very nature of a TP order), while on the other hand, the Broker hedged it on the LP side as a Market Order, thereby not ruling out a deterioration in the quality of the Client’s order execution.
10. c) Thus, it can be concluded that the Broker knowingly made this kind of assumption, clearly assumed responsibility for the slippage, and therefore must reimburse the Client for the difference.
11. d) Buy Limit and Sell Limit orders (including Take Profit orders) should be placed on the market specifically as Limit orders; in this case, if market liquidity is low, they simply will not be executed but will remain open until market conditions allow them to be executed.

Based on the facts set forth above and taking into account the documentary evidence provided by both parties to the dispute, the DRC experts concluded that the execution of the Client’s pending Take Profit order # 124323890 at the time of the incident was incorrect. Therefore, the financial result on the disputed position # 124323890 should be recalculated taking into consideration the Buy Limit price of 5,001.50 indicated by the Client. In other words, the Broker must credit the Client’s account with 3,472.42 EUR, in order to reflect the necessary changes.

The DRC experts believe that the Broker’s issue is related to incorrect settings in the mechanism for routing clients’ pending orders to the LP side. If the Broker lacks the technical capability to route Buy Limit/Sell Limit orders (including Take Profit orders) as Limit orders to the LP side, it must either prohibit clients from using these types of orders on its platform (to avoid misleading them), or update its technical infrastructure to route such orders as Limit orders, or accept the risk that it will have to cover negative slippage when executing clients’ pending orders from its own funds.

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.