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Contract reading

What BCM MARKETS legally published, but does not want you to read

Every clause below is published by BCM MARKETS itself, on its own website, today. The finding is not that the text exists. It is the distance between what a client is shown and what a client agreed to. Read from its own documents on .

Contracting entity: BCM Markets Ltd

sole discretionhidden feecomplaint deadlinecomplaint refusalconflict disclosuredeemed acceptanceprofit voidingunilateral amendmentwithdrawalsadvisory

BCM Markets Ltd promises no funding fees, 24 hour withdrawals and funds safe from insolvency. Its client agreement allows up to 5% on any money that is not in US dollars. It also lets BCM pledge your balance for another customer's debt, and annul every profit if it suspects manipulation. You get 2 business days to object to a trade, and website promises carry no remedy.

Contract risk

Money at risk
7.8/10

Where this contract sitsHow far this contract goes, overall. Under 2 is nothing beyond the ordinary; 6 to 9 means several clauses put money you have already earned at risk; 9 and above reads as designed to make payout refusable.

0510
CriticalClauses that can cost you money you have already earned or deposited, or that remove your ability to challenge it.
7
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
21
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
9
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
5

How the 21 break downThe same flagged clauses, split by how much each one can cost you. Severity is our reading of the clause, not the broker's label.

Critical7
Warning13
Notice1

section 134 of 136is where the deepest clause sits: the very end of the document it is in

The numbers in this contractFigures taken from this broker's own clauses, so the labels differ from broker to broker. The four in the panel above are the same on every report.

2 of these 4 figures come from a clause we rate critical, which means it can take your money or your profit rather than only delay it.

What the documents say

21 clauses worth knowing about, worst first, each quoted from BCM MARKETS's own files

01

Your money is segregated under clause 13, then charged to BCM Markets under clause 14.3. Clause 14.4 lets BCM pledge those assets to an exchange, a broker or another third party. That third party can enforce against them for BCM's own debts, or for the debts of any other customer of BCM.

Why this matters

The PAMM page tells you the funds are protected from broker insolvency. Clause 14.4 lets that security rank ahead of your own claim, so a default that is not yours can reach your balance.

Exhibit 1CriticalRarely seen

Money received or held on your behalf by us will be treated as client money in accordance with the FSC Rules and Regulations or other relevant laws or rules and will at all times be segregated from our own funds.
Clause 13 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Where it sits: section 70 of 136 in the Investment Dealer Client Agreement, 51% of the way through.

Set against a regulated standard: FCA (UK), CySEC (Cyprus), ESMA (EU)

Firms licensed by the FCA or CySEC may not take a retail client's money or assets as collateral for the firm's own obligations, and title transfer collateral arrangements with retail clients are banned. Clause 14.4 lets BCM Markets pledge your assets for its own obligations and for another customer's.

BCM MARKETS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Our readingA broker lien over client assets is ordinary. Extending it so a third party can enforce against your balance for another customer's obligations, ahead of your own claim, is not.

  • Worse together with Exhibit 6The charge over your assets is what the retention clause enforces: the same money secures the debt and cannot leave until BCM says the debt is gone.
02

BCM Markets can close every position, annul all your profits and charge a penalty equal to that profit. Clause 34.9 needs only a suspicion of fraud, manipulation or swap arbitrage. It reaches transactions previously made in the account, not just the open ones. None of those three terms is defined in any of the nine documents.

In plain words

Liquidity providers are outside banks and brokers.

Why this matters

Profit from trades you closed months ago can be taken back as a penalty, on suspicion alone. Clause 24.5 then refuses complaints about a profitable position the company cancelled afterwards.

Exhibit 2CriticalRarely seen

In the event where the Company suspects any fraud, manipulation, swap-arbitrage or other forms of deceitful or fraudulent activity in a Client's Trading Account or Accounts with the Company or otherwise related or connected to the any and/or all Transactions, then the Company reserves the right, at its sole discretion, to close all open positions in the Client's Trading Account and deduct or add a penalty (equivalent to the swap and/or any profit amount) for all transactions currently and/or previously made in the account and/or annul all profits made as a result and decline from accepting any further requests from the Client to be exempted from any swaps and/or terminate all agreements with the Client.
Clause 34.9 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference
Our own capture of bcm-markets.com, taken on Oct 11, 2026The claim, on Spanish deposits page, FAQ answer on the minimum withdrawal amountThis capture shows the page the quotation was taken from. The words themselves are not marked in it, so please read the quotation above as the evidence.Visit this page on the broker's siteDownload the full size image file

Buried at section 133 of 136 in the Investment Dealer Client Agreement, 98% of the way through.

Our readingVoiding trades on suspected abuse is common. A penalty equal to the profit on every transaction previously made in the account, with no definition of the behaviour that triggers it, is not.

  • Worse together with Exhibit 7The clause that annuls your profit is also the one you cannot complain about, because clause 24.5 refuses complaints about a profitable position BCM cancelled afterwards.
03

Deposit anything other than US dollars and clause 30 lets BCM Markets add a markup of up to 5% on the conversion. The same ceiling applies when dollars are converted to buy an instrument priced in another currency. The deposits page says BCM does not charge any fees for deposits or withdrawals.

Why this matters

Send $1,000 from a euro account and up to $50 is gone before your first trade. The contract sets only a ceiling, so the rate BCM actually applies is never published.

Exhibit 3CriticalHarder than usual5%

Any amount of any currency, other than USD, transferred by you as well as such amount received from the sale or redemption of investment or paid to us shall be converted to USD at the rate provided by custodian bank appointed by us from time to time plus a markup charged by us which shall not be higher than 5%.
Clause 30 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 118 of 136 in the Investment Dealer Client Agreement, 87% of the way through.

What it costsA $1,000 deposit sent in euros can reach your account as $950. The $50 is BCM's markup, not a bank charge.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must tell a retail client the costs and charges of a service before they trade, as a cash figure. This contract names a ceiling of 5% and leaves the rate BCM Markets applies unpublished.

BCM MARKETS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

04

BCM Markets tells you on its website that you are entitled to compensation if a withdrawal runs late. Clause 32.4 says you do not rely on, and have no remedy for, any promise that is not written into the agreement. No document in the set mentions compensation.

In plain words

Supersedes means beats: where two documents disagree, that one wins.

Why this matters

Take the compensation promise to a Mauritius court and BCM can point at clause 32.4. The promises that sold you the account, fast payouts and no fees, sit outside the agreement you accepted.

Exhibit 4CriticalStandard wording

Each of the parties acknowledges and agrees that in entering into this Agreement, and the documents referred to in it, it does not rely on, and shall have no remedy in respect of, any statement, representation, warranty or understanding (whether negligently or innocently made) of any person (whether party to this Agreement or not) other than as expressly set out in this Agreement.
Clause 32.4 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 124 of 136 in the Investment Dealer Client Agreement, 91% of the way through.

05

You get 2 business days to object in writing to any confirmation or statement. After that, clause 9.6 makes BCM's record conclusive and binding on you. BCM can correct its own errors whenever it finds them, however late.

Why this matters

Statements come twice a year under clause 9.5, and clause 1.10 has you waive the monthly one when the account opens. A trade priced wrongly on a Monday is agreed fact by Wednesday, whether or not you looked.

Exhibit 5CriticalHarder than usual2 working days

Any confirmation or statement of account or any certificate issued by us in respect of any transaction or other matter shall be conclusive and binding on you unless objection in writing is received by us within 2 Business Days of the actual or deemed delivery date.
Clause 9.6 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Where it sits: section 48 of 136 in the Investment Dealer Client Agreement, 35% of the way through.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must send a retail client a statement of their account at least once every three months. BCM Markets sends one twice a year, and clause 1.10 has you waive the monthly statement when the account opens.

BCM MARKETS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

06

You have the right to withdraw your balance on demand under clause 1.10. Clause 14.5 then says you may not withdraw without BCM's prior consent until all your obligations are discharged. Payments to you from your own assets are at BCM's absolute discretion.

Why this matters

Nothing in the nine documents says how long BCM has to decide, or what counts as an outstanding obligation. The deposits page promises you can withdraw any amount at any time with no holding periods.

Exhibit 6CriticalHarder than usual

Until you have paid or discharged in full all your obligations, we shall be entitled to retain all your Assets and you may not (without our prior consent) withdraw or substitute any such Assets. We may in our absolute discretion make payments or deliveries to you from such Assets, or otherwise exercise our rights of set-off, combination and/or consolidation.
Clause 14.5 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Where it sits: section 71 of 136 in the Investment Dealer Client Agreement, 52% of the way through.

Two business days to object, and six kinds of complaint BCM will not accept

Clause 9.6 makes every BCM Markets confirmation and statement conclusive and binding unless you object in writing within 2 Business Days. Clause 24 then lists six kinds of complaint the company will not accept, including complaints about the price you got. Clause 35.4 leaves anything the documents do not cover to BCM's sole discretion.

Complaint deadlines4 clauses flagged

Six kinds of complaint are refused outright under clause 24. They include complaints about the price you got against the underlying market, how long an order took, and profits from a position BCM cancelled afterwards. Quotes from other firms are not taken into account in any dispute.

Why this matters

The complaint you are most likely to make, that your price was wrong, is the one clause 24.3 will not hear. You also get no notice when a dispute over your position is closed, and you carry the risk meanwhile.

Exhibit 7CriticalHarder than usual6

Complaints in regard to a Transaction or Order execution based on the difference in the prices for the Contract for Difference in the Trading Platform and for the underlying asset of the Contract for Difference are not accepted.
Clause 24.3 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 102 of 136 in the Investment Dealer Client Agreement, 75% of the way through.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must accept and investigate a complaint from a retail client and point them to an independent ombudsman. This contract lists six kinds of complaint BCM Markets will not accept at all.

BCM MARKETS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Limited by Exhibit 10The complaints policy does name one route past a refusal: a rejected complaint can be appealed to the FSC in Mauritius.

Disputes the legal documents do not mention are settled at BCM's sole discretion, under clause 35.4. Clause 32.8 then makes you pay what BCM says you owe even if you have a counterclaim against it.

Why this matters

A gap in the contract is filled by the company you are in dispute with. You cannot hold back money while your own claim against BCM is unresolved.

Exhibit 8WarningHarder than usual

Disputes not mentioned in the Legal Documents and/or any other official document published by us from time to time, are resolved in accordance with the common market practice and at the sole discretion of the Company.
Clause 35.4 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 134 of 136 in the Investment Dealer Client Agreement, 99% of the way through.

BCM's liability to you cannot exceed the highest monthly commission you paid in the six months before the incident. Clause 29.5 sets that cap, and on a Standard account, priced with spreads and no commission, the cap is nothing.

Why this matters

A platform failure that costs you thousands is answerable, at most, by one month of commission. Clause 18.3 already limits BCM's liability to gross negligence, wilful default or fraud that you can prove.

Exhibit 9WarningRarely seen

In no event shall we bear liability, regardless of the form of action and damages suffered by you, exceed the highest total monthly commissions paid by customer to us over the 6 months prior to any incident.
Clause 29.5 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 116 of 136 in the Investment Dealer Client Agreement, 85% of the way through.

Our readingLiability caps usually name a sum, or the fees paid for the service. Tying the cap to commission alone leaves a client on a commission free account type with a cap of zero.

A formal complaint goes in writing to the CEO, and BCM says its reasoned answer will always be sent to you by post. The policy sets a 30 business day target in one section and a 30 day maximum in another.

Why this matters

Two different deadlines in one policy means you cannot tell when BCM is late. The same policy gives you a way out: a rejected complaint can be appealed to the FSC in Mauritius.

Exhibit 10WarningStandard wording30 working days

The Company follows the outlined procedures to ensure that the Complaint is, as far as possible, resolved within a period of thirty (30) business days. The response to the Complaint and reasoning thereof shall always be sent by post to the Complainant.
Clause 6 in Complaints Handling Policy
Read from the broker's site on Archived copyOpen the reference

Buried at section 20 of 24 in the Complaints Handling Policy, 83% of the way through.

Up to 5% can come off any money that is not in US dollars

Clause 30 lets BCM Markets Ltd add a markup of up to 5% when it converts your money into US dollars, and the same ceiling applies converting dollars out again to buy an instrument. The deposits page says BCM does not charge any fees for deposits or withdrawals. The contract's own charge schedule contains no figures at all.

Cost disclosure1 clause flagged

The Customer Charge Schedule at the back of the client agreement names no amounts. It points to the website for brokerage fees and to an investment agreement for commission. Clause 17.2 lets BCM amend charges by written notice, and any charge you pay may be shared with third parties.

Why this matters

The one document that should list what BCM charges you lists nothing. Clause 16.4 also says BCM need not tell you about profit it makes from a conflicting interest in your transaction.

Exhibit 11WarningHarder than usual

You will pay our charges, details of which are set out in the Customer Charge Schedule and maybe amended from time to time by written notice from us to you.
Clause 17.2 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 85 of 136 in the Investment Dealer Client Agreement, 63% of the way through.

Suspicion alone lets BCM Markets annul every profit in the account

Clause 34.9 lets BCM Markets close your positions, annul all profits and deduct a penalty equal to that profit, on suspicion of fraud, manipulation or swap arbitrage. The penalty reaches transactions already closed. Clause 21.2 adds a second route, because the warranties you repeat with every order include one about the law where you live.

Profit at risk1 clause flagged

Every order you place repeats the warranties in clause 21.1. One of them is that your trading breaks no law or rule where you live. Clause 21.2 lets BCM void any position, at absolute discretion, if a warranty is breached.

Why this matters

The site says it is not directed at EU residents and lets you click through anyway. If a rule where you live says otherwise, that same click gives BCM a ground to void your trades.

Exhibit 12WarningRarely seen

The Client represents and warrants to the Company, and agrees that each such representation and warranty is deemed repeated each time the Client gives an Instruction or Request by reference to the circumstances prevailing at such time, that:
Clause 21.1 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 98 of 136 in the Investment Dealer Client Agreement, 72% of the way through.

Our readingWarranties in a client agreement are usually given once, at account opening. Deeming them repeated at every order turns a one off statement into a standing condition that can void trades.

  • Worse together with Exhibit 2A warranty repeated at every order gives BCM a second route to void positions, without needing to suspect anything.

BCM Markets can refuse your instruction without giving a reason

Clause 6.4 lets BCM Markets refuse any instruction at absolute discretion and without reasons, and an instruction includes an order to close a position. Clause 26 lets it change the agreement on 8 Business Days notice, and you have agreed that posting on the website counts as telling you. Leverage of 1:500 is advertised with no negative balance protection in any document.

In plain words

Negative balance protection is a limit that stops you owing more than you put in. Without it, one fast market move can leave you owing the broker money on top of your deposit.

Unilateral control3 clauses flagged

BCM can amend the client agreement on not less than 8 business days notice under clause 26. You have already agreed that posting information on the website counts as telling you. The website terms go further and treat your continued use as acceptance of any change.

Why this matters

A fee or a rule can change while you hold open positions, and the notice may never reach your inbox. You are expected to check the website for it.

Exhibit 13WarningHarder than usual8 working days

Any amendment to this Agreement shall be notified in writing and if made by us shall take effect on such date as we shall specify (being not less than 8 Business Days after the issue of the notice).
Clause 26 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 107 of 136 in the Investment Dealer Client Agreement, 79% of the way through.

BCM may refuse to act on any instruction at absolute discretion and without giving reasons, under clause 6.4. It says it will take reasonable steps to tell you promptly, and it is not liable if it does not act. An instruction includes an order to close a position.

Why this matters

A refusal to act on your closing order leaves you in a losing position you asked to exit. Clause 24.4 then refuses complaints about how long an order took to execute.

Exhibit 14WarningHarder than usual

We may at our absolute discretion refuse to accept or act in accordance with any instructions, without being under any obligation to give any reasons thereof. If we decline an instruction, we will take reasonable steps to notify you promptly of this but subject to this, we will not be liable for any failure to accept or act on such instructions.
Clause 6.4 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Where it sits: section 34 of 136 in the Investment Dealer Client Agreement, near the start.

  • Worse together with Exhibit 7BCM can decline your instruction without a reason, and clause 24.4 refuses complaints about how long an order took.

Losses can run past your deposit, and clause 12.4 makes you pay the shortfall on demand with interest. BCM Markets advertises leverage up to 1:500 on both account types. Your positions start closing when your margin level falls below 50%, which reduces that risk without removing it.

Why this matters

A gap in the market can leave you owing BCM money you never deposited. Nothing in the nine documents promises to write that debt off.

Exhibit 15WarningHarder than usual50%

You will at all times remain liable for the payment of any and all outstanding Obligations and if the proceeds realized pursuant to clause 12.2 are insufficient for the discharge of all such Obligations, you will promptly pay on demand the deficit and all unpaid liabilities together with interest.
Clause 12.4 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Where it sits: section 66 of 136 in the Investment Dealer Client Agreement, 49% of the way through.

Set against a regulated standard: FCA (UK), CySEC (Cyprus), ESMA (EU), ASIC (Australia)

Firms licensed by the FCA, CySEC or ASIC must give a retail client negative balance protection, so the account cannot fall below zero, and must cap retail leverage far below this level. BCM Markets offers 1:500 and makes you pay any deficit with interest.

BCM MARKETS is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Mauritius courts only, and BCM can hand your account to another company

Clause 33.3 gives the courts of Mauritius exclusive jurisdiction and has you waive any objection to that forum. Clause 23 lets BCM Markets transfer every right and obligation to an unnamed associate on one month's notice, while you may not transfer anything. Clause 32.10 has you give up the argument that you took no legal advice.

Where you would sue1 clause flagged

Disputes go to the courts of Mauritius alone, and clause 33.3 has you waive any objection to that forum. Clause 23 lets BCM transfer every right and obligation under your agreement to an unnamed associate on one month's notice. You may not transfer anything.

In plain words

On a principal basis, as your counterparty, means the broker takes the other side of your trade itself. Your loss is then the firm’s gain, so it has an interest in how your trade ends.

Why this matters

Suing in Port Louis means local lawyers and local costs, wherever you live. You also cannot argue later that you took no legal advice, because clause 32.10 waives that argument.

Exhibit 16WarningHarder than usual

Agrees not to claim that such proceedings have been brought in an inconvenient forum or that such court does not have jurisdiction over the Client.
Clause 33.3 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 127 of 136 in the Investment Dealer Client Agreement, 93% of the way through.

A transfer from a new email address becomes high risk whatever its size

The BCM Markets AML policy rates transfers over $7,500 medium risk and those over $50,000 high risk. Any transfer instruction from an email address other than the one you first gave is high risk at any amount. If BCM cannot complete its checks, the policy says it may not act on the transaction and must end the relationship.

Verification triggers1 clause flagged

Transfers over $7,500 are medium risk and those over $50,000 are high risk under the AML policy. Any transfer instruction from an email address other than the one you first gave is high risk whatever its size. High risk clients are reviewed again every nine months.

Why this matters

Change your email and your next transfer goes into the queue that gets the most scrutiny. If BCM cannot finish its checks, the policy says it may not act on the transaction and must end the relationship.

Exhibit 17WarningStandard wording$7500

Transactions exceeding a threshold of USD 7,500 or its equivalent, but below that of USD 50,000 or its equivalent will be classified as Medium Risk.
Clause Transaction Monitoring Policy in AML/CFT Policy, p.64
Read from the broker's site on Archived copyOpen the reference

Buried at section 428 of 451 in the AML/CFT Policy, 95% of the way through.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Under $7,500BCM rates the transfer low risk.Transaction Monitoring Policy
Over $7,500BCM rates the transfer medium risk.Transaction Monitoring Policy
Over $50,000BCM rates the transfer high risk.Transaction Monitoring Policy
Any amount, new email addressA transfer instruction from an email address other than the one you first gave is high risk, whatever its size.Transaction Monitoring Policy
  • Worse together with Exhibit 6A transfer instruction from a new email address is high risk, and clause 14.5 already lets BCM hold the money while it decides.

A liquidity provider can pay BCM out of what it makes from client losses

BCM Markets writes in its conflict of interest policy that a liquidity provider trading against client positions may pay it by reference to the profit that provider makes from those trades. Under clause 3.5 BCM is also the direct counterparty to your trades. The control it names, that it gives no advice, is not what the client agreement says.

Who pays BCM2 clauses flagged

BCM states in its conflict of interest policy that a liquidity provider trading against client positions may pay it by reference to the profit that provider makes from those trades. It also takes a share of the spread on your volume. Under clause 3.5 BCM is your counterparty, not your agent.

In plain words

Remuneration means payments it receives.

Why this matters

The company holding your money can earn more when your trade loses. BCM answers this by saying the payment is worked out across all client positions with that provider, not account by account.

Exhibit 18WarningStandard wording

client losses, where a Liquidity Provider trading on its own account against client positions remunerates BCM Markets Ltd by reference to profits generated by the Liquidity Provider from those trades.
Clause 16 in Conflict of Interest Policy
Read from the broker's site on Archived copyOpen the reference

Buried at section 42 of 43 in the Conflict of Interest Policy, 98% of the way through.

The conflict of interest policy answers the advice conflict by stating that BCM gives no investment advice and recommends no transaction. Clause 4.1 of the client agreement says BCM may provide advice, information or recommendations, and may manage client portfolios.

Why this matters

The control BCM names to manage this conflict is not what your agreement says. If BCM does advise you, clause 5.2 limits its liability for that advice to negligence or bad faith you can prove.

Exhibit 19Warning

BCM Markets Ltd does not provide investment advice in relation to FX and CFD transactions and therefore does not recommend any particular transaction to clients.
Clause 16 in Conflict of Interest Policy
Read from the broker's site on Archived copyOpen the reference

Buried at section 42 of 43 in the Conflict of Interest Policy, 98% of the way through.

  • Same clause as Exhibit 18Both findings rest on the same policy: one on how BCM is paid, the other on the control it names to manage that.

The contract relies on a Terms of Business that BCM does not publish

Clause 24.4 makes the Terms of Business the test for whether an execution complaint is accepted, and the best execution policy says to read it alongside the agreement. That document is not on the BCM Markets legal page. The company also sells PAMM and copy trading with no terms published for either.

The document shelf2 clauses flagged

An execution complaint is only accepted if the order was not executed as the Terms of Business provide, under clause 24.4. That document is not on the legal page and not in the set we read. The best execution policy also tells you to read it alongside the agreement.

Why this matters

The one route to a valid complaint about execution runs through a document BCM does not publish. PAMM and copy trading are sold on the site with no terms for either, and PAMM managers set performance fees of 10% to 30% of your profit.

Exhibit 20Warning

Complaints in regard to time of Order execution notwithstanding the amount of time the Company Dealer needed to execute the Order are not accepted, unless the Order placed in the queue has not been executed as the Terms of Business provide.
Clause 24.4 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Buried at section 102 of 136 in the Investment Dealer Client Agreement, 75% of the way through.

You contract with BCM Markets Ltd, registered in Mauritius with number 204864 and licensed by the FSC as an investment dealer. Your deposits are collected by Blackridge Technology Services Ltd, named only in the website footer as BCM's payment agent. No document in the set covers that arrangement.

Why this matters

The company that takes your money is not the company that owes it back to you. No investor compensation scheme is named anywhere in the nine documents, so the FSC licence is the only backstop.

Exhibit 21Notice

BCM Markets Ltd is a company duly registered in the Republic of Mauritius with registration number 204864 and license number GB23202163.
Clause 3.2 in Investment Dealer Client Agreement
Read from the broker's site on Open the reference

Where it sits: section 21 of 136 in the Investment Dealer Client Agreement, near the start.

Where the marketing and the contract disagree

A promise made in public, set against the clause that governs it

01

BCM promises compensation for a late withdrawal on its website, and the agreement says you have no remedy for any promise that is not in the agreement.

Said in public, in English

If BCM Markets fails to process your withdrawal within our stated 24-hour timeframe, you are entitled to compensation in the form of fee rebates or account credit. We believe accountability should be measurable, not just promised.

English deposits and withdrawals page, FAQ answer on withdrawal accountability

In the contract · clause 32.4

Each of the parties acknowledges and agrees that in entering into this Agreement, and the documents referred to in it, it does not rely on, and shall have no remedy in respect of, any statement, representation, warranty or understanding (whether negligently or innocently made) of any person (whether party to this Agreement or not) other than as expressly set out in this Agreement.

02

The page blames any cost on third parties, while clause 30 takes up to 5% of a non-dollar deposit as a markup charged by BCM itself.

Said in public, in English

BCM Markets does not charge any fees for deposits or withdrawals. However, third-party payment providers (banks, card issuers, crypto networks) may apply their own processing or network fees.

English deposits page, FAQ answer on deposit and withdrawal fees

In the contract · clause 30

Any amount of any currency, other than USD, transferred by you as well as such amount received from the sale or redemption of investment or paid to us shall be converted to USD at the rate provided by custodian bank appointed by us from time to time plus a markup charged by us which shall not be higher than 5%.

03

The PAMM page says client funds are protected from broker insolvency, while clause 14.4 lets a third party enforce against those assets for BCM's debts.

Said in public, in English

While your investment is subject to market risk based on the manager's trading activity, the funds themselves are protected from broker insolvency.

English PAMM page, FAQ answer on whether a PAMM investment is protected

In the contract · clause 14.4

deposit, charge or pledge such Assets with or to the order of any exchange, market operator, clearing house, intermediate broker or other third party and on terms that such third party may enforce such deposit, charge or pledge in satisfaction of all or any Obligations, and all or any obligations of ours or of any other customer of ours, to such third party)

04

The page promises withdrawals at any time with no restrictions, and clause 14.5 bars any withdrawal without BCM's consent while it says an obligation is outstanding.

Said in public, in English

There is no minimum withdrawal amount at BCM Markets. Your earnings belong to you, and you can withdraw any amount at any time without restrictions or holding periods.

English deposits page, FAQ answer on the minimum withdrawal amount

In the contract · clause 14.5

Until you have paid or discharged in full all your obligations, we shall be entitled to retain all your Assets and you may not (without our prior consent) withdraw or substitute any such Assets.

05

The Spanish page tells readers their profits belong to them, and clause 34.9 lets BCM annul all profits in the account on suspicion alone.

Said in public, in Spanish

No hay monto mínimo de retiro en BCM Markets. Tus ganancias te pertenecen, y puedes retirar cualquier monto en cualquier momento sin restricciones ni períodos de espera.

Word for word in English: There is no minimum withdrawal amount at BCM Markets. Your profits belong to you, and you can withdraw any amount at any time with no restrictions and no waiting periods.

Spanish deposits page, FAQ answer on the minimum withdrawal amount

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In the contract · clause 34.9

then the Company reserves the right, at its sole discretion, to close all open positions in the Client's Trading Account and deduct or add a penalty (equivalent to the swap and/or any profit amount) for all transactions currently and/or previously made in the account and/or annul all profits made as a result

The documents this reading is based on

9 files, all published by BCM MARKETS. Each shows when we read it and a fingerprint of its wording.

WIKILIX keeps the copy of each file it read, and does not republish it: what is published is the fingerprint of its wording. Download the file yourself and hash its text, lowercased with runs of whitespace collapsed, and a matching fingerprint means the wording quoted above is still the wording BCM MARKETS publishes.

How this reading was done

Every clause above was read out of a document BCM MARKETS publishes itself

This reading was published on .

Documents
9 of 9downloaded from the broker's site, and 9 read in full
Pages opened
26pages walked to find those documents, footer links included
Marketing pages
7public pages set against what the contract says
Languages
EN vs ESthe language it advertises in, against the language it contracts in
Position measured
21clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

BCM Markets Ltd

You contract with BCM Markets Ltd, registered in Mauritius with company number 204864 and licensed by the Financial Services Commission of Mauritius as an Investment Dealer (Full-Service Dealer except Underwriting) under licence GB23202163. Clause 3.5 says BCM deals with you as principal and not as your agent, so it is the other side of your trades. It is not an EU or UK firm, and its own pages say the site falls outside the European and MiFID II framework. Your deposits are collected by Blackridge Technology Services Ltd as BCM's authorised payment agent, named only in the website footer, and no document in the set sets out that arrangement.

Quotations are copied verbatim from the documents named above, with the clause number and the page each one came from. Where a clause is quoted in another language, the original is shown first and the English is a translation.

The plain-language parts, what a clause means for a client, how ordinary it is, and how it reads against a regulated standard, are WIKILIX's analysis and are labelled as such on every card. This is a reading of public documents, not legal advice and not an allegation of wrongdoing.

In fairness, and what we could not check

A reader who knows the edges of the work can trust the middle of it

All nine legal documents sit on one page and open without a login. Five carry a version number, a review date of 03-Jul-2026 and a board approval date, so you can see what you agreed to. Nothing in the nine documents charges a dormancy or inactivity fee. There is no bonus scheme either, so no turnover rule locks up your deposit. The conflict of interest policy states in writing that a liquidity provider trading against client positions may pay BCM out of what it makes, which most brokers leave unsaid. It adds that the payment is worked out across all clients with that provider, not account by account. The complaints policy sets a 30 business day target and tells you a rejected complaint can be appealed to the FSC.

We read all nine legal documents in full. Clause 24.4 and the best execution policy both rely on a Terms of Business, and BCM Markets does not publish it, so we could not read the one document that decides whether an execution complaint is accepted. The agreement also makes the Client Application Form (Schedule A) part of your contract, and that form sits inside the account opening flow, which we did not complete. BCM sells PAMM and copy trading and publishes no terms for either, so there was nothing to read. No earlier version of any of the nine documents is available, so this is a first reading with nothing to compare against. Figures for spreads, commission and leverage come from the account pages on bcm-markets.com, which the charge schedule in the contract points to.

How to check any of this yourself

Every quote above links to the BCM MARKETS file it came from. This is what to do with it.

Open the three stepsFind the words in the source, work out the fingerprint, and read what a difference does and does not prove.

Open the source and search for the words

Every quote has a link under it. Open the file, or the web page, and search it for the words we quote. The clause number next to the quote tells you where to look.

If the words are not there any more, the source may have changed after we read it. That is worth knowing too. We keep the date we read it, and a code worked out from its wording, so the quote stays checkable.

What a fingerprint is

A fingerprint is a code worked out from what a source says. Change one word and the code changes completely. We keep two codes for every file we read, and the panel on each source shows both.

The first is the code of the exact file we downloaded. The second is the code of its wording alone, with capital letters lowered and runs of spaces collapsed. When the same words are saved as a new file, the first code changes and the second one stays the same.

Only the first code can be worked out on your own computer. Save the file, then run one of these, putting the name of the file you saved where the example is. The panel on each source prints the command with that source's real file name already in it.

macOS or Linux:
  shasum -a 256 the-file-you-saved.pdf

Windows:
  certutil -hashfile the-file-you-saved.pdf SHA256

The two codes are different from each other, and they are not meant to match. Comparing one against the other proves nothing.

What a difference means, and what it does not

A different file code on its own proves nothing. A PDF saved again with a new date inside it is a new file saying exactly the same thing.

A different wording code means the words themselves changed. That is the one that matters, and it is why we keep it.

Even then, a change is not proof of bad faith. Companies update their documents. What this report says is what the document said on the day we read it, and every quote carries that date.

A source that is a web page and not a file has no file to save, so only the code of its wording is shown.

How this report is made

Every clause quoted above comes from a document BCM MARKETS publishes on its own website, downloaded and hashed on the date shown, with the clause number and page recorded so any reader can check it. We do not allege anything the documents do not say, and we do not judge BCM MARKETS on anything other than its own published terms and its own public marketing. Where a clause has a qualifier that softens it, the report says so. Last read Oct 11, 2026.

If you represent BCM MARKETS and a clause has changed, been withdrawn, or is being read out of context, tell us and we will re-read the documents and update this page. Corrections from the broker are welcome and are published with the reading they change. Contact us.

This is a reading of a contract, not legal advice and not a ruling on BCM MARKETS. Whether its licence is real and current is a separate check on the broker profile.

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