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Contract reading

What CARLTON legally published, but does not want you to read

Every clause below is published by CARLTON 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: Carlton Financial Limited

marketing contradictionsole discretiondispute barrierhidden feeprivacyprofit voidingcall recordingclient agreementcomplaintscountry restriction

Carlton never publishes the contract you sign. Four of its documents say a Client Agreement governs and beats them, and it is on no page of the site. Its swap-free policy lets Carlton charge you backwards in time and delete profit it calls abusive. The homepage promises negative balance protection, and the risk notice says you can lose more than you deposited.

Contract risk

Money at risk
8.2/10

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.
5
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
14
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
10
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
5

How the 14 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.

Critical5
Warning8
Notice1

section 32 of 32is where the deepest clause sits: the very end of the document it is in

What the documents say

14 clauses worth knowing about, worst first, each quoted from CARLTON's own files

01

Every legal document Carlton publishes defers to a Client Agreement that sits on no page of its site. The website terms say that agreement wins wherever the two disagree.

Why this matters

You agree to terms you cannot read. The rules on withdrawals, fees and profit all live in that document, and the registration form never shows it to you before you deposit.

Exhibit 1CriticalRarely seen

In case there is any conflict or inconsistent between the terms of this Website Terms and Conditions and between the Client Agreement then the Client Agreement shall prevail.
Clause Carlton Limited Website Terms and Conditions in Carlton Limited Website Terms and Conditions, p.1
Read from the broker's site on Open the reference

Buried at section 24 of 32 in the Carlton Limited Website Terms and Conditions, 75% of the way through.

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

Firms licensed by the FCA or CySEC must give a retail client the terms of business in a durable form before they provide any service. Carlton's documents point to a Client Agreement it does not publish.

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

Our readingBrokers normally put the client agreement first on the legal page. Here four separate documents state that the agreement governs, and the agreement itself appears nowhere on the site. The complaint procedure the terms point to is also unpublished.

  • Worse together with Exhibit 6You cannot read the contract, and the documents you can read name three different companies behind it.
02

Carlton can apply swap charges to your Islamic account after the fact, reaching back over trades you already closed, with no warning. It calls that deduction a balance correction. If it decides you misused the account, it can wipe the profit too.

Why this matters

Money already in your balance can drop weeks after the trades that earned it. Carlton does not have to tell you first, and says it owes you no justification for the decision.

Exhibit 2CriticalRarely seen

The Company reserves the right to apply swap charges or administrative holding fees retroactively, based on historical trade data, position duration, or market conditions.
Clause Retroactive Adjustments in Swap-Free (Islamic) Account Policy
Read from the broker's site on Open the reference
Our own capture of carltonfx.com, taken on Oct 3, 2026Swap-free accounts carry backdated charges and deletable profit (clause Retroactive Adjustments)Visit this page on the broker's siteDownload the full size image file

Where it sits: section 11 of 21 in the Swap-Free (Islamic) Account Policy, 52% of the way through.

Our readingMost swap-free policies either cap the free period or start charging from a stated day. This one reaches backwards over positions that are already closed, prices them on historical trade data, and books the result as a correction to your balance.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Account openedCarlton may grant swap-free status, at its sole discretion.Swap-Free (Islamic) Account Policy
While the account runsCarlton can replace the swap exemption with administrative or holding fees at any time.No Guaranteed Permanent Swap Exemption
Beyond a reasonable periodCarlton can apply swap charges. The policy never says how long that period is.Right to Apply Charges Based on Holding Duration
After the trades are closedCarlton can charge retroactively from historical trade data, with no prior notice.Retroactive Adjustments
If Carlton calls it abuseCarlton can revoke swap-free status, void the profit and close the account.Abuse and Misuse
  • Worse together with Exhibit 7The open-ended fee right in this policy is the charge the account types page says does not exist.
03

Carlton's homepage promises negative balance protection, so you only risk what you put into a trade. The risk notice says the opposite. You can lose more than you deposited, and Carlton can ask you for more money.

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.

Why this matters

Negative balance protection means a loss cannot take your account below zero. If the homepage is wrong, one bad night leaves you owing Carlton money you never deposited.

Exhibit 3CriticalStandard wording

It is possible to lose more money than you have deposited into the Account.
Clause Risk Warning in Carlton Risk Disclosure Notice, p.1
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus), ESMA (EU)

Firms licensed by the FCA, CySEC or another ESMA regime must give retail clients negative balance protection, and must cap retail leverage far below the 1:500 Carlton advertises. Carlton's own notice says you can lose more than you deposited.

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

  • Worse together with Exhibit 1Nothing Carlton publishes caps your loss, and the agreement that might sits out of reach.
04

Carlton's footer says it does not serve residents of the United States, Canada, Israel, the UAE, India or Iran. Its registration form offers the United States, India, the UAE and Israel, and arrives with India already selected.

Why this matters

If you live in one of those countries, Carlton has already written down that it does not serve you. That gives it a reason in its own words to close the account or refuse a payout later. Its form still let you in.

Exhibit 4CriticalRarely seen

Restricted Regions: Carlton Financial Limited does not provide services for the residents of certain countries, such as the United States of America, Canada, Israel, UAE, India and the Islamic Republic of Iran.
Clause Restricted Regions in Scalping Policy
Read from the broker's site on Archived copyOpen the reference
Our own capture of carltonfx.com, taken on Oct 3, 2026What the contract says, clause Restricted RegionsVisit this page on the broker's siteDownload the full size image file

Where it sits: section 7 of 32 in the Scalping Policy, near the start.

Our readingA refused country appearing in a signup list is common offshore. A refused country arriving as the preselected default on the broker's own registration form is not, and Carlton's homepage also offers Netbanking and shows the Razorpay logo, both Indian payment rails.

05

Carlton calls a trade opened and closed inside 10 seconds stale trading, and reserves the right to cancel it immediately. Anything under 180 seconds on forex or metals counts as scalping, which it does not permit.

Why this matters

A fast winning trade is not safe money. The policy never says what happens to the profit on a scalping trade. That penalty sits in the Client Agreement, which Carlton does not publish.

Exhibit 5CriticalHarder than usual

We Define 'Stale Trading' As A Method Traders Use Where They Open And Close Trades Within 10 Seconds.
Clause Stale Trading in Scalping Policy
Read from the broker's site on Archived copyOpen the reference
Our own capture of carltonfx.com, taken on Oct 3, 2026Trades closed within 10 seconds can be cancelled (clause Stale Trading)Visit this page on the broker's siteDownload the full size image file

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Under 10 secondsCarlton calls it stale trading and can cancel the trade immediately.Stale Trading
Under 180 seconds, forex and metalsThe trade counts as scalping, which Carlton does not permit on its platform.Scalping
Under 300 seconds, CFDsThe trade counts as scalping, including single stocks, indices, metals and crypto CFDs.Scalping
  • Worse together with Exhibit 1The scalping ban names no penalty, because the penalty sits in the Client Agreement Carlton does not publish.
06

The website terms say you deal with Carlton Limited, incorporated in Mauritius, under Mauritius law. The cookie policy and the trading policies name Carlton Financial Limited, at a Saint Lucia address. The contact page gives a private apartment in Tbilisi, Georgia as the physical address.

Why this matters

To get money back through a court you need to know who holds it and where. Carlton's own documents give you three answers, and none of them names a regulator you could complain to.

Exhibit 6WarningHarder than usual

This website is owned and operated by Carlton Limited ('us', 'we' and 'our'), a company incorporated in Republic of Mauritius.
Clause Carlton Limited Website Terms and Conditions in Carlton Limited Website Terms and Conditions, p.1
Read from the broker's site on Open the reference

Where it sits: section 3 of 32 in the Carlton Limited Website Terms and Conditions, near the start.

Carlton publishes no fee list, and reserves the right to add fees at any time

Carlton's account types page promises no extra charges and no hidden fees. Its swap-free policy reserves administrative fees, holding fees or other charges at any time, in place of swaps. No document on the site says what a deposit, a withdrawal or an account actually costs.

Cost disclosure1 clause flagged

Carlton's account types page is headed with a promise of no extra charges and no hidden fees. The swap-free policy lets Carlton add administrative fees, holding fees or other charges at any time, and they come out of your balance.

Why this matters

No document on the site lists what Carlton charges. There is no fee schedule, no payment terms and no withdrawal costs anywhere. You cannot work out what an account costs before you fund it.

Exhibit 7WarningHarder than usual

While positions in a Swap-Free account may initially be exempt from overnight swap charges, the Company reserves the right to apply administrative fees, holding fees, or other charges in place of swaps at any time.
Clause No Guaranteed Permanent Swap Exemption in Swap-Free (Islamic) Account Policy
Read from the broker's site on Open the reference
Our own capture of carltonfx.com, taken on Oct 3, 2026The claim, on Heading on Carlton's account types pageVisit this page on the broker's siteDownload the full size image file
Our own capture of carltonfx.com, taken on Oct 3, 2026What the contract says, clause No Guaranteed Permanent Swap ExemptionVisit this page on the broker's siteDownload the full size image file

Where it sits: section 8 of 21 in the Swap-Free (Islamic) Account Policy, 38% of the way through.

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

Firms licensed by the FCA or CySEC must show a retail client the costs and charges of a service before they trade. Carlton publishes no fee list at all.

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

Carlton can change the terms by posting them and will not tell you

Four Carlton documents say an amendment binds you the moment it appears on the website. The website terms state plainly that Carlton will not notify you separately. Noticing the change is your job, not Carlton's.

Changing the deal1 clause flagged

Four of Carlton's documents say a change binds you as soon as it appears on the website. The website terms add that Carlton will not notify you separately, and tell you to check the site regularly.

Why this matters

Carlton can rewrite what you agreed to while your money sits in the account. You find out only if you reread the documents yourself.

Exhibit 9WarningHarder than usual

The Terms and Conditions can be modified at any time by us and you agree to continue to be bound by the Terms and Conditions as modified. We will give you notice of these changes by posting the changes on our website - we will not separately notify you of these changes.
Clause Modification in Carlton Limited Website Terms and Conditions, p.3
Read from the broker's site on Open the reference

Buried at section 25 of 32 in the Carlton Limited Website Terms and Conditions, 78% of the way through.

The agreement that settles disputes is the one Carlton does not publish

Four Carlton documents defer to a Client Agreement that appears on no page of its website. The website terms switch their own arbitration clause off for clients, and send them to that unpublished agreement instead. Carlton also owns the recording of every call you make, and caps what it owes you at supplying the website again.

Missing contract2 clauses flagged

Carlton can record any call, chat or meeting it has with you. Its privacy notice says those recordings are its sole property, and that they count as the evidence of what was said.

Why this matters

If you dispute an instruction you gave by phone, Carlton holds the proof. The notice gives you no right to a copy of it.

Exhibit 11WarningHarder than usual

These recordings will be our sole property and will constitute evidence of the communications between us.
Clause What kind of personal information do we collect? in Carlton Privacy Notice, p.2
Read from the broker's site on Open the reference

Where it sits: section 18 of 44 in the Carlton Privacy Notice, 41% of the way through.

  • Worse together with Exhibit 1Carlton holds the only record of a phone instruction, and the complaints route that would weigh it is unpublished.

Carlton caps what it owes you for any loss from using the site. At most, Carlton supplies the website again, or pays for someone else to. You also agree to cover its group's costs if a third party offer on the site goes wrong.

Why this matters

This cap sits in the only contract Carlton actually publishes. It covers the website, not your trading account, and the agreement that covers the account is the one you cannot read.

Exhibit 14NoticeStandard wording

To the maximum extent permitted by law, we will not be liable in any way for any loss or damage suffered by you through use of or access to this website, or our failure to provide this website.
Clause Disclaimer and limitation of liability in Carlton Limited Website Terms and Conditions, p.3
Read from the broker's site on Open the reference

Buried at section 32 of 32 in the Carlton Limited Website Terms and Conditions, 100% of the way through.

Carlton sends your documents abroad and points you at a page that does not exist

Carlton can send your identity documents, income details and trading records to related companies in Cyprus, Vanuatu, Jordan and other places it does not name. Recordings are held for 5 or 10 years after you leave. When you ask what rights you have, the notice points at a website page Carlton has not published.

Your data2 clauses flagged

Carlton can send your identity documents, income details and trading records to related companies in Cyprus, Vanuatu, Jordan and other places it does not name. Recordings are held for 5 or 10 years after you leave.

Why this matters

When you ask what rights you have over that data, the notice points at Carlton's website, and no such page exists. There is no named contact to ask.

Exhibit 12WarningHarder than usual

For example, currently we have other Carlton related entities located in Cyprus, Vanuatu, Jordan, and other jurisdictions.
Clause Transfers outside of the European Economic Area in Carlton Privacy Notice, p.3
Read from the broker's site on Open the reference

Buried at section 37 of 44 in the Carlton Privacy Notice, 84% of the way through.

Carlton's cookie policy says it may place cookies that save your username and password on your device. The same document warns that without them you could not play games or access your account.

Why this matters

A policy that still talks about games was not written for a trading account. The file's own properties name a different company, MEX CURRENCIES & MONETARY BROKERS L.L.C, as its author. What Carlton does with your login details is not settled by this document.

Exhibit 13WarningHarder than usual

such as username, password, other personal details, e-mail address
Clause 2. Use of Cookies in Cookie Policy
Read from the broker's site on Archived copyOpen the reference

Carlton decides when its own price feed was wrong

Carlton supplies the aggregated price, decides when that price was idle or skewed, and reverses the orders filled on it. No outside benchmark is named. Its two policies also promise different outcomes: the price feed policy repricing to correct market conditions, the scalping policy a net result of zero.

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.

Price and counterparty1 clause flagged

Carlton supplies the aggregated price feed and decides when it was idle or skewed. It then reserves the right to reverse the profit and loss on orders filled at those prices. No outside reference price is named anywhere.

Why this matters

A winning trade can be unwound on Carlton's own account of what the right price was. Carlton does promise to tell you by email or by phone. It also nets a reversed pair of orders to zero, rather than leaving you the losing half.

Exhibit 8WarningStandard wording

We Reserve The Right To Reverse The Profit And Loss Realized From Orders Where Idle Stroke Happened.
Clause Idle Prices in Scalping Policy
Read from the broker's site on Archived copyOpen the reference

Carlton says it is licensed and names no regulator anywhere

Carlton's homepage says it is licensed and backed by a strong compliance framework. No document it publishes names a financial regulator, a licence number or a supervisor. None says client money is held separately from the firm's own, and none names a compensation scheme.

Licence and client money1 clause flagged

Carlton's homepage says it is licensed and backed by a strong compliance framework. No document it publishes names a financial regulator, a licence number or a supervisor. The only number published is a company registration number.

Why this matters

Nothing in the paperwork tells you which authority you could complain to. No document says your money is held separately from Carlton's own, and none names a compensation scheme.

Exhibit 10Warning

CARLTON FINANCIAL LIMITED | REGISTRATION NUMBER: 2024-00131
Clause Cookie Policy cover page in Cookie Policy
Read from the broker's site on Archived copyOpen the reference
Our own capture of carltonfx.com, taken on Oct 3, 2026The claim, on Why Carlton Fx section on the homepageVisit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must hold client money in segregated accounts, and must give clients access to an independent complaints scheme. Carlton's documents mention neither.

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

Where the marketing and the contract disagree

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

01

The homepage sells a loss capped at your trade amount, and the risk notice says your loss is not capped at all.

Said in public, in English

Negative balance protection so you only risk your trade amount

Solutions list on the Carlton FX homepage

In the contract · clause Risk Warning

It is possible to lose more money than you have deposited into the Account.

02

Carlton prints a client saying it serves the UAE, on the same site whose footer says it does not serve UAE residents.

Said in public, in English

This broker serves us both in UAE and Bahrain as clients just like our own local support teams and banking withdrawal options were also very smooth.

Client testimonial on the Carlton FX homepage

In the contract · clause Restricted Regions

Restricted Regions: Carlton Financial Limited does not provide services for the residents of certain countries, such as the United States of America, Canada, Israel, UAE, India and the Islamic Republic of Iran.

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of carltonfx.com

03

India is the country Carlton's registration form selects for you, and one of the six its footer refuses to serve.

In the contract · clause Restricted Regions

Restricted Regions: Carlton Financial Limited does not provide services for the residents of certain countries, such as the United States of America, Canada, Israel, UAE, India and the Islamic Republic of Iran.

04

The page that sells the accounts promises no extra charges, and the swap-free policy reserves charges of any size at any time.

Said in public, in English

No extra charges. No hidden fees.

Heading on Carlton's account types page

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of carltonfx.com

In the contract · clause No Guaranteed Permanent Swap Exemption

While positions in a Swap-Free account may initially be exempt from overnight swap charges, the Company reserves the right to apply administrative fees, holding fees, or other charges in place of swaps at any time.

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of carltonfx.com

05

The homepage says licensed, and the documents name an incorporation and no financial regulator anywhere.

Said in public, in English

Licensed – Backed by strong financial compliance framework.

Why Carlton Fx section on the homepage

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of carltonfx.com

In the contract · clause Carlton Limited Website Terms and Conditions

This website is owned and operated by Carlton Limited ('us', 'we' and 'our'), a company incorporated in Republic of Mauritius.

The documents this reading is based on

10 files, all published by CARLTON. 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 CARLTON publishes.

How this reading was done

Every clause above was read out of a document CARLTON publishes itself

This reading was published on .

Documents
7 of 10downloaded from the broker's site, and 7 read in full
Pages opened
26pages walked to find those documents, footer links included
Older copies
4earlier versions downloaded, 7 identical to the copy we hold by fingerprint
Marketing pages
6public pages set against what the contract says
Position measured
9clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

Carlton Financial Limited

Carlton Financial Limited is the company named in the cookie policy, the scalping policy and the swap-free policy, with registration number 2024-00131 and an address in Saint Lucia. The website terms name a different company, Carlton Limited, incorporated in Mauritius, and put Mauritius law over the contract. The contact page gives a third address, a private apartment in Tbilisi, Georgia. No document Carlton publishes names a financial regulator or a licence number, and the scalping policy refers to Client Agreements that Carlton does not publish.

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

Carlton publishes its scalping, swap-free and price feed rules as plain web pages rather than burying them in a PDF. It gives real numbers where most offshore brokers give none: 180 seconds, 300 seconds, 10 seconds. The price feed policy promises an email or a phone call when a trade is cancelled. It also nets a reversed pair of orders to zero, instead of leaving you holding the losing half. The risk notice is blunt in a useful way, and tells you plainly that you can lose more than you put in.

We could not find Carlton's Client Agreement. We checked the footer of every page, the legal links and the account registration form, and it is published nowhere. Carlton links an AML and KYC page and a legal documents page, and neither one exists. We did not read Carlton's About page, so nothing from it appears here. Every marketing line quoted here comes from a page we opened ourselves. Carlton's cookie policy PDF has broken characters in its text, so our quotations from it are kept short. The site is published in English only, so there was no second language version to hold against the documents. The three web policies have no earlier copy anywhere, so we cannot say when they first appeared. We checked the four archived PDFs by fingerprint rather than reading them again.

How to check any of this yourself

Every quote above links to the CARLTON 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 CARLTON 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 CARLTON 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 3, 2026.

If you represent CARLTON 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 CARLTON. Whether its licence is real and current is a separate check on the broker profile.

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