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Contract reading

What CDO Markets legally published, but does not want you to read

Every clause below is published by CDO 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: CDO Markets Limited

profit voidingunilateral amendmentdeemed acceptancehidden feesegregationsole discretionaccount accessbonus lockcampaignclient money

CDO Markets Limited contracts from Port Vila, Vanuatu, through a 15 page PDF that carries no version number. Clause 16.2 lets it use your pooled money to cover another client's default, while its own FAQ promises your cash back immediately in a default. A paragraph added since 2022 lets it cancel, void or delete your trades without notice. The FAQ says there are no fees at all, and clause 22 charges $15 a month once an account sits 13 months without a trade.

Back to CDO Markets

Contract risk

Money at risk
8.0/10

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.
4
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
18
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 18 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.

Critical4
Warning12
Notice2

section 20 of 22is where the deepest clause sits, 91% of the way into 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.

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

Critical$15Fee on an unused account. Jump to the clause this comes from.A dormant account is charged $15 a month until empty25%Profit at risk. Jump to the clause this comes from.Fast trades and robot trades can be reversed28 daysTime to complain. Jump to the clause this comes from.A 28 day complaint target with no outer limit50%Bonus requirement. Jump to the clause this comes from.Cashback needs a partner account and can be forfeited

What the documents say

18 clauses worth knowing about, worst first, each quoted from CDO Markets's own files

01

Your money sits in one shared account with every other client's money. Clause 16.2 then lets CDO Markets use anything in that account to meet the default of any client of the company.

Why this matters

Another trader's unpaid loss can be settled out of the balance you deposited. You get no notice, no say and no stated right to be repaid.

Exhibit 1CriticalRarely seen

The Client acknowledges that all monies credited to the Client Bank Account maintained by the Company may be used by the Company to meet the default of any client of the Company.
Clause 16.2 in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.11
Read from the broker's site on Open the reference

Buried at section 104 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), 80% of the way through.

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

Firms licensed by the FCA or CySEC must hold retail client money so that one client's shortfall cannot be met out of another client's funds. This contract says the opposite, and permits it for the default of any client.

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

Our readingPooling client money in one bank account is ordinary. A clause letting the firm spend that pooled money on another client's default is not, because it moves a stranger's loss onto your balance.

  • Same clause as Exhibit 15The same clause empties the compensation promise CDO Markets prints on every legal page.
02

CDO Markets can decide on its own that your trading was abusive, manipulative or fraudulent, then cancel, void or delete your trades and suspend the account without telling you first. None of those three words is defined anywhere in the contract.

In plain words

Liquidity providers are outside banks and brokers.

Why this matters

Profit you have already made can be removed before you are asked a single question. A second sentence in the same paragraph lets CDO Markets undo your trade whenever one of its liquidity providers undoes a trade, for any reason, with no liability to you.

Exhibit 2CriticalHarder than usualNew

The Company reserves the right, at its sole discretion, to monitor, identify, and take action against any abusive, manipulative, or fraudulent trading behavior. This includes, without limitation, the right to cancel, void, or delete trades, restrict account activity, or suspend accounts without prior notice if such behavior is detected.
Clause Scalping and EAs Policy in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.5
Read from the broker's site on Open the reference

Where it sits: section 32 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), near the start.

  • Worse together with Exhibit 3One clause reverses trades on a measurable test, this one needs no test at all.
  • Worse together with Exhibit 5Trades can be deleted here, and the liability clause caps what you could ever recover for it.
03

Stop trading for 13 months and CDO Markets charges you $15 every calendar month for holding the account. The fee never pushes you into debt, it stops at whatever is left, so a small balance is drained to zero.

Why this matters

Money you left behind disappears at $15 a month without you doing anything. The same clause sets two clocks, 13 consecutive months in one sentence and one calendar year in the next, so you cannot tell when the charging starts.

Exhibit 4CriticalHarder than usual$15

The monthly inactive account fee is USD 15.00 (fifteen) per calendar month.
Clause 22 in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.12
Read from the broker's site on Open the reference

Buried at section 110 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), 85% of the way through.

What it costsA dormant account holding $150 loses $15 a month once the clock runs out. Ten months later there is nothing left.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
After 13 consecutive months with no tradesThe monthly charge becomes payable, counted from your last trade or rollover.22
Every calendar month after thatCDO Markets takes $15 out of the balance.22
Balance smaller than the feeOnly the amount that zeroes the account is charged, so the account is emptied rather than put into debit.22
Dormant for one calendar yearThe same clause says the fee applies at twelve months, against its own 13 month trigger.22
  • Worse together with Exhibit 6This is the only fee the contract names, and clause 9.1 lets CDO Markets add others whenever it likes.
04

Whatever CDO Markets does or fails to do, the most you can recover is the amount you paid it for access to the service. The same section calls that your sole and exclusive remedy.

Why this matters

Most clients pay nothing for platform access, so the cap leaves you with nothing to claim. A failed order, a frozen platform or a deleted trade all land inside that limit, and the contract also asks you to cover CDO Markets for claims arising from your use of its system.

Exhibit 5CriticalHarder than usual

Any liability arising out of any action or omission by us shall be limited to an amount equal to the amount of user fees paid to us by you for service access.
Clause 4. Electronic Trading Terms in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.4
Read from the broker's site on Open the reference

Where it sits: section 28 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), near the start.

05

The contract says CDO Markets deals as principal on its own account and can take the opposite position to yours, either for another client or for itself. Its own FAQ tells you there is no dealing desk and that orders run straight through without human intervention.

Why this matters

When CDO Markets is on the other side, your loss is its gain. It also quotes the only prices used to value your positions, and it publishes no conflict of interest policy explaining how it handles that.

Exhibit 9WarningStandard wording

The Client acknowledges that the Company may, in certain circumstances, take the opposite position in a Foreign Exchange, either acting for another client or on its own account.
Clause 5 in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.9
Read from the broker's site on Open the reference

Where it sits: section 73 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), 56% of the way through.

CDO Markets still advertises campaigns that closed in 2023

The Raw Spread offer sits in the CDO Markets main menu as a limited time zero commission deal, and its own condition 3 says it ran only to 30 November 2023. The countdown clock on that page now runs backwards past a thousand days. The cashback page leads with a 50% rate that its own duration line ended on 31 January 2026.

Offers that ended1 clause flagged

The menu still offers Raw Spread as a limited time zero commission deal. The conditions on that page say it ran from 31 October to 30 November 2023, and the countdown clock on it has been running backwards for over a thousand days.

Why this matters

You can open an account expecting zero commission and get the standard $2 per side instead. The cashback page does the same: it leads with 50% of the spread back, then says that rate ended on 31 January 2026 and drops to 40%.

Exhibit 13WarningHarder than usual

Valid from October 31st to November 30st, 2023.
Clause Campaign Conditions, 3 in Raw Spread Campaign Conditions
Read from the broker's site on Open the reference
Our own capture of cdomarkets.com, taken on Sep 18, 2026The claim, on Raw Spread campaign, still listed in the main menu as a limited time offerVisit this page on the broker's siteDownload the full size image file
Our own capture of cdomarkets.com, taken on Sep 18, 2026What the contract says, clause Campaign Conditions, 3Visit this page on the broker's siteDownload the full size image file

CDO Markets fixes its own charges and publishes no rates

Clause 9.1 makes you pay commissions, fees, taxes and charges at rates CDO Markets sets itself and tells you about when it chooses. No rate card sits in the contract or in any other legal document it publishes. The leveraged crypto page shows what that permits: interest applied every 8 hours, three times a day, with the rate stated nowhere.

Cost disclosure1 clause flagged

Clause 9.1 makes you pay commissions, fees, taxes and charges at rates CDO Markets decides itself, notified to you whenever it chooses. No rate card appears in the contract or in any other legal document.

Why this matters

You agree to charges before knowing what they are. The leveraged crypto page shows how that works: interest is applied every 8 hours, three times a day, and the rate is published nowhere.

Exhibit 6WarningHarder than usual

The Client must pay to the Company commissions, fees, taxes and charges in connection with dealing in Foreign Exchange for the Client at the rates determined by the Company from time to time and notified to the Client in writing from time to time.
Clause 9.1 in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.10
Read from the broker's site on Open the reference
Our own capture of cdomarkets.com, taken on Sep 18, 2026The claim, on Deposit and Withdrawal page, withdrawal sectionVisit this page on the broker's siteDownload the full size image file

Buried at section 85 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), 65% of the way through.

What it costsInterest every 8 hours means three charges a day. Hold a crypto perpetual position for a week and it is charged 21 times, at a rate the site never states.

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

Firms licensed by the FCA or CySEC must give a retail client the costs and charges before that client trades. This contract sets no rates at all and leaves CDO Markets to fix them later.

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

Nothing in the CDO Markets contract obliges it to pay you out

All 15 pages of the CDO Markets agreement contain no withdrawal clause: no deadline, no method, no minimum and no duty to return your money. The only published rule on payouts sits in the money laundering policy, which sends funds back to the account they came from and never to a third party. The one day approval time appears on the FAQ page, not in the contract.

Getting paid1 clause flagged

Read all 15 pages and you will not find a withdrawal clause. No deadline, no method, no minimum and no duty on CDO Markets to send your money back, while its FAQ promises bank wires are generally approved in one day.

Why this matters

That one day figure is a line on a web page, not a term you can hold CDO Markets to. The only published rule on payouts is a routing rule: money goes back to the account it came from, and never to a third party.

Exhibit 7WarningHarder than usual

Likewise CDO Markets will never disburse funds to a Third Party, and will always “return to sender” i.e. Client Account at CDO to Client account at correspondent bank where the original transfer was made.
Clause Money Transfer Policy Overview in Anti-Money Laundering Policy
Read from the broker's site on Open the reference

Where it sits: section 14 of 27 in the Anti-Money Laundering Policy, 52% of the way through.

CDO Markets can undo your trades and spend your pooled money

Clause 16.2 lets CDO Markets use the pooled client account to meet the default of any client, which means your balance can pay for a stranger's loss. A paragraph added since 2022 lets it cancel, void or delete trades at its sole discretion and without prior notice, and undo your trade whenever a liquidity provider undoes one. A third clause reverses orders placed with an expert advisor on an undeclared account.

Money already earned1 clause flagged

Open and close trades inside 120 seconds, and once those trades pass 25% of your total, CDO Markets treats you as a scalper. Scalping and automated trading are allowed on special accounts only, and orders placed without that label can be reversed.

Why this matters

You can lose completed profit for using an expert advisor you never declared at signup. CDO Markets does undertake in the same clause to treat you fairly and to leave no stray open positions behind.

Exhibit 3WarningStandard wording25%

In order to ensure the stability of the Company platforms and Products, Scalping strategies (we define "Scalping" as a method traders use where they open and close trades within 120 seconds, and these Scalping trades constitute more than 25% of total trades) and EA strategies (an "EA" is an "Expert Advisor", which is add-on software linked to a Meta Trader currency platform, and allows for automatic trades under certain conditions) are allowed on special accounts only.
Clause Scalping and EAs Policy in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.5
Read from the broker's site on Open the reference

Where it sits: section 30 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), near the start.

The CDO Markets cashback needs a partner account and can be taken back

The 50% spread rebate requires you to open an introducing broker account alongside your trading account, and applies only to accounts up to $5,000 trading FX majors. CDO Markets can disqualify you and strip rewards already earned if it decides you were scalping, a term the campaign page never defines. No separate bonus terms document exists anywhere on the site.

Rebates with conditions1 clause flagged

To collect the advertised 50% spread rebate you have to open an introducing broker account as well as a trading account. CDO Markets can disqualify you and take back rewards already earned if it decides you were scalping.

Why this matters

Rebates you have already banked can be removed, and the campaign page never says what counts as scalping. The contract's own test, 120 seconds and more than 25% of trades, appears nowhere on that page, and no separate bonus terms document exists.

Exhibit 14WarningHarder than usual50%

Scalping is not permitted under this campaign. Participants found engaging in scalping activities will be disqualified and may forfeit any rewards or benefits earned through the campaign.
Clause Scalping in Cashback Campaign, Conditions and Rules
Read from the broker's site on Open the reference

The rules that matter sit outside the contract you sign

Leverage, stop out levels and swap charges live on CDO Markets marketing pages, and clause 19 says the agreement is only the four contract documents. Two of its own pages already give different stop out levels for 1:500 leverage, 100% and 50%. The contract itself carries no version number since 2022, and a revised privacy statement can block access to your account and your orders until you accept it.

Terms you cannot pin down3 clauses flagged

Leverage, stop out levels and swap charges live on CDO Markets marketing pages, not in the agreement you sign. Clause 19 then says the agreement is only the four contract documents, so those pages form no part of it.

In plain words

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

Why this matters

CDO Markets can change the level where your positions are closed by editing a web page, and you have no clause to point at. Two of its own pages already disagree: the account types table sets a 100% stop out at 1:500 leverage, the raw spread campaign sets 50%.

Exhibit 8WarningHarder than usual

The Client agrees that the Client Agreement, Contract Information Guide, Disclosure Statement and Client Acknowledgement constitutes the entire agreement between the Company and the Client and supersedes any prior agreement relating to the subject matter of this agreement or any prior declaration or statement both parties may have made.
Clause 19 in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.12
Read from the broker's site on Open the reference

Buried at section 107 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), 82% 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
Balance 100 USD to 5,000 USDLeverage up to 1:500, positions closed at a 100% stop out level.LEVERAGE POLICY
Balance 5,001 USD to 10,000 USDLeverage falls to 1:400 and the stop out level moves to 75%.LEVERAGE POLICY
Balance 10,001 USD to 15,000 USDLeverage falls to 1:300 and the stop out level moves to 50%.LEVERAGE POLICY
Balance 15,001 USD to 100,000 USDLeverage falls to 1:200 and the stop out level moves to 20%.LEVERAGE POLICY
Above 100,000 USDLeverage falls to 1:100 and the stop out level moves to 10%.LEVERAGE POLICY
  • Worse together with Exhibit 17Terms you cannot version and rules kept off the contract leave you unable to prove what you agreed to.

When CDO Markets changes its privacy statement, the next login puts the new version in front of you. You cannot see your account information or place an order until you agree to it.

Why this matters

A revised statement can stand between you and a position you need to close. Accepting terms you have not read becomes the price of reaching your own money.

Exhibit 12WarningHarder than usual

The first time you log on to a non-public part of our web site after we have modified our Web site Privacy Statement, you will be required to click-through our revised Statement. Accessing your account information or placing an order will not be possible until you agree to the terms of the revised Statement
Clause Web Site Privacy Statement Updates in Privacy Policy
Read from the broker's site on Open the reference

Buried at section 47 of 55 in the Privacy Policy, 85% of the way through.

CDO Markets dropped the version marker from its terms. The 2022 copy was labelled V2.1, today's file at the same address has no label, and it states that it replaces all previous versions.

Why this matters

You cannot prove which wording you agreed to, because a new file can replace the old one at the same address with nothing to tell them apart. The signup form asks you to accept the Client Agreement and shows you no copy of it at that step.

Exhibit 17WarningHarder than usual

This Disclosure Statement (“DS”) replaces all previous versions of the DS.
Clause Background in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.2
Read from the broker's site on Open the reference

Where it sits: section 7 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), near the start.

Your maximum claim is the platform fees you paid CDO Markets

CDO Markets caps all liability at the user fees you paid it for service access, and calls that your sole and exclusive remedy. Most clients pay no such fee, so the cap leaves nothing to claim. Its complaints procedure then sets a 28 day target it only has to endeavour to meet, allows open ended further investigation, and names no independent body.

If it goes wrong1 clause flagged

CDO Markets acknowledges a complaint within five business days and aims to resolve it in 28 days. It only has to endeavour to meet that, and it can extend the case for further investigation with no end date given.

Why this matters

If the 28 days pass, nothing happens automatically and no outside body is named for you to go to. Your complaint goes to an email address at the same company you are complaining about.

Exhibit 10WarningHarder than usual28 days

CDO Markets will acknowledge your complaint within five business days and endeavour to resolve your complaint within 28 days.
Quoted in Complaints Procedure
Read from the broker's site on Open the reference

Where it sits: section 11 of 22 in the Complaints Procedure, 50% of the way through.

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

Firms licensed by the FCA or CySEC must answer a complaint inside a fixed final deadline and then tell the client about an independent complaints scheme. CDO Markets sets a target it only promises to endeavour to meet and names no outside body.

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

CDO Markets can pass your details to marketers unless you object

The CDO Markets privacy policy lists publishers and direct marketers among the third parties that may receive your name, income and trading history. Sharing stops only if you ask to opt out, and the opt out expressly does not cover your introducing broker. The policy also relies on a UK statute replaced in 2018 and says the firm may charge a small fee to show you the data it holds.

Your data1 clause flagged

CDO Markets lists the third parties it may hand your name, address, income and trading history to. The list includes publishers and direct marketers, and you only stop it by asking to opt out.

Why this matters

Your financial details travel unless you object, and the opt out does not cover disclosures to your introducing broker. CDO Markets also says it may charge you a small administrative fee to show you the data it holds, under a UK statute replaced in 2018.

Exhibit 11WarningHarder than usual

Publishers and other direct marketers of products related to the financial services industry, such as newsletter or book publishers and software or trading system developers;
Clause Who we may share your information with in Privacy Policy
Read from the broker's site on Open the reference

Buried at section 40 of 55 in the Privacy Policy, 73% of the way through.

  • Worse together with Exhibit 14The cashback offer pushes you into opening an introducing broker account, the one disclosure you cannot opt out of.

A 20,000 euro protection claim sits above a contract that names no scheme

Every CDO Markets legal page carries a claim that a compensation fund protects traders up to €20,000 per complaint. None of its legal documents mentions any compensation scheme, and the definition its segregation promise rests on is cut off mid phrase. The risk disclosure confirms you can lose more than you deposited, and clause 8.3 leaves you liable for the shortfall.

What protects the money2 clauses flagged

The risk disclosure says you may lose more than you put in and may have to pay in more later. Clause 8.3 makes you liable for any shortfall after CDO Markets closes your positions.

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

A gap in the market can leave you owing CDO Markets money on top of the deposit you already lost. Nothing in the documents offers negative balance protection, which would write that shortfall off.

Exhibit 18WarningStandard wording

You may lose more than the amount originally invested and, in respect of these products traded on margin, you may have to pay additional funds later.
Quoted in Risk Disclosure
Read from the broker's site on Open the reference

Where it sits: section 8 of 22 in the Risk Disclosure, 36% of the way through.

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

Retail clients of firms under the FCA and ESMA rules get negative balance protection, so losses cannot take the account below zero. This contract makes you liable for the deficiency instead.

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

Every legal page tells you a compensation fund gives traders up to €20,000 of protection per complaint. No CDO Markets legal document mentions a compensation scheme, and the contract lets your pooled money pay another client's default.

Why this matters

You cannot find out from the documents how to claim that money, or who pays it. The segregation promise you do get points at a rule book the contract names only halfway, as the Futures Industry (Client Funds), with no country and no year.

Exhibit 15NoticeHarder than usual

The FMA offers a transparent process and a compensation fund that provides traders with up to €20,000 protection per complaint.
Quoted in Risk Disclosure
Read from the broker's site on Open the reference

Buried at section 20 of 22 in the Risk Disclosure, 91% of the way through.

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

Firms licensed by the FCA or CySEC belong to a statutory compensation scheme with published limits and a claims process. CDO Markets names a trade association fund on its web pages and mentions no scheme in its legal documents.

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

Vanuatu law governs, and no court is named

One sentence in the CDO Markets agreement settles the governing law as Vanuatu law. No court, arbitration body or venue appears anywhere in the document. The company you would sue is registered at 1276 Kumul Highway, Port Vila.

Where a claim goes1 clause flagged

One sentence settles the law that governs your account: Vanuatu law. The contract names no court, no arbitration body and no place where a dispute would be heard.

Why this matters

A claim against CDO Markets means Vanuatu law and a company registered in Port Vila. With no forum written down, you cannot tell before you deposit where you would have to bring it.

Exhibit 16NoticeStandard wording

The provisions of this Agreement shall be governed by Vanuatu law.
Clause 21 in Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), p.12
Read from the broker's site on Open the reference

Buried at section 109 of 130 in the Terms and Conditions (Disclosure Statement, Client Agreement, Contract Information Guide and Client Acknowledgement), 84% of the way through.

Where the marketing and the contract disagree

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

01

The FAQ promises your money back immediately if there is a default, and the contract lets that same money be spent on someone else's default.

Said in public, in English

All client money will be maintained in segregated accounts in line with certain laws and regulations, keeping it completely separate from funds required to run the business. Rest assured that client payments will be refunded to your bank account immediately in the unlikely event of a default rather than being viewed as a recoverable asset by general creditors.

FAQ 24, Is my cash secured?

In the contract · clause 16.2

The Client acknowledges that all monies credited to the Client Bank Account maintained by the Company may be used by the Company to meet the default of any client of the Company.

02

CDO Markets tells you it charges nothing, while its contract charges $15 a month on an idle account and its own table charges $2 per side on an ECN account.

Said in public, in English

Trading is absolutely free at CDO Markets, and there are no fees or charges. However, some of them can be a result of the service provider you choose.

FAQ 27, How much does CDO Markets charge in fees or commissions?

In the contract · clause 22

The monthly inactive account fee is USD 15.00 (fifteen) per calendar month.

03

The FAQ says nobody at CDO Markets stands between you and the market, and the contract lets the firm take the other side of your trade.

Said in public, in English

No. Our negative response indicates that the trading system fully executes all trading orders. Straight-Through Processing (STP) (without human intervention) is how orders are carried out.

FAQ 9, Is there a dealing desk at CDO Markets?

In the contract · clause 5

The Client acknowledges that the Company may, in certain circumstances, take the opposite position in a Foreign Exchange, either acting for another client or on its own account.

04

The money page presents CDO Markets charges as none, and the contract publishes no rates while letting the firm set them itself.

Said in public, in English

CDO Markets do not charge any fee for withdrawal of your funds and cannot be held responsible for any additional bank and/or any other fees incurred as a result of bank transfers.

Deposit and Withdrawal page, withdrawal section

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

In the contract · clause 9.1

The Client must pay to the Company commissions, fees, taxes and charges in connection with dealing in Foreign Exchange for the Client at the rates determined by the Company from time to time and notified to the Client in writing from time to time.

05

The campaign is advertised today as a live limited time offer, and its own conditions say it closed on 30 November 2023.

Said in public, in English

We’re eliminating commission fees so that you can keep more of your hard-earned profits.

Raw Spread campaign, still listed in the main menu as a limited time offer

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

In the contract · clause Campaign Conditions, 3

Valid from October 31st to November 30st, 2023.

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

What changed quietly

This is our first reading of CDO Markets, so there is nothing to compare it against.

  • ADDEDClause Scalping and EAs Policy

    CDO Markets gave itself the power to void or delete trades and suspend accounts without notice, which the 2022 version did not contain.

    The Company reserves the right, at its sole discretion, to monitor, identify, and take action against any abusive, manipulative, or fraudulent trading behavior. This includes, without limitation, the right to cancel, void, or delete trades, restrict account activity, or suspend accounts without prior notice if such behavior is detected.

  • ADDEDClause Scalping and EAs Policy

    A cancellation by someone CDO Markets deals with can now undo your trade, and that link did not exist in 2022.

    The Company may, from time to time, hedge its positions with liquidity providers. In the event that a liquidity provider cancels, reverses, or modifies a transaction for any reason, the Company shall have the corresponding right to cancel, reverse, or adjust the Client’s transaction accordingly, without incurring any liability to the Client.

  • REWRITTENClause Title page

    The version number came off the front page, so the file you accept today carries no marker at all.

    DISCLOSURE STATEMENT

  • REWRITTENClause Client Acknowledgement, 6

    You now confirm that CDO Markets fully explained the terms to you, which closes off a later complaint that nobody did.

    the trading terms and services herein have been fully explained to the client by the Company or its authorized representative

  • ADDEDClause Client Agreement, parties

    The current contract names the parties and gives the full Port Vila address, where the 2022 copy left the address line blank.

    CDO Markets Limited (“the company”) 1276 Kumul Highway, 1st Floor, Govant Building, Port Vila, VANUATU; and

The documents this reading is based on

10 files, all published by CDO 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 CDO Markets publishes.

How this reading was done

Every clause above was read out of a document CDO Markets publishes itself

This reading was published on .

Documents
9 of 10downloaded from the broker's site, and 9 read in full
Pages opened
25pages walked to find those documents, footer links included
Older copies
2earlier versions downloaded
Marketing pages
11public pages set against what the contract says
Position measured
16clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

CDO Markets Limited

You contract with CDO Markets Limited, 1276 Kumul Highway, 1st Floor, Govant Building, Port Vila, Vanuatu. The contract names no other company, no group parent and no local branch. Every legal page repeats the same Vanuatu licence number, 17936. The document set is thin for the products sold: the same entity offers stocks, options and leveraged crypto with no payment terms, no conflict of interest policy and no client categorisation document.

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

Four things here are better than the offshore average. Clause 3.4 puts client orders ahead of the firm's own trades. The scalping rule sets a measurable test, 120 seconds and more than 25% of trades, instead of leaving abusive trading undefined. The complaints page gives a named email, a five business day acknowledgement and a 28 day target, which many Vanuatu brokers publish nothing about. The current contract also adds the full Port Vila address and names the parties, which the 2022 copy left blank, and the menu labels the old 1:888 leverage offer as ended.

CDO Markets publishes six legal documents and one contract. There is no payment terms document, no bonus terms document and no conflict of interest policy for us to read, so the rules on deposits, withdrawals, leverage, stop outs and cashback exist only on marketing pages. We read those pages ourselves today, and CDO Markets can edit them at any time. The client portal at our.cdomarkets.com needs an account, so any terms shown inside it are outside this reading. We compared the contract against the broker's own 2022 copy and the risk disclosure against a May 2026 copy. No earlier copy of the privacy policy, the money laundering policy, the complaints procedure or the glossary exists for comparison. The site is published in English only, so there was no second language version to hold against the contract.

How to check any of this yourself

Every quote above links to the CDO 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 CDO 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 CDO 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 Sep 18, 2026.

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

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