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Contract reading

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

Every clause below is published by esaFX 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: PT Esandar Arthamas Berjangka

unpublished termswithdrawalsaccount closureaccount openingbiometricsclient agreement missingcomplaint deadlineconflict of interestdata retentiondata sharing

EsaFX publishes a privacy policy, a complaint procedure and a staff code of conduct. It publishes no client agreement, no fee schedule and no withdrawal rules. Its own deposits page asks whether deposits and withdrawals carry fees and leaves the answer blank. Complaints run through BAPPEBTI's portal, and the 21 working day clock starts only once BAPPEBTI approves.

Contract risk

Harder than average
5.5/10

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.
0
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
8
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
5
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
3

How the 8 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.

Critical0
Warning7
Notice1

section 18 of 34is where the deepest clause sits, 53% 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.

What the documents say

8 clauses worth knowing about, worst first, each quoted from esaFX's own files

01

EsaFX publishes a privacy policy, a complaint page and a staff code of conduct. None of the three covers your money. Its privacy policy calls itself part of other customer agreement documents, and those documents are not published.

Why this matters

Nothing tells you what EsaFX may charge, how long it may hold a withdrawal, or what it may do with your profit. You cannot compare its terms with another broker's, because there are none published to read.

Exhibit 1WarningHarder than usual

This Privacy Policy is an integral part that cannot be separated from other customer agreement documents.
Clause opening paragraph in Privacy Policy
Read from the broker's site on Archived copyOpen the reference
Our own capture of esafx.co.id, taken on Oct 2, 2026The claim, on Open Account page, step 1 of 5Visit this page on the broker's siteDownload the full size image file
Our own capture of esafx.co.id, taken on Oct 2, 2026What the contract says, clause opening paragraphVisit this page on the broker's siteDownload the full size image file

Where it sits: section 1 of 34 in the Privacy Policy, near the start.

  • Worse together with Exhibit 2The fee promise is qualified by terms and conditions, and those are among the documents EsaFX does not publish.
  • Worse together with Exhibit 3With no agreement published, there is no rule a client can hold EsaFX to when a withdrawal stops.
02

EsaFX promises instant transactions with no processing fees, then adds that terms and conditions apply. You cannot read those conditions anywhere on the site. On the same page, EsaFX asks whether deposits and withdrawals carry fees and prints no answer.

Why this matters

A fee you were not told about comes out of the money you deposited. If EsaFX does charge one, the page that promised none also refuses to name it.

Exhibit 2WarningHarder than usual

Enjoy Instant transactions with no processing fees (terms and conditions apply).
Quoted in Deposits And Withdrawals
Read from the broker's site on Open the reference
Our own capture of esafx.co.id, taken on Oct 2, 2026Fee promise rests on terms EsaFX does not publishVisit 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 give a retail client the costs and charges of a product before they trade. EsaFX publishes a conditional promise of no processing fees and no figure behind it.

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

03

Nothing EsaFX publishes tells you when a withdrawal arrives, what it costs, or when it can be refused. Its deposits page asks how long deposits and withdrawals take and leaves the space under the question empty.

Why this matters

If a withdrawal stalls, you have no published rule to point to and no deadline to hold EsaFX to. The only answer it publishes about leaving is to contact customer support.

Exhibit 3WarningHarder than usual

How long do deposits and withdrawals take?
Quoted in Deposits And Withdrawals
Read from the broker's site on Open the reference
Our own capture of esafx.co.id, taken on Oct 2, 2026No published withdrawal timetable, limit or refusal groundVisit this page on the broker's siteDownload the full size image file
04

You get no deadline for EsaFX's first reply. Its seven published steps send you to BAPPEBTI's portal to file. The 21 working day limit on EsaFX's own handling starts only after BAPPEBTI approves your complaint.

Why this matters

Your complaint can wait as long as that approval takes, and nothing published limits the wait. You also have no named person at EsaFX who must answer you first.

Exhibit 4WarningStandard wording21 working days

The maximum period for handling customer complaints is 21 (twenty one) working days after BAPPEBTI gives approval to receive customer complaints.
Clause Complaint Time Period in Complaint
Read from the broker's site on Archived copyOpen the reference
Our own capture of esafx.co.id, taken on Oct 2, 2026Complaint clock starts only when BAPPEBTI approves (clause Complaint Time Period)Visit this page on the broker's siteDownload the full size image file

What it costs21 working days spread across five day weeks is 29 calendar days. That count starts on the day BAPPEBTI approves the complaint, not the day you sent it.

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

Firms licensed by the FCA or CySEC must answer a complaint within a set period and name an independent scheme the client can go to. EsaFX sets no period for its own first reply.

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

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Step 1You send your complaint to EsaFX by WhatsApp or email.Submit Complaint
Step 2An EsaFX administrator directs you to the BAPPEBTI complaints website.Get Assistance
Step 3You fill in the complaint on BAPPEBTI's online system, not on EsaFX's site.Form Filling
Step 4You upload proof of your fund transfer, and a special power of attorney if someone complains for you.Complaint Details
Step 5BAPPEBTI verifies and approves the complaint before EsaFX's own handling stage begins.Complaint Processing
Step 6EsaFX then has 21 working days to handle the complaint, counted from that approval.Complaint Time Period
Step 7EsaFX reports the result of the handling to BAPPEBTI.Complaint Reports
05

EsaFX's Indonesian privacy policy says it keeps your data for the period the law requires. It also says you can ask for data to be corrected. The English version of that same section says neither, and repeats the list of statutes from the paragraph above it.

Why this matters

Reading in English, you are never told how long EsaFX holds your identity number, your bank account number or your fingerprint data. The Indonesian reader is told. Same policy, same page, two different promises.

Exhibit 6WarningHarder than usual

In managing personal information, EsaFX is subject to the provisions of applicable laws and regulations in Indonesia, including but not limited to Law Number 32 of 1997 as amended by Law Number 10 of 2011 concerning Commodity Futures Trading
Clause Retention and Disposal of Personal Information in Privacy Policy
Read from the broker's site on Archived copyOpen the reference
Our own capture of esafx.co.id, taken on Oct 2, 2026The claim, on Indonesian version of the privacy policy, section Penyimpanan dan Pemusnahan Informasi PribadiThis 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
Our own capture of esafx.co.id, taken on Oct 2, 2026What the contract says, clause Retention and Disposal of Personal InformationVisit this page on the broker's siteDownload the full size image file

Where it sits: section 9 of 34 in the Privacy Policy, 26% of the way through.

  • Worse together with Exhibit 5The missing retention rule matters more because the data collected includes fingerprints, photo gallery and bank account number.

EsaFX collects your fingerprint, camera and photo gallery to run its app

EsaFX's privacy policy claims your fingerprints or biometrics, camera, photo gallery, storage and location, and gives app functionality as the reason. The same policy has you agree it may share your identity data with business partners, affiliates, search engines and others. The advertised entry is a US$10 deposit, and the documents demanded include proof of wealth and whatever else the brokerage representative thinks appropriate.

Data demands1 clause flagged

EsaFX's privacy policy claims your fingerprints or biometrics, camera, photo gallery, storage space and location, and gives app functionality as the reason. The same policy has you agree it may share your identity data with business partners, affiliates, search engines and others.

Why this matters

You give this consent once, at account opening, and cannot accept some items and refuse others. The advertised way in is a US$10 deposit, and the list of who may receive your data ends with "and others".

Exhibit 5WarningHarder than usual$10

Regarding device information, namely information generated on the basis of your use of the application. This information includes, without limitation, IP address/cellphone ID, location, camera, media/gallery, storage space, fingerprints/biometrics for devices, device type information, cellphone network information and other information.
Clause Collection and Use of Personal Information in Privacy Policy
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 6 of 34 in the Privacy Policy, near the start.

EsaFX records its conflicts of interest in a register it keeps confidential

EsaFX's code of conduct, added since April 2026, has staff declare conflicts to their manager and logs them in a register it keeps confidential. Dealers and analysts may trade the same market personally with written approval from their manager and the President Director. Nothing in the published set tells you when a conflict touches your account.

Who takes your side1 clause flagged

EsaFX's code of conduct has staff declare a conflict of interest to their manager, then records it in a company register it keeps confidential. Dealers and analysts may trade the same market for themselves with written approval from their manager and the President Director.

Why this matters

You are not told when someone at EsaFX has an interest on the other side of your business. Nothing EsaFX publishes says who takes the other side of your trade.

Exhibit 7WarningStandard wordingNew

Setiap pengungkapan benturan kepentingan akan dicatat dalam register benturan kepentingan Perusahaan dan dijaga kerahasiaannya.
Clause Pasal 11 ayat 3 in KODE ETIK (CODE OF CONDUCT) PT ESANDAR ARTHAMAS BERJANGKA
Read from the broker's site on Archived copyOpen the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must tell a retail client about a conflict they cannot manage, and must hand over their conflicts policy on request. EsaFX's code keeps the register confidential and names no disclosure to clients.

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

Three pages of EsaFX describe its licences three different ways

EsaFX's footer says BAPPEBTI, Bank Indonesia and OJK supervise it for derivatives whose underlying assets are securities. Its code of conduct says Bank Indonesia licensed it as a money market and foreign exchange derivatives broker under PADG 26 of 2025. Its about page describes a commodity futures broker under the 1997 Act.

Who you contract with1 clause flagged

EsaFX's footer says BAPPEBTI, Bank Indonesia and OJK supervise it for derivatives whose underlying assets are securities. Its code of conduct says Bank Indonesia licensed it as a money market and foreign exchange derivatives broker. Its about page describes a commodity futures broker.

Why this matters

Which regulator stands behind your account depends on which licence your product sits under, and EsaFX describes that three ways. Its complaint page routes you to BAPPEBTI whichever product you hold.

Exhibit 8Notice

PT Esandar Arthamas Berjangka is licensed and supervised by BAPPEBTI, BI, and OJK for financial derivative products with underlying assets in the form of Securities, and is a member of the BBJ exchange and a member of the KBI futures clearing house.
Clause site footer in Privacy Policy
Read from the broker's site on Archived copyOpen the reference
Our own capture of esafx.co.id, taken on Oct 2, 2026The claim, on site footer, which appears on every pageVisit this page on the broker's siteDownload the full size image file
Our own capture of esafx.co.id, taken on Oct 2, 2026What the contract says, clause Pasal 1Visit this page on the broker's siteDownload the full size image file

Where it sits: section 18 of 34 in the Privacy Policy, 53% 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 Indonesian policy states a retention rule and a right to ask for corrections, and the English version of the same section states neither.

Said in public, in Indonesian

Kami akan menyimpan informasi pribadi Anda untuk periode yang diperlukan berdasarkan peraturan perundangan untuk memenuhi berbagai tujuan yang berbeda dan diatur dalam Kebijakan Privasi ini dan disesuaikan kembali untuk waktu lebih lama jika diizinkan atau diharuskan oleh hukum khususnya dalam bidang Perdagangan Berjangka Komoditi.

Word for word in English: We will keep your personal information for the period required under the regulations to meet the various different purposes set out in this Privacy Policy, and adjusted again for a longer time if permitted or required by law, particularly in the field of Commodity Futures Trading.

Indonesian version of the privacy policy, section Penyimpanan dan Pemusnahan Informasi Pribadi

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

In the contract · clause Retention and Disposal of Personal Information

In managing personal information, EsaFX is subject to the provisions of applicable laws and regulations in Indonesia, including but not limited to Law Number 32 of 1997 as amended by Law Number 10 of 2011 concerning Commodity Futures Trading

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

02

The footer attributes the Bank Indonesia licence to derivatives on securities, and the code of conduct states it covers money market and foreign exchange underlyings.

Said in public, in English

PT Esandar Arthamas Berjangka is licensed and supervised by BAPPEBTI, BI, and OJK for financial derivative products with underlying assets in the form of Securities, and is a member of the BBJ exchange and a member of the KBI futures clearing house.

site footer, which appears on every page

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

In the contract · clause Pasal 1

PT Esandar Arthamas Berjangka yang selanjutnya disebut "Perusahaan" adalah badan hukum yang memperoleh izin dari Bank Indonesia sebagai Pialang Derivatif PUVA berdasarkan PADG No. 26 Tahun 2025.

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

03

EsaFX requires agreement to registration documents it does not publish, and the one legal document it does publish calls itself part of that unpublished agreement.

Said in public, in English

Prospective customers are required to read, understand, and agree to all Online Registration Documents and other terms and conditions.

Open Account page, step 1 of 5

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

In the contract · clause opening paragraph

This Privacy Policy is an integral part that cannot be separated from other customer agreement documents.

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

What changed quietly

First reading of EsaFX, so there is nothing to compare it against yet.

  • ADDEDClause Pasal 11

    EsaFX added a 36 article code of conduct after April 2026, and it is the first document in the set to deal with conflicts of interest.

    Setiap pengungkapan benturan kepentingan akan dicatat dalam register benturan kepentingan Perusahaan dan dijaga kerahasiaannya.

The documents this reading is based on

5 files, all published by esaFX. 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 esaFX publishes.

How this reading was done

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

This reading was published on .

Documents
5 of 5downloaded from the broker's site, and 5 read in full
Pages opened
23pages walked to find those documents, footer links included
Older copies
1earlier versions downloaded
Marketing pages
4public pages set against what the contract says
Languages
EN vs IDthe language it advertises in, against the language it contracts in
Position measured
4clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

PT Esandar Arthamas Berjangka

You contract with PT Esandar Arthamas Berjangka, a Jakarta company trading as EsaFX, and no second or offshore entity appears anywhere in its documents. Its code of conduct states that Bank Indonesia licensed it as a PUVA derivatives broker under PADG No. 26 of 2025, which covers money market and foreign exchange underlyings. Its about page describes a commodity futures broker under the 1997 Commodity Futures Trading Act, a member of the Jakarta Futures Exchange and of Kliring Berjangka Indonesia, supervised by BAPPEBTI. The footer on every page attributes BAPPEBTI, Bank Indonesia and OJK supervision to derivatives with securities underlyings. The documents do not settle which description governs a retail account.

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

EsaFX names the three bank accounts that receive client money, with the branch and address of each, and labels them separate accounts, so you can check where your money is going before you send it. It lists its nine licensed brokerage agents with their BAPPEBTI decree numbers and dates. The complaint route ends at a government portal rather than an internal panel, and nothing in it puts a deadline on you for raising a complaint. Its code of conduct bars staff from accepting a client's user id and password.

EsaFX publishes three legal documents: the privacy policy, the complaint procedure and the code of conduct. We read all three in full, and the privacy policy in both its English and its Indonesian version. We found no client agreement, no terms of business, no risk disclosure and no fee schedule, either on the site today or anywhere in its published history. The fee, withdrawal and account closure wording we quote comes from the deposits page and the account FAQ, which are the only places EsaFX addresses those subjects. The registration documents a client signs sit behind the account signup, so we did not read them. One earlier copy exists, of the complaint page as it stood in April 2026, and there is no earlier copy of the privacy policy to set beside today's.

How to check any of this yourself

Every quote above links to the esaFX 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 esaFX 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 esaFX 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 2, 2026.

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

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