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Contract reading

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

Every clause below is published by Exclusive 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: Exclusive Markets Ltd

sole discretionhidden feedeemed acceptancedormancyprofit voidingwithdrawalsabusive tradingcomplaint windowconflictforum waiver

Exclusive Markets can cancel your profit even after you have already withdrawn it. Closing a trade inside five minutes is scalping under its own definition, and scalping is abusive trading. Withdrawals get five business days, but the contract lets the firm take longer with no outer limit. The website bars ten countries, the contract bars eleven, and the two lists do not match.

Contract risk

Money at risk
7.6/10

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.
6
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
22
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
22
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
3

How the 22 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.

Critical6
Warning13
Notice3

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

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

What the documents say

22 clauses worth knowing about, worst first, each quoted from Exclusive Markets's own files

01

If Exclusive Markets decides your trading was abusive, it can strip out your gains. Clause 17.4(h) reaches profit that is already in your bank account, not just profit still sitting on the platform. Clause 17.4(c) lets it go back over the whole time you have been a client.

Why this matters

Money you withdrew months ago is not settled. The firm decides on its own whether your trading was abusive, and the contract sets no test it must meet and gives you no appeal.

Exhibit 1CriticalHarder than usual

nullify, reverse, cancel, adjust, or remove any profits, credits (including bonus from applicable promotions), trading results, rebates, or gains generated directly or indirectly through such activity, regardless of whether such profits have been realized, floating, partially withdrawn, or fully closed.
Clause 17.4(h) in Client Agreement, p.34
Downloaded from the broker's site on Open the reference
Our own capture of payload-exclusivemarkets-content-prod-exclusivemarkets.s3.eu-west-2.amazonaws.com, taken on Sep 15, 2026Profit can be cancelled after you have withdrawn it (clause 17.4(h))Visit 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 treat a retail client fairly and cannot simply reverse a completed payment on their own judgement. This contract lets Exclusive Markets remove profit it has already paid you.

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

  • Worse together with Exhibit 2The contract defines scalping as closing inside five minutes and calls scalping abusive, so ordinary short-term trading can trigger this clause.
  • Worse together with Exhibit 8The same abuse finding also lets the firm switch off negative balance protection and take money from your other accounts.
02

You get paid within five business days only if seven conditions in clause 21.7 are all met. If any one of them is not, clause 21.8.3 replaces the deadline with a reasonable time that is allowed to run longer, and the contract never says how much longer.

Why this matters

One of the seven conditions is that there is no abusive trading, and Exclusive Markets decides that itself. Your withdrawal can sit open while it looks, with no date by which it must finish.

Exhibit 3CriticalHarder than usual5 working days

Upon the Company receiving an instruction from the Client to withdraw funds from the Trading Account, the Company shall pay the said amount within five (5) Business Days, if the following requirements are met:
Clause 21.7 in Client Agreement, p.37
Downloaded from the broker's site on Open the reference
Our own capture of assets.exclusivemarkets.com, taken on Sep 15, 2026What the contract says, clause 21.7Visit this page on the broker's siteDownload the full size image file
Our own capture of payload-exclusivemarkets-content-prod-exclusivemarkets.s3.eu-west-2.amazonaws.com, taken on Sep 15, 2026Withdrawal clock can be extended with no outer limit (clause 21.7)Visit this page on the broker's siteDownload the full size image file

What it costsA withdrawal made on the first of the month should arrive by the eighth working day at the latest. If clause 21.8 is triggered, the contract stops promising any date at all.

Set against a regulated standard: FCA (UK), ASIC (Australia)

Firms licensed by the FCA or ASIC are expected to return retail client money promptly and to hold it separately so it can be paid back. This contract sets a five business day target and then lets the firm exceed it without naming a limit.

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

  • Only applies after Exhibit 1An abusive trading suspicion both blocks the withdrawal and lets the firm remove the profit you were trying to withdraw.
03

The footer on every page names ten countries Exclusive Markets will not serve. Clause 3.1(c) of the contract names eleven, and they are not the same eleven. Four countries are barred by the contract and missing from the website: Australia, Iraq, Japan and Turkey.

Why this matters

If you live in one of those four, the website tells you that you are welcome and the contract says the firm does not accept you. That gap is an argument the firm can use about your account later.

Exhibit 4CriticalHarder than usual4

who is a citizen or resident of certain jurisdictions such the United States of America, Australia, Canada, Cuba, Iran, Iraq, Japan, North Korea, Sudan, Syria, Turkey as the Company does not accept Clients from these countries; or
Clause 3.1(c) in Client Agreement, p.9
Downloaded from the broker's site on Open the reference
Our own capture of assets.exclusivemarkets.com, taken on Sep 15, 2026What the contract says, clause 3.1(c)Visit this page on the broker's siteDownload the full size image file
Our own capture of payload-exclusivemarkets-content-prod-exclusivemarkets.s3.eu-west-2.amazonaws.com, taken on Sep 15, 2026Website and contract bar different countries (clause 3.1(c))Visit this page on the broker's siteDownload the full size image file
04

An Islamic account is sold as free of interest charges. If Exclusive Markets later decides you misused it, clause 5.2(b) lets it recover every swap and interest cost for the whole period the account was swap-free. Clause 4.1 also allows a daily holding charge once an undisclosed free period runs out.

Why this matters

You chose this account so you would never pay interest. The contract lets the firm bill you for all of it afterwards, and the amount of the daily charge is not written in the document.

Exhibit 6CriticalRarely seen

correct and recover any unpaid Swaps and any associated unpaid interest expenses and/or costs pertaining to any and all of such Client's Swap-Free Accounts during the period for which such Trading Accounts were Swap-Free Accounts
Clause 5.2(b) in Islamic Swap-Free Accounts Terms and Conditions, p.4
Downloaded from the broker's site on Open the reference
Our own capture of payload-exclusivemarkets-content-prod-exclusivemarkets.s3.eu-west-2.amazonaws.com, taken on Sep 15, 2026Swap-free accounts can be charged the swaps later (clause 5.2(b))Visit 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 cost of a product before they use it. The daily charge here is not in the terms at all, only a pointer to a web page.

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

Our readingCharging back avoided swaps is what makes this unusual. A swap-free account is taken for religious reasons, and this clause lets the firm convert it into an interest bearing account after the fact, for time that has already passed.

05

When you copy someone on Exclusive Markets and the firm decides that person traded abusively, clause 6.1(h) lets it close, cancel or reverse the matching positions in your account. You did nothing except press follow.

Why this matters

Your gains depend on conduct you cannot see and cannot control. The firm also says it does not check how a strategy provider performs, so you carry a risk nobody is watching.

Exhibit 7CriticalRarely seen

This includes, without limitation, the right to modify, close, cancel, or reverse any corresponding copied positions in the Follower’s account, or otherwise adjust the Follower’s copied trades to reflect actions taken against the Provider.
Clause Schedule A 6.1(h) in Client Agreement, p.65
Downloaded from the broker's site on Open the reference
Our own capture of payload-exclusivemarkets-content-prod-exclusivemarkets.s3.eu-west-2.amazonaws.com, taken on Sep 15, 2026Copy trading profit reversed for what the trader did (clause Schedule A 6.1(h))Visit this page on the broker's siteDownload the full size image file

Our readingReversing one person's trades because of another person's conduct is unusual in a retail agreement. It moves the consequence of a rule breach onto someone who did not breach the rule and had no way to know.

  • Only applies after Exhibit 1It is the same abusive trading test from clause 17, applied to a person who is not you.
06

Put money in, change your mind, take it out without placing a trade, and Exclusive Markets can charge you $15 under clause 21.13. Bank and processing charges come off on top, and the clause leaves the decision to the firm.

Why this matters

Deciding a broker is not for you before you risk anything is the safest thing you can do. This clause puts a price on it, and the deposit page does not mention it.

Exhibit 5WarningHarder than usual$15

the Company shall have the sole discretion and be entitled to charge a fixed administrative and processing fee of USD 15 (fifteen United States dollars) or equivalent as per the currency of the account (the “No Trading Activity Fee”)
Clause 21.13 in Client Agreement, p.38
Downloaded from the broker's site on Open the reference
Our own capture of payload-exclusivemarkets-content-prod-exclusivemarkets.s3.eu-west-2.amazonaws.com, taken on Sep 15, 2026A $15 fee for depositing and not trading (clause 21.13)Visit this page on the broker's siteDownload the full size image file

What it costsDeposit $200, place no trade, ask for it back, and $185 returns before any bank charge. The $15 is gone without a single position opened.

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

Firms licensed by the FCA or CySEC must disclose costs and charges to a retail client before they trade. This charge sits on page 38 of a 66 page contract and not on the funding page a depositor is sent to.

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

The loss cap and the rulebook can both be changed by Exclusive Markets

Clause 7.4.1 promises you cannot lose more than your account holds, and clause 7.4.4.2 lets the firm remove that protection. Any other term can change on five business days notice, with silence counted as agreement. The contract also defines scalping as closing a trade inside five minutes, and calls scalping abusive.

Discretion3 clauses flagged

Clause 7.4.1 promises you cannot lose more than the money in your account. Clause 7.4.4.2 then lets Exclusive Markets remove that protection, in whole or in part, if it decides you misused it. Clause 7.4.5.1 lets it do so without notice.

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

The one promise that caps your loss is the one the firm can withdraw. It can also take money from your other accounts and wallets to cover what it says you owe.

Exhibit 8CriticalRarely seen

For the benefit of the Company’s Clients, the Company has implemented a “negative balance protection” (NBP) mechanism, on an account basis, whereby the Client cannot lose more than the funds available in that Trading Account.
Clause 7.4.1 in Client Agreement, p.23
Downloaded from the broker's site on Open the reference
Our own capture of assets.exclusivemarkets.com, taken on Sep 15, 2026What the contract says, clause 7.4.1Visit this page on the broker's siteDownload the full size image file
Our own capture of payload-exclusivemarkets-content-prod-exclusivemarkets.s3.eu-west-2.amazonaws.com, taken on Sep 15, 2026Negative balance protection can be switched off (clause 7.4.1)Visit this page on the broker's siteDownload the full size image file
Set against a regulated standard: ESMA (EU), FCA (UK), CySEC (Cyprus)

Firms under ESMA rules, and those licensed by the FCA or CySEC, must give retail clients negative balance protection that cannot be removed. This contract grants it and reserves the right to take it away.

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

Our readingNegative balance protection is normally a floor that does not move. Here it is conditional on the firm's own view of your trading, which turns a guarantee into a permission.

  • Worse together with Exhibit 1One abusive trading finding can remove your profit and your loss cap in the same decision.

The contract gives scalping its own meaning: opening several CFD positions at once and closing them in under five minutes. Scalping then appears in the definition of abusive trading, which is the door to every penalty in clause 17.

Why this matters

Ordinary short-term trading can put you inside the definition. You would not know it, because the meaning sits in the glossary on page 7, not in the rules about your account.

Exhibit 2WarningHarder than usual5

“Scalping” shall mean the situation where the Client opens too many positions in CFDs at the same time and closes them for less than five minutes or buying at Bid price and selling at Ask price, so as to gain the Bid/Ask difference.
Clause 2.1.1(vv) in Client Agreement, p.7
Downloaded from the broker's site on Open the reference
  • Only applies after Exhibit 1The definition on its own costs nothing until clause 17.4 uses it to remove profit.

Exclusive Markets can change any term of your agreement on five business days notice, and three if you are a company. Clause 26.6 treats you as accepting it unless you close your account first.

Why this matters

Notice can be given by a post on the website, so you have to go looking. Your only answer to a change you dislike is to leave.

Exhibit 19WarningHarder than usual5 working days

For any change made under Paragraphs 26.2 and 26.3 herein, the Company shall provide the Client with advance notice of at least 5 (five) Business Days where the Client is natural person and three Business Days where the Client is a legal person.
Clause 26.4 in Client Agreement, p.41
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC normally give a retail client around 30 days to consider a change to their terms. This contract gives five business days.

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

Three charges that are in the contract and not on the fees page

Exclusive Markets can take $15 if you deposit, never trade and withdraw, under clause 21.13. It can take up to $15 more to handle a closed account, but only where your balance is small enough to absorb it. Holders of Islamic swap-free accounts can be billed for every swap they were told they would not pay.

Cost disclosure1 clause flagged

After your agreement ends, Exclusive Markets can charge up to $15 for handling what is left. Clause 27.3.3 says the fee is not imposed where the balance is more than the fee, so as written it applies only when your balance is small enough to be swallowed.

Why this matters

A leftover $12 can be taken in full. The larger the balance, the less likely the charge, which is the opposite of how a handling cost normally works.

Exhibit 10WarningRarely seen$15

The Termination Handling Fee shall be a one-off fee of up to Fifteen US Dollars (USD $15.00) or the equivalent sum (depending on the Currency of that Client account).
Clause 27.3.1 in Client Agreement, p.42
Downloaded from the broker's site on Open the reference

What it costsA wallet left with $12 after termination can be charged the fee and emptied. A wallet holding $500 is not charged at all.

Our readingMost closing fees apply to everyone or to nobody. Writing the test so that only balances at or below the fee are charged means the clause can only ever empty an account, never reduce a large one.

Profit you have already banked is not final

Clause 17.4(h) lets Exclusive Markets remove gains whether they are floating, closed or already partly withdrawn. Clause 17.4(c) reaches back over your whole time as a client. If you copy another trader, clause 6.1(h) of Schedule A lets the firm reverse your positions because of what that person did.

Profit reversal1 clause flagged

Clause 8.6 calls the prices on the platform non-binding and for information only. Clause 8.12 says you cannot rely on any displayed price as a guarantee of what you will get.

In plain words

Liquidity providers are outside banks and brokers.

Why this matters

A gap between the price you clicked and the price you got is not something you can complain about. The contract has already recorded your agreement that the screen means nothing.

Exhibit 13WarningHarder than usual

The Client acknowledges and agrees that prices displayed on the Trading Platform, including any streaming, indicative or delayed quotes, are generated through electronic pricing feeds sourced from liquidity providers and/or internal pricing engines and are provided on a non-binding basis for informational purposes only.
Clause 8.6 in Client Agreement, p.26
Downloaded from the broker's site on Open the reference

Ninety business days to answer you, and a cap on what you can recover

The Exclusive Markets complaints procedure allows up to 90 business days for a final answer, then calls that same period three months. Clause 32.2 caps everything you can recover at your deposits minus your withdrawals, so lost profit falls outside it. Introducers get 15 calendar days to dispute a payment before the right is treated as waived.

Complaint limits3 clauses flagged

Exclusive Markets aims to answer a complaint in 21 business days. The outside limit is 90 business days, which is about four and a half months, and the same document then calls that period three months.

Why this matters

You cannot go to the regulator until the firm has finished or the time is up. The two different deadlines in one document make it harder for you to say when that moment arrived.

Exhibit 14WarningHarder than usual90 working days

In any event, the Company shall provide the Client with the outcome of its investigation no later than ninety (90) business days from the date of receipt of the complaint.
Clause E in Complaints Procedure for Clients
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must give a retail client a final answer to a complaint within eight weeks, after which the client can take it to an independent scheme. This procedure allows 90 business days.

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

Whatever Exclusive Markets does, clause 32.2 caps everything you can recover at your deposits minus your withdrawals. Profit the firm should have paid you sits outside that cap.

Why this matters

If a mistake costs you a gain rather than your capital, the cap can leave you with nothing to claim. Clause 30.5 sets an even lower cap, at the fees you have paid.

Exhibit 15WarningHarder than usual

our aggregate liability to you in respect of all claims arising out of or in connection with the Client Agreement will be limited to the aggregate amount of the deposits less withdrawals on your Trading Account.
Clause 32.2 in Client Agreement, p.48
Downloaded from the broker's site on Open the reference

If you introduce clients to Exclusive Markets and disagree with a commission payment, you have 15 calendar days from the payment date to object in writing. Miss it and clause 10.7 treats your right to challenge as given up.

Why this matters

The clock starts when the firm pays, not when you notice the shortfall. Accepting the money at all is treated as full and final settlement for that month.

Exhibit 16WarningHarder than usual15 days

In case the Introducer disagrees with any amount payable, the Introducer must NOT accept payment for the said amount and must immediately send a written notice of dispute to the Company but not later than 15 (in words: fifteen) calendar days starting from the date that payment is made by the Company, otherwise the right to challenge the Commission and or the payment shall be deemed to have been waived by the Introducer.
Clause 10.7 in Introducing Broker Agreement, p.12
Read from the broker's site on Open the reference

Every dispute goes to Seychelles, and only Seychelles

Clause 42.1 of the Exclusive Markets client agreement sends disputes to the exclusive jurisdiction of the Seychelles courts. The website terms go further and record that you waive all and any rights to bring an action in any court anywhere else in the world.

Where you can sue1 clause flagged

The website terms do more than choose Seychelles law. They record that you give up all and any rights to bring an action about the website in any court anywhere else in the world.

Why this matters

Suing in Seychelles means travel, local lawyers and local costs, wherever you live. A clause in a contract you clicked through decides that for you.

Exhibit 18WarningHarder than usual

These terms shall be governed by and construed in accordance with the Republic of Seychelles and the User explicitly accepts that only the Courts of Seychelles have jurisdiction to deal with any matter arising from or in any way, whether directly or indirectly, related the use of this website and, accordingly, the user explicitly waives all and any rights to bring any action of any sort in relation to this web site in any court anywhere else in the world.
Clause 12.a in Terms and Conditions of Website Use
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC cannot remove a retail consumer's right to bring a claim in their home courts. This clause asks you to waive that right worldwide.

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

The document check arrives when you ask for your money

Clause 21.7.7 makes full verification a condition of being paid rather than a condition of opening an account. Exclusive Markets can ask for source of funds papers at any time, and its AML policy lets it block an account at its own discretion. Until the check clears, the five business day withdrawal deadline does not apply.

Verification timing1 clause flagged

Clause 21.7.7 makes full verification a condition of being paid, so the check lands at the moment you ask for your money rather than when you deposit it. The AML policy lets Exclusive Markets block an account at any time.

Why this matters

You can deposit and trade for months and only meet the document demand when you want to withdraw. Until you satisfy it, the five business day clock does not apply to you.

Exhibit 20WarningHarder than usual

the Client and must be fully verified according to Verification guidelines set forth on the Website.
Clause 21.7.7 in Client Agreement, p.37
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC are expected to identify a client before the business relationship starts, not at the point of payout. This contract makes verification a withdrawal condition.

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

  • Worse together with Exhibit 3An unfinished verification is one of the seven conditions that removes the five business day deadline.

Exclusive Markets earns a percentage of everything you trade

Clause 44 discloses that a liquidity provider pays Exclusive Markets a monthly commission based on your trading volume, on page 53 of a 66 page contract. The firm's own conflicts policy says this works against your interest in low costs. The same documents disagree about whether the firm ever takes the other side of your trade.

Who gets paid2 clauses flagged

A liquidity provider pays Exclusive Markets a monthly commission worked out as a percentage of the volume you trade. That sits in clause 44, on page 53 of a 66 page contract, and the firm's own conflicts policy admits the problem.

Why this matters

The more you trade, the more the firm earns, whether you win or lose. Its own policy says this works against your interest in keeping costs down.

Exhibit 11WarningStandard wording

The Client is hereby informed that the Company receives monthly commissions from the Liquidity Provider calculated as a percentage of the volume of Orders sent for execution every month.
Clause 44 in Client Agreement, p.53
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must tell a retail client about payments received from third parties in connection with their business, before the service begins. Exclusive Markets discloses this, in clause 44, near the end of the agreement.

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

  • Same clause as Exhibit 12The same clause 44 that discloses the payment also states the firm never trades against you, which its conflicts policy does not match.

The client agreement and the execution policy both say Exclusive Markets never takes the other side of your trade. The conflicts policy lists acting as principal among its conflicts, and says the firm may match your order against another client's.

Why this matters

You cannot tell from these documents whether the firm profits when you lose. The conflicts policy is dated 2023 and may simply be older than the rest.

Exhibit 12NoticeStandard wording

It is understood that the Company arranges for the execution of Client Orders with another entity (the Liquidity Provider) and does not execute them itself as a principal to principal against the Client.
Clause 44 in Client Agreement, p.53
Downloaded from the broker's site on Open the reference

Not trading costs $10 a month, and $5 a week for introducers

Three months without a deposit, withdrawal or trade makes an Exclusive Markets account dormant, and clause 25.2 allows $10 every month after that. Three more months and the firm can close it. Introducers lose $5 a week, or their whole commission balance where it holds less than $5.

In plain words

Dormancy means an account left unused.

Dormancy2 clauses flagged

Three months with no deposit, no withdrawal and no trade makes your account dormant under clause 25.1. Clause 25.2 then allows $10 a month. Three more months and the firm can close the account entirely.

Why this matters

Taking a break is enough to start the charge. Nothing in the clause requires Exclusive Markets to warn you first, and nothing stops the fee eating a small balance.

Exhibit 9WarningHarder than usual$10

The Client acknowledges and confirms that any Account(s) opened with the Company where there is no deposits, withdrawals or trading activity for a period of 3 (three) months, shall be classified by the Company as a Dormant Account
Clause 25.1 in Client Agreement, p.40
Downloaded from the broker's site on Open the reference

What it costsA dormant account charged $10 a month loses $120 over a year. A balance of $60 is gone in six months.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Month 3The account is classified as dormant after no deposit, withdrawal or trade.25.1
DormantA monthly fee of $10 may be charged on the account.25.2
Month 6An account holding no funds can be reclassified as inactive.25.3
InactiveExclusive Markets can close the account at its sole discretion.25.4

An introducer portal with no new clients for three months goes dormant. Clause 9.8 then charges $5 a week, or your entire commission balance if it holds less than $5.

Why this matters

Commission you have already earned can be taken a week at a time until nothing is left. The clause has you give up any claim to the money deducted.

Exhibit 17WarningHarder than usual$5

Dormant Portal will be charged with a weekly dormant fee of 5 (five) USD or the full amount of the generated Commissions if the available commissions are less than 5 (five) USD.
Clause 9.8 in Introducing Broker Agreement, p.10
Read from the broker's site on Open the reference

What it costsA portal holding $60 in earned commission is emptied in twelve weeks at $5 a week. A portal holding $3 loses all of it at the first charge.

Exclusive Markets punishes bonus misuse it never defines

Six parts of clause 17.3 set out what counts as abuse of a bonus promotion, including converting promotional credit into withdrawable money. No bonus terms document appears anywhere in the Exclusive Markets legal shelf. The penalties are published in full and the rules they enforce are not.

Missing document1 clause flagged

Six parts of clause 17.3 govern how you may behave with a bonus, including what happens if you turn promotional credit into money you can withdraw. Exclusive Markets publishes no bonus terms document setting out the rules those clauses enforce.

Why this matters

You can break a bonus rule you were never shown. The penalties are written down in full while the conditions they punish are not.

Exhibit 21NoticeHarder than usual

any trading activity which, in the Company’s reasonable opinion, demonstrates behaviour inconsistent with the intended commercial purpose of any applicable Bonus promotions, including but not limited to attempts to convert promotional credit into withdrawable funds through low-risk, non-commercial, abusive, manipulative, or coordinated strategies.
Clause 17.3.13 in Client Agreement, p.33
Downloaded from the broker's site on Open the reference

A Seychelles counterparty with payments running through Cyprus

You contract with Exclusive Markets Ltd, registration 8423950-1, under Seychelles FSA authorisation SD-031. Clause 21.16 routes several payment methods through Exclusive Markets (Cyprus) Ltd, a different company that is not your counterparty. No document names any investor compensation scheme.

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.

Who holds your money1 clause flagged

You contract with Exclusive Markets Ltd in Seychelles under FSA authorisation SD-031. Clause 21.16 says several payment methods are handled by Exclusive Markets (Cyprus) Ltd, a separate company that is not your counterparty.

Why this matters

No document names any investor compensation scheme. If the firm fails, clause 22.5 leaves you with an unsecured claim and nothing to fall back on.

Exhibit 22NoticeStandard wording

The Company is authorized and regulated by the Seychelles Financial Services Authority (hereafter the “FSA”) with authorization number SD-031.
Clause 1.2 in Client Agreement, p.2
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC belong to a statutory compensation scheme that pays retail clients if the firm fails. These documents name no equivalent for Exclusive Markets Ltd.

Exclusive Markets 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 website tells residents of Australia, Iraq, Japan and Turkey they are not restricted, while the contract says Exclusive Markets does not accept them.

Said in public, in English

Exclusive Markets does not provide services to residents of the following countries: Belarus, Canada, Cuba, Islamic Republic of Iran, Myanmar, North Korea, Russia, South Sudan, Syria, and The United States.

Restricted countries notice in the footer of every page, read on the About page

In the contract · clause 3.1(c)

who is a citizen or resident of certain jurisdictions such the United States of America, Australia, Canada, Cuba, Iran, Iraq, Japan, North Korea, Sudan, Syria, Turkey as the Company does not accept Clients from these countries; or

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

02

The funding page calls withdrawals instant while the contract allows five business days and lets that be exceeded.

Said in public, in English

Select from a variety of secure, instant, and easy deposit/withdrawal options available for a stress-free trading experience.

Opening line of the Funding Methods page

In the contract · clause 21.7

Upon the Company receiving an instruction from the Client to withdraw funds from the Trading Account, the Company shall pay the said amount within five (5) Business Days, if the following requirements are met:

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

03

The site warns that losses can pass your deposit while the contract promises they cannot, and elsewhere lets the firm withdraw that promise.

Said in public, in English

CFDs are complex financial instruments requiring knowledge and understanding. Their value may fluctuate significantly. Losses may exceed profits and, in some circumstances, deposits.

Risk warning in the footer of every page

In the contract · clause 7.4.1

For the benefit of the Company’s Clients, the Company has implemented a “negative balance protection” (NBP) mechanism, on an account basis, whereby the Client cannot lose more than the funds available in that Trading Account.

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

What changed quietly

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

  • REWRITTENClause · 2026-04-21 to 2026-09-15

    The footer warning dropped the plain statement that you can lose money rapidly and replaced it with softer wording about value moving.

    CFDs are complex financial instruments requiring knowledge and understanding. Their value may fluctuate significantly. Losses may exceed profits and, in some circumstances, deposits.

The documents this reading is based on

22 files, all published by Exclusive 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 Exclusive Markets publishes.

How this reading was done

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

This reading was published on .

Documents
4 of 22downloaded from the broker's site, and 4 read in full
Pages opened
44pages walked to find those documents, footer links included
Older copies
1earlier versions downloaded
Marketing pages
9public pages set against what the contract says

Who the contract is with

Exclusive Markets Ltd

You contract with Exclusive Markets Ltd, a Seychelles company, registration number 8423950-1, at Suite 18, Third Floor, Vairam Building, Providence, Mahé. Clause 1.2 names the Seychelles Financial Services Authority as its regulator under authorisation number SD-031. A second company appears when you pay. Clause 21.16 says several payment methods are processed and executed by Exclusive Markets (Cyprus) Ltd, registration number HE 421534, described as an Appointed Independent Representative and Distributor. That Cyprus company is not the party you contract with, and the documents do not say it holds a European licence. Your money moves through Cyprus while your rights sit in Seychelles.

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

Exclusive Markets publishes a full set of legal documents, free and without a login: the client agreement, complaints procedure, conflicts policy, order execution policy, AML policy, privacy notice, swap-free terms, the PAMM and introducer agreements. Many offshore brokers publish less. Clause 7.4.1 grants negative balance protection in plain words. Clause 22.3 sets out client money segregation duty by duty rather than in one vague line. Clause 45.1 gives a natural person 14 calendar days to walk away with a full refund if they have not traded, which is rare in a Seychelles contract. Clause 20.7 promises one month of written notice before any new CFD commission starts. The complaints procedure names the FSA, gives its postal address and telephone number, and states plainly that the right to go to court is unaffected.

We read most of the 66 page Client Agreement, but not all of it. The pages covering the platform licence, account credentials and real stock trading were not read, and every clause we quote comes from a page we did read. We read the complaints procedure, the cookies policy, the swap-free terms, the conflicts of interest policy and the introducer agreement end to end. We read only parts of the AML policy, the privacy notice, the website terms and the order execution policy, by searching them for the subjects in this report. We did not read the risk disclosure, the PAMM agreement, the complaint form, the information security policy, the business continuity policy or the ISO certificate at all. Searching inside these PDFs for a word like fee does not reliably work, because of the way the text sits inside the files, so a client trying to check a term for themselves will find it harder than it looks. Every marketing claim quoted here comes from a page we opened ourselves. Only one earlier copy of any document exists to compare against, an April 2026 copy of the glossary page, so the other documents have no earlier version to set beside them.

How to check any of this yourself

Every quote above links to the Exclusive 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 Exclusive 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 Exclusive 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 15, 2026.

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

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