Wikilix
Contract reading

What First Gold legally published, but does not want you to read

Every clause below is published by First Gold 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: First Asia Merchants Bullion Limited

sole discretionhidden feedeemed acceptanceliability exclusionlanguage gapmargin requirementprofit voidingaccount securityclient moneycost disclosure

First Asia Merchants Bullion Limited sells leveraged gold and silver contracts and takes the other side of your trades. You get 3 days to query a trade, after which the rules treat it as correct. The firm alone decides what an abnormal trade is, cancels it, and the contract bars you from questioning that. A quiet account holding under US$150 loses US$10 a month until it is cleared out.

Back to First Gold

Contract risk

Money at risk
7.5/10

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.
6
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
19
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
14
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
4

How the 19 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
Warning11
Notice2

section 220 of 225is where the deepest clause sits: the very end of the document it is in

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

3 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.

Critical$10Fee on an unused account. Jump to the clause this comes from.Dormant accounts pay US$10 a month until cleared outCritical3 daysTime to complain. Jump to the clause this comes from.Three days to dispute a trade, then it standsCritical30%Account limit. Jump to the clause this comes from.Positions closed at 30% margin, and you owe the rest$110Fee you were not shown. Jump to the clause this comes from.US$110 a lot, published only in an FAQ

What the documents say

19 clauses worth knowing about, worst first, each quoted from First Gold's own files

01

First Gold can cancel and reverse your trades whenever it treats them as what it calls Abnormal Transactions, a label its own opinion defines. Clause 7 says its decision is final and you cannot object, challenge or question it in any circumstances.

Why this matters

A winning run can be undone and your balance put back as though the trades never happened. The same clause says First Gold does not have to show you any proof, so there is nothing for you to argue against.

Exhibit 1CriticalRarely seen

“Abnormal Transactions” means the trading method, devices, means, pattern or manner adopted by the Client resulting in such transaction or series of transactions which, in the sole opinion and judgment of the Company without the need to first consult the opinion of the Client, affects or has affected the system stability and order, and/or market risk of the Company;
Clause 1 in Client Account Agreement 客戶帳戶協議, p.1
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 24 of 225 in the Client Account Agreement 客戶帳戶協議, near the start.

Our readingCancelling trades for market abuse is common in this industry. Defining the trigger by the firm's own opinion, calling the decision final, barring you from objecting in any circumstances and waiving any need for proof is not.

  • Worse together with Exhibit 3The firm's decision is final and you have three days to raise anything at all, so a reversal lands with no route to challenge it.
02

US$10 a month comes out of your account once it has gone six months without a real trade and holds less than US$150. When what is left falls under US$10, clause 25 says the account is cleared out and you cannot object.

Why this matters

A small balance you stopped watching is gone inside a year, and the fee does not stop until there is nothing to take. First Gold then closes the account and tells you after the decision is made.

Exhibit 2CriticalHarder than usual$10

If Client holds a trading account with the Company for over 6 months, and (i) there is no substantive transaction during that period, and (ii) the balance is less than US$150, the Company will charge the Client a monthly administration fee of US$10 by deducting directly from this account.
Clause 25 in Client Account Agreement 客戶帳戶協議, p.6
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 75 of 225 in the Client Account Agreement 客戶帳戶協議, 33% of the way through.

What it costsAn account with US$100 left and no trading pays US$10 a month. Ten of those deductions leave nothing.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Six months, no real trade, balance under US$150A US$10 monthly administration fee starts, taken straight out of the account.25
Balance under US$10First Gold clears out what is left and you cannot raise any objection.25
Balance at zeroFirst Gold cancels the account and ends the contract on the last trading day of that month.25
03

First Gold emails you a daily confirmation report, and you have 3 days from the date it is issued to report an error. After that the rules say every transaction counts as correct and no dispute will be accepted.

Why this matters

Miss the 3 days because you were away or the email went to spam, and a wrong price or a wrong size becomes yours for good. No complaints procedure and no outside scheme is named in any document.

Exhibit 3CriticalHarder than usual3 days

Clients should verify the transactions listed in the report and inform the Company within 3 days after the date the report is issued if any errors are found. Otherwise, all transactions will be considered as correct and no dispute will be accepted.
Clause Daily Confirmation in Trading Guidelines (Precious Metals): Daily Confirmation
Read from the broker's site on Open the reference
Our own capture of firstbullion.com, taken on Oct 5, 2026Three days to dispute a trade, then it stands (clause Daily Confirmation)Visit this page on the broker's siteDownload the full size image file

Buried at section 175 of 225 in the Trading Guidelines (Precious Metals): Daily Confirmation, 78% of the way through.

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

Firms licensed by the FCA or CySEC must give a retail client a written complaints procedure and access to an independent complaints scheme. This document gives you 3 days and names no scheme.

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

04

First Gold closes part or all of your positions, without further notice, once your equity falls to 30% of the margin you have used. Margin is the cash you must keep behind a position.

In plain words

Indemnities are money it says you owe it.

Why this matters

Clause 21 says First Gold owes you no duty to limit your loss when it closes you out, and you carry any shortfall, legal costs included. If the close out leaves the account below zero, you still owe the difference.

Exhibit 4CriticalHarder than usual30%

When there is an unsettled loss in a client’s account for open positions, resulting in the equity value equal or below 30% of the held margin value, the Company will close part or all of the client’s open positions without further notice (the position with highest loss is given the highest priority) until the equity value is greater than the stop loss margin value for the remaining positions.
Clause Settlement for Stop Loss 2 in Trading Guidelines (Precious Metals): Settlement for Stop Loss
Read from the broker's site on Open the reference
Our own capture of firstbullion.com, taken on Oct 5, 2026Positions closed at 30% margin, and you owe the rest (clause Settlement for Stop Loss 2)Visit this page on the broker's siteDownload the full size image file

Where it sits: section 63 of 225 in the Trading Guidelines (Precious Metals): Settlement for Stop Loss, 28% of the way through.

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

Firms licensed by the FCA, and firms following ESMA's retail rules, must close a retail client's leveraged position when margin reaches 50% of the amount required. Those clients also cannot be pursued for more than the money in the account. This contract closes at 30% and makes you liable for the shortfall.

First Gold 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
Equity below 50% of used marginAn alert message lands in your trading platform mailbox.Settlement for Stop Loss 1
Equity at or below 30% of used marginFirst Gold closes part or all of your positions without further notice, worst loss first.Settlement for Stop Loss 2
Account left shortYou pay the deficit, the losses and the costs, legal costs included.21(a)
  • Worse together with Exhibit 6The 30% level sits in a rulebook the firm can rewrite at any time, so the point at which you are closed out is not fixed by your contract.
05

One lot of spot gold, 100 ounces, costs you US$110 on First Gold's own figures: a 5 point spread plus a US$60 handling fee. That figure sits in one FAQ answer about opening an account.

Why this matters

Ten lots in a month cost you US$1,100 before the market moves either way. Clause 19 lets First Gold set the commission rate by notice, so nothing you signed fixes the US$110.

Exhibit 5WarningHarder than usual$110

If a Client opens an account directly with us, the spread is 5 and the administration fee is USD60, which is USD110 in total.
Clause Account Opening Q4 in FAQ: Account Opening
Read from the broker's site on Open the reference
Our own capture of firstbullion.com, taken on Oct 5, 2026The claim, on English FAQ, answer to a question about the administration fee for opening an accountVisit this page on the broker's siteDownload the full size image file
Our own capture of firstbullion.com, taken on Oct 5, 2026What the contract says, clause 開戶 Q4Visit this page on the broker's siteDownload the full size image file

Where it sits: section 57 of 225 in the FAQ: Account Opening, near the start.

What it costsTen lots of spot gold in a month cost US$1,100 in spread and handling fees, using the firm's own US$110 figure.

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

Firms licensed by the FCA or CySEC must tell a retail client the costs and charges of a trade before it is placed. This contract states no rate at all, and the only figure anywhere is in an FAQ answer.

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

  • Worse together with Exhibit 12The firm sets the spread itself and has you agree in advance that it is fair, so the one published cost figure can move without notice to you.
06

The 2020 agreement attached the margin table and trading rules to the contract you signed. The 2021 version took them out: you now confirm you understand the rules First Gold emails you, and it can add, delete or change them at any time with immediate effect.

Why this matters

The close out level, the margin you must post, the order size cap and the 3 day deadline to query a trade all live in that rulebook. First Gold can change any of them by posting a notice on its website, and you are bound as soon as it does.

Exhibit 6WarningHarder than usualNew

Client confirms that the margin requirements and trading rules that the Company email to the client are now well understood and agreed to trade conforming to the requirements and rules.
Clause Client's Information Statement in Client Account Agreement 客戶帳戶協議, p.12
Read from the broker's site on Archived copyOpen the reference

Buried at section 145 of 225 in the Client Account Agreement 客戶帳戶協議, 64% of the way through.

  • Worse together with Exhibit 3The 3 day deadline to query a trade is itself one of the rules the firm can rewrite, so the deadline can shorten without your agreement.

Closed out at 30% margin, on rules the firm can rewrite

First Gold closes your positions once your equity reaches 30% of the margin used, without further notice. Clause 21 says it owes you no duty to limit your loss, and clause 39 lets it liquidate everything when it decides its own protection needs it. The rulebook holding the 30% level left the contract in 2021 and can be changed at any time.

Exit conditions2 clauses flagged

The first trigger in clause 39 is First Gold deciding that its own protection needs it. It can then cancel your orders, close your positions, sell property it holds for you and set your accounts off against each other, with no further notice or demand.

Why this matters

Your open trades can be shut at the firm's chosen moment and price, and clause 41 has you give up any claim for the loss that follows. That waiver keeps out only wilful misconduct, negligence and reckless disregard by First Gold.

Exhibit 8CriticalHarder than usual

cancel all or any outstanding orders of the Client for Bullion and RMB Kilobar Gold, and/or close all or any positions in the Client’s Account whether or not the settlement has taken place;
Clause 39(c) in Client Account Agreement 客戶帳戶協議, p.8
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 110 of 225 in the Client Account Agreement 客戶帳戶協議, 49% of the way through.

First Gold's disclaimer says that by opening any page of the site you agree to the terms set out on it. Those terms include a line that the firm is not liable for any damages of any kind arising from using the site.

Why this matters

You accept a liability exclusion before you ever open an account or tick a box. This is common practice for websites in the region, so treat it as the floor rather than the surprise.

Exhibit 19NoticeStandard wording

By accessing this site and any of its pages you are agreeing the terms and conditions set out above.
Clause Important in Disclaimer
Read from the broker's site on Open the reference

Three days to challenge a trade, then your silence counts as agreement

First Gold gives you 3 days from the date of its daily confirmation report to report an error. After that the rules say all transactions will be considered correct and no dispute will be accepted. Clause 32 also makes every order placed with your password yours, including one entered by the firm's own staff.

Complaint window1 clause flagged

Clause 32 makes you solely responsible for every order entered with your account number and password, whether you authorised it or not. It covers orders typed in by First Gold's own officers, employees or agents, and the firm takes no liability for mishandling them.

Why this matters

If someone else trades your account, the loss is yours and the contract gives you nobody to claim from. You also promise to cover First Gold's own costs arising from those orders.

Exhibit 7CriticalRarely seen

The Client acknowledges and agrees that he shall be wholly and solely responsible for all instructions given or entered direct by telephone or through the On-Line Services, or by such other means as designated by and acceptable to the Company, using the Access Codes (whether authorized by him or not, and whether or not the instructions were given or entered by the Company or any of its officers or employees or agents at the Client’s express request).
Clause 32 in Client Account Agreement 客戶帳戶協議, p.6
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 89 of 225 in the Client Account Agreement 客戶帳戶協議, 40% of the way through.

Our readingClient agreements routinely make you responsible for orders placed with your own password. Extending that to orders the firm's own staff entered, while excluding the firm's liability for mishandling them, is unusual.

  • Worse together with Exhibit 16The firm emails you the trading password it created, then treats every order entered with it as yours.

Spot silver margin is 1% on the product page and 3% in the rules

First Gold's product page says a spot silver contract needs 1% margin per lot. Its trading guidelines page says 3% for the same 2,500 ounce contract, with close out at 30%. A position sized on the lower figure needs three times the cash the product page promised.

Mixed numbers1 clause flagged

First Gold's product page says a spot silver contract needs 1% margin per lot. Its trading guidelines page says 3% for the same contract, with close out at 30%.

Why this matters

A position you size on the lower figure needs three times the cash the product page promised. Both pages are live today, in English and in Chinese, and neither points to the other.

Exhibit 14WarningHarder than usual3%

Spot Silver(LLS) 2500 ounce USD/ounce 0.001 USD 1%
Clause Spot Precious Metal Contract table in Spot Precious Metal Contract
Read from the broker's site on Open the reference
Our own capture of firstbullion.com, taken on Oct 5, 2026The claim, on Spot Precious Metal Contract product page, initial margin per contractVisit this page on the broker's siteDownload the full size image file
Our own capture of firstbullion.com, taken on Oct 5, 2026What the contract says, clause Margin Requirements tableThis 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

US$110 a lot, published in an FAQ about opening an account

US$110 per lot is the only trading cost First Gold publishes: a 5 point spread plus a US$60 handling fee, in one FAQ answer. The contract itself sets no rate, leaving commission, interest and the spread to whatever the firm notifies from time to time. Settlement happens in Hong Kong dollars at a rate the firm determines conclusively.

Cost disclosure2 clauses flagged

Your gold is priced in US dollars, but clause 24 settles your account in Hong Kong dollars at an exchange rate First Gold decides. Clause 11 lets it convert your money into any currency at a rate it determines conclusively, without asking you.

Why this matters

A conversion at a rate only the firm sets is a cost you cannot check, and it applies every time money moves. Clause 11 also says First Gold is not liable for any loss you take on that conversion.

Exhibit 10WarningHarder than usual

The settlement currency is Hong Kong Dollar. The exchange rates between US Dollar and Hong Kong Dollar or, as the case may be, between RMB and Hong Kong Dollar shall be determined by the Company with reference to prevailing market rates.
Clause 24 in Client Account Agreement 客戶帳戶協議, p.5
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 39 of 225 in the Client Account Agreement 客戶帳戶協議, near the start.

Holding a position past the daily settlement costs you overnight interest, and First Gold sets the rate. Its own example charges US$64 a day for two lots of spot gold, and a position left open after Friday is charged three days of it.

Why this matters

US$64 a day is real money against a position you thought was just sitting there, and the firm says the amount can change with market and supply conditions. Clause 20 puts the rate entirely in First Gold's hands.

Exhibit 11WarningHarder than usual$64

The daily swap point for buying XAUUSD is -32: -32 × 1 USD × 2 = -64 USD ( interest payable by the client )
Clause Overnight Interest and Fee in Trading Guidelines (Precious Metals): Overnight Interest and Fee
Read from the broker's site on Open the reference

Buried at section 197 of 225 in the Trading Guidelines (Precious Metals): Overnight Interest and Fee, 88% of the way through.

What it costsTwo lots of spot gold held over a weekend are charged three days of interest, US$192 on the firm's own US$64 figure.

No clause anywhere sets a deadline for paying your money out

The First Gold agreement has no withdrawal section at all. It sets no deadline, no method and no fee for returning your money, and clause 45 says the agreement and its schedules are the whole of the deal. The only published timing is an FAQ line giving three business days to close an account.

Getting paid1 clause flagged

The agreement has no withdrawal section. Nothing in it says how you ask for your money, what a payout costs, or how long First Gold has to send it, and clause 45 says the agreement and its schedules are the whole deal between you.

Why this matters

With no deadline written down, a slow payout breaks no term you can point to. The only published timing is an FAQ line giving three business days to close an account.

Exhibit 9WarningRarely seen

Each party acknowledges that this Agreement together with any schedules and appendix attached hereto shall constitute and contains the whole agreement between the parties and that each party has not relied upon any oral or written representation made to it by the other or its employees or agents and has made its own independent investigations into all matters relevant to it.
Clause 45 in Client Account Agreement 客戶帳戶協議, p.9
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 130 of 225 in the Client Account Agreement 客戶帳戶協議, 58% of the way through.

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

Firms licensed by the FCA or CySEC must set out in the client agreement how a retail client withdraws money and what happens to client money on request. This agreement is silent on both.

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

Our readingClient agreements normally set out how a payout is requested, what it costs and how long it takes. This one has no withdrawal clause at all, and the only timing figure sits in an FAQ answer about closing an account.

The firm decides what an abnormal trade is, and that decision is final

Clause 7 lets First Gold cancel and reverse trades it treats as Abnormal Transactions, a term its own opinion defines. The same clause says you cannot object, challenge or question the decision in any circumstances, and that no proof has to be shown. Clause 33 adds a second reversal power whenever the firm suspects software affected its platform.

Trade reversal1 clause flagged

Clause 33 lets First Gold cancel and reverse your trades when it suspects software or a program affected its platform. The Chinese column of that clause ends by saying you may not object, and the English column, which clause 3 says wins, has no such line.

Why this matters

If you read the Chinese, you are told you cannot complain about a reversal. The governing English text never says that, so the version you read is not the version that counts.

Exhibit 13WarningHarder than usual

The Company has the right in its sole and absolute discretion to cancel and reverse the transactions when the Company suspects or has reasonable grounds to believe that, in the sole opinion of the Company, these transactions were entered by way of using software or program or even manual methods that affect the trading platform stability of the Company.
Clause 33 in Client Account Agreement 客戶帳戶協議, p.7
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 93 of 225 in the Client Account Agreement 客戶帳戶協議, 41% of the way through.

Your file can go to anyone the firm says its interests require

The privacy circular inside the First Gold agreement allows disclosure to any person where the firm's own interests require it. The privacy policy you accept in the same form promises the opposite: disclosure only with your consent or where the law demands it. The account opening FAQ also asks for both sides of your identity card and your bank card through an online chat representative.

Your data2 clauses flagged

The privacy circular built into the agreement lets First Gold pass your file to any person where its own interests require disclosure. The separate privacy policy you tick in the same form promises disclosure only with your consent or where the law demands it.

Why this matters

Two documents you accept in one sitting give opposite answers about who sees your identity card, your bank details and your trading record. The one inside the contract is the wider of the two.

Exhibit 15WarningHarder than usual

any person in the event that the Company’s interests require disclosure.
Clause Schedule 1, 5(viii) in Client Account Agreement 客戶帳戶協議, p.15
Read from the broker's site on Archived copyOpen the reference

Buried at section 220 of 225 in the Client Account Agreement 客戶帳戶協議, 98% of the way through.

First Gold's own FAQ asks you to send both sides of your identity card and a copy of your bank card in a zip file to an online service representative. After a phone check, it emails you the trading account number and password.

Why this matters

Your identity documents travel through a chat service and your trading password arrives in your inbox. Clause 32 then treats every order placed with that password as yours.

Exhibit 16WarningRarely seen

After that, the Client is required to note down the reference code for account opening and send the reference code, legible and intact images of both sides of his/her ID card and hard copy of the bank card in a zip or rar file to any of our online Client service representatives.
Clause Account Opening Q2 in FAQ: Account Opening
Read from the broker's site on Open the reference

Our readingMost firms collect identity documents through an upload inside the account portal. The route published here is a chat service, with the trading password then sent to your email address.

First Gold can take the other side of your trade and set the price

Clause 18 lets First Gold take the opposite position to your order, on its own account. Clause 13 lets it decide the spread at its sole discretion, and clause 14 has you accept in advance that its prices and spreads are fair and reasonable. The contract names no outside reference price.

Who you trade against1 clause flagged

Clause 18 lets First Gold take the opposite position to your order, on its own account. Clause 13 lets it decide the spread, the gap between its buy and sell price, at its sole discretion, and clause 14 has you accept in advance that its prices are fair.

Why this matters

Your loss can be the firm's gain on the same trade, and the contract names no outside price to measure its quotes against. You have already agreed that whatever it quotes is reasonable.

Exhibit 12WarningHarder than usual

The Client acknowledges and agrees that the Company, at its sole and absolute discretion, may take the opposite position to the Client’s Trading Order, whether on its own account or on behalf of other Clients, and/or the Company may take opposite position to the Client’s Trading Order to match the Client’s partial or entire Trading Order and/or may transfer the Client’s partial or entire Trading Order to another market on its own account or on the account of the Client.
Clause 18(b) in Client Account Agreement 客戶帳戶協議, p.4
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 44 of 225 in the Client Account Agreement 客戶帳戶協議, near the start.

Margin goes to the firm's own account, with no segregation promised

Your margin is money placed with First Asia Merchants Bullion Limited, and clause 18 lets the firm apply it towards its own obligations to any person. No document says client money is segregated, and none names a compensation scheme. The site footer describes the firm as a Type AA member of the Chinese Gold and Silver Exchange, number 114, regulated by the law of Hong Kong.

Where your money sits1 clause flagged

Your margin is money placed with First Asia Merchants Bullion Limited, and clause 18 lets the firm use what you deposit to meet its own obligations to any person. No document says client money is held apart from the firm's own funds.

Why this matters

If the firm fails, nothing in writing separates your balance from its money, and no compensation scheme is named anywhere. The 2020 rules told clients to pay cash straight into the company's own bank account.

Exhibit 17WarningHarder than usual

The Client authorizes the Company to apply any monies which the Client may deposit with or pay to the Company, in or towards meeting the Company’s obligations to any person insofar as such obligations arise out of, in connection with or incidental to business transacted by the Company on the Client’s behalf.
Clause 18(c) in Client Account Agreement 客戶帳戶協議, p.4
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 56 of 225 in the Client Account Agreement 客戶帳戶協議, near the start.

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

Firms licensed by the FCA, ASIC or CySEC must hold retail client money in segregated client accounts, kept apart from the firm's own funds. No First Gold document says where your margin is held or that it is kept apart.

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

Hong Kong law, and the English text beats the Chinese one most clients read

Clause 44 puts the contract under Hong Kong law and the non exclusive jurisdiction of Hong Kong courts, where First Gold and most of its clients are. Clause 3 says the English version prevails over every other language version. The site opens in Chinese, so the governing text is the one in the other column.

Which text wins1 clause flagged

Clause 44 puts the contract under Hong Kong law and the non exclusive jurisdiction of Hong Kong courts, where the firm and most of its clients are. Clause 3 then says the English version prevails over any other language version.

Why this matters

The site opens in Chinese, so the text you read is not the text that decides a dispute. Suing in Hong Kong is at least practical for a Hong Kong client, which is more than many offshore brokers offer.

Exhibit 18NoticeStandard wording

This Agreement is governed and shall be construed in accordance with the laws of Hong Kong, without giving effect to any conflict of law principle. Both parties hereto irrevocably agree to submit to the non-exclusive jurisdiction of the courts of Hong Kong for determining any dispute or matter arising from or relating to this Agreement.
Clause 44 in Client Account Agreement 客戶帳戶協議, p.9
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 128 of 225 in the Client Account Agreement 客戶帳戶協議, 57% 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 English answer reads as a one off charge for opening an account, while the Chinese answer says the US$60 is charged on every lot you trade.

Said in public, in English

If a Client opens an account directly with us, the spread is 5 and the administration fee is USD60, which is USD110 in total.

English FAQ, answer to a question about the administration fee for opening an account

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

In the contract · clause 開戶 Q4

直接開戶在公司, 黃金點差是5點及手續費為60美金每手，一共是110美金的。

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

02

The product page puts spot silver margin at 1% per lot and the trading guidelines put it at 3%.

Said in public, in English

Spot Silver(LLS) 2500 ounce USD/ounce 0.001 USD 1%

Spot Precious Metal Contract product page, initial margin per contract

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

In the contract · clause Margin Requirements table

SPOT SILVER 2500 ounce 0.001 2.5 USD 3% 30%

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

03

The privacy policy limits disclosure to your consent or the law, while the agreement's own schedule allows disclosure to anyone when the firm's interests require it.

Said in public, in English

Other disclosure of your personal data will only be undertaken after this Company has obtained your prescribed consent or as may be required by law. This Company will not sell or lease your personal data to any person.

Privacy Policy Statement, one of three documents ticked at registration

In the contract · clause Schedule 1, 5(viii)

any person in the event that the Company’s interests require disclosure.

04

The Chinese column of clause 33 tells the client they may not object, and the English column, which clause 3 makes the governing text, says nothing of the kind.

Said in public, in Chinese

當公司懷疑或有理由相信這些交易，根據公司的意見，是透過使用軟件或程式或影響平台穩定性的方法而進行，公司有權獨自選擇和酌情地決定取消及還原該些交易的權利，客戶不得異議。

Word for word in English: Where the Company suspects or has grounds to believe that these transactions, in the Company's opinion, were carried out using software or programs or methods affecting platform stability, the Company has the right to decide alone and at its discretion to cancel and reverse those transactions, and the Client may not object.

Chinese column of clause 33 in the Client Account Agreement

In the contract · clause 33

The Company has the right in its sole and absolute discretion to cancel and reverse the transactions when the Company suspects or has reasonable grounds to believe that, in the sole opinion of the Company, these transactions were entered by way of using software or program or even manual methods that affect the trading platform stability of the Company.

What changed quietly

First reading of First Gold, so nothing here is a change since an earlier version of this page.

  • REWRITTENClause Client's Information Statement · V6.9 ( 11/2020 ) to V7.0 ( 11/2021 )

    The rules you agree to are no longer attached to the contract: they are whatever the firm last emailed or posted on its website.

    Client confirms that the margin requirements and trading rules that the Company email to the client are now well understood and agreed to trade conforming to the requirements and rules. The client acknowledges that these trading rules may change from time to time at the sole and discretion of the Company and will be binding to the client. The latest version of trading rules is available on the Company's website or email to the client.

  • REMOVEDClause Schedule 1 (Trading Rules) · V6.9 ( 11/2020 ) to V7.0 ( 11/2021 )

    The five pages of trading rules attached to the 2020 agreement, including the margin table, the close out levels and the 3 day deadline to query a trade, are not in the 2021 agreement.

  • REWRITTENClause 50 · V6.9 ( 11/2020 ) to V7.0 ( 11/2021 )

    The privacy circular became Schedule 1 because the trading rules schedule that used to sit in front of it was taken out.

    The Circular to Clients Relating to the Personal Data (Privacy) Ordinance, Cap.486 of the laws of Hong Kong, as attached in Schedule 1 to this Agreement, shall be incorporated by reference into and form an integral part of this Agreement.

The documents this reading is based on

14 files, all published by First Gold. 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 First Gold publishes.

How this reading was done

Every clause above was read out of a document First Gold publishes itself

This reading was published on .

Documents
13 of 14downloaded from the broker's site, and 13 read in full
Pages opened
35pages walked to find those documents, footer links included
Older copies
1earlier versions downloaded
Languages
EN vs ZH-HKthe language it advertises in, against the language it contracts in
Position measured
16clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

First Asia Merchants Bullion Limited

You contract with First Asia Merchants Bullion Limited, trading as First Gold. Its address in the agreement is 8th Floor, W Square, 314-324 Hennessy Road, Wan Chai, Hong Kong. The agreement names no other entity. The firm is the buyer and seller facing you, not your agent: clause 18 lets it take the opposite position to your order. Its site footer describes it as a member of the Chinese Gold and Silver Exchange Bullion Group, Type AA, number 114, and a Hong Kong Customs Category A registrant. No financial regulator is named in any document, and no compensation scheme is mentioned. The three documents you tick at registration are served from crm.fg114114.com, the firm's own client portal, which its account opening buttons link to.

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

The contract is short for this industry at 16 pages, with Chinese and English side by side in one file. First Gold publishes its full trading rules on the website in three languages. Those pages carry the margin table, the 30% close out level, the settlement times and worked examples for profit and overnight interest, which many firms keep off the site. Every page carries a risk warning about capital risk. There are no bonus terms to trip over: the promotions page has nothing dated later than 2021. The firm also publishes a notice naming seven websites that copy its brand.

The client agreement is not published on the First Gold website itself. You reach it only from inside the account opening form, and we read that copy in full, along with the 2020 version from the firm's old download page. We did not see the client portal behind the login, so any deposit or withdrawal screen there is outside this reading. There is no fee schedule anywhere on the site, so the US$110 a lot figure in the FAQ could not be checked against one. Nothing else in the set was left unread.

How to check any of this yourself

Every quote above links to the First Gold 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 First Gold 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 First Gold 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 5, 2026.

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

What traders say about First Gold

Comments on First Gold are posted on its profile

Nobody has commented on First Gold yet. If you have traded with them, your experience helps the next reader decide.

Write the first comment
Back to the First Gold profile