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Contract reading

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

Every clause below is published by GLX 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: Global Liquidity Exchange

sole discretiondeemed acceptancehidden feecomplaintswithdrawalsincorporation by referencejoint liabilitykyc freezeunilateral amendmentassignment

GLX is no longer on the web: both of its domains are listed for sale, and the three legal documents it published went with them. The contract pools your money with other clients', lets GLX invest it, and gives GLX the interest. GLX's own deposit page promised segregated accounts at top tier banks. Withdrawals can be withheld at GLX's discretion, and no clause sets a deadline to pay you. You get three working days to object to a statement before it counts as agreed.

Contract risk

Money at risk
8.5/10

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.
9
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
20
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
13
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
5

How the 20 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.

Critical9
Warning11
Notice0

section 33 of 36is where the deepest clause sits, 92% 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.

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.

What the documents say

20 clauses worth knowing about, worst first, each quoted from GLX's own files

01

GLX built its contract around its own website. The fee list, the privacy policy and the trading hours all live there by reference. Both GLX domains are now listed for sale by resellers, and the three legal documents went with them.

Why this matters

You cannot read the terms you agreed to, or check what GLX may charge you. The only complaint address in the documents is an email on a domain now offered for sale.

Exhibit 1CriticalRarely seen3

You must pay us the applicable commissions and charges as published by us from time to time on our website at www.glexchange.com.
Clause 7.1 in GLX Terms and Conditions, p.12
Read from the broker's site on Open the reference

Where it sits: section 118 of 460 in the GLX Terms and Conditions, 26% of the way through.

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

Firms licensed by the FCA or CySEC must give a retail client the contract and the cost schedule in a durable form they can keep, and must keep a complaints route open. GLX put all three on a website that is gone.

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

Our readingA contract that pulls in website pages by reference is ordinary. A contract whose referenced website has been sold out from under it is not, because the incorporated terms cannot be read at all.

02

GLX told depositors their money sat in Segregated Client Trust Accounts with Top-Tier International Banks. The contract says your money is not kept separate from other clients' money. It also lets GLX invest that money and keep the interest.

In plain words

Liquidity providers are outside banks and brokers.

Why this matters

Pooling client money is normal. Letting the broker invest it and keep every penny it earns is not. The interest on your own deposit belongs to GLX, not to you.

Exhibit 2CriticalHarder than usual

When funding your trading account, client money is held in Segregated Client Trust Accounts with Top-Tier International Banks.
Quoted in Deposit Process, Security of Funds
Read from the broker's site on Open the reference

Where it sits: section 46 of 460 in the Deposit Process, near the start.

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

Firms licensed by the FCA, CySEC or ASIC must hold retail client money in trust, must not use it for their own account, and must tell the client who receives any interest. GLX's clause 3.5 pools the money, lets GLX invest it, and gives GLX the interest.

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

  • Worse together with Exhibit 7Your money is pooled and investable, and the documents never say which company is holding it.
03

Asking for your money is only a request. Clause 3.6 lets GLX withhold any payment in whole or in part. One of the grounds it gives is no more than GLX being "entitled to withhold the amount".

Why this matters

No clause in the contract says when GLX has to pay you. Nothing sets a deadline, so a hold can run for as long as GLX likes.

Exhibit 3CriticalHarder than usual

Please note that we may at our discretion elect to withhold any payment requested by you (in whole or in part) if: (a) an amount is required to be maintained with us at all times under clause 1.2; or (b) we are entitled to withhold the amount.
Clause 3.6 in GLX Terms and Conditions, p.7
Read from the broker's site on Open the reference

Where it sits: section 66 of 460 in the GLX Terms and Conditions, near the start.

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

Firms licensed by the FCA or CySEC must return retail client money promptly on request and give a reason for any refusal. GLX needs no reason beyond its own entitlement.

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

Our readingGLX does have to tell you when it withholds, under clause 3.7. It never has to say when it will pay.

  • Worse together with Exhibit 4GLX can void the trade that made the profit and then withhold payment of whatever is left.
04

If GLX believes you manipulated its prices or its platform, clause 4.18 splits your trades in two. Trades where you owe GLX money are enforced. Trades where GLX owes you money are void from the start, unless you prove otherwise within 30 days.

Why this matters

The contract never defines manipulation. You carry the burden of producing "conclusive evidence" within 30 days, and GLX can act without notice to you.

Exhibit 4CriticalRarely seen30 days

If we reasonably believe that you have manipulated our prices, our execution processes or the Trading Platform, we may in our sole and absolute discretion and subject to clause 4.16, without notice to you:
Clause 4.18 in GLX Terms and Conditions, p.10
Read from the broker's site on Open the reference

Where it sits: section 100 of 460 in the GLX Terms and Conditions, near the start.

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

Firms licensed by the FCA or CySEC must treat retail clients fairly and apply the same test to a trade whichever way it went. Clause 4.18 applies opposite outcomes to the same finding.

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

Our readingMost contracts let a broker void trades it judges abusive. The asymmetry is the unusual part: one finding of manipulation produces opposite outcomes depending on who is owed. Clause 4.16 does require GLX to act reasonably and in good faith.

05

You get three working days to tell GLX in writing that a document it sent you is wrong. After that, clause 12.9 treats the document as "correct and conclusive". The clock starts when GLX presses send, because clause 22.20 treats its email as received on sending.

Why this matters

Miss the window and GLX's version of a trade becomes the agreed version. You carry that risk even for a statement you never opened, because the days run from sending.

Exhibit 5CriticalHarder than usual3 working days

You must verify the contents of each document received from us. We will take such documents to be correct and conclusive, unless you notify us in writing to the contrary within 3 Business Days of receiving the document.
Clause 12.9 in GLX Terms and Conditions, p.18
Read from the broker's site on Open the reference

Where it sits: section 179 of 460 in the GLX Terms and Conditions, 39% of the way through.

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

Firms licensed by the FCA or CySEC must accept a retail client's complaint for months after the event and answer it in writing. GLX gives three working days before the document becomes conclusive.

GLX 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
The day GLX sends itA confirmation or statement counts as received, whether or not you open it.22.20(c)
3 business days laterYour window to object in writing closes.12.9
After the windowGLX treats the document as correct and conclusive.12.9
  • Worse together with Exhibit 13Your three days run out against a record that the contract itself says beats the contract.
06

The terms hand complaints to a Product Disclosure Statement, and that document also overrides the terms wherever the two disagree. GLX's legal page offered a privacy policy, website terms and the terms themselves. No Product Disclosure Statement was ever published.

Why this matters

You have no way to find out how GLX handles a complaint, who reviews it, or how long it takes. The document that outranks your contract was never shown to you.

Exhibit 6CriticalRarely seen

Please refer to the PDS for further information on how complaints are to be handled under the Agreements.
Clause 22.30 in GLX Terms and Conditions, p.35
Read from the broker's site on Open the reference
Our own capture of web.archive.org, taken on Oct 10, 2026The claim, on Opening line of the GLX legal documents pageVisit this page on the broker's siteDownload the full size image file

Buried at section 353 of 460 in the GLX Terms and Conditions, 77% of the way through.

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

Firms licensed by the FCA or CySEC must give retail clients a written complaints procedure and tell them how to reach an independent scheme. GLX points to a document it never published.

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

Our readingContracts often give a second document priority over themselves. One where that second document does not exist leaves the client's rights resting on something nobody can read.

  • Worse together with Exhibit 5The deadline to object is in the terms, while the procedure for complaining is in the document nobody published.

GLX can change the terms, your leverage and who is liable for your losses

Clause 13.1 of the GLX terms lets the firm close your positions, refuse orders and change your leverage, with or without notice. Clause 22.9 lets GLX rewrite the terms at any time. A margin shortfall becomes a debt due at once, with no cap at the money you deposited, and every director of a company account guarantees it personally.

Account control4 clauses flagged

If your account falls below the required margin, clause 6.2 makes the shortfall immediately due and payable to GLX. Failing to pay it is an event of default. No clause caps your loss at the money you put in.

In plain words

Negative balance protection is a limit that stops you owing more than you put in. Without it, one fast market move can leave you owing the broker money on top of your deposit.

Why this matters

A fast market can leave you owing GLX more than your deposit. GLX can then charge default interest daily and call on a guarantor for the rest.

Exhibit 8CriticalStandard wording

If at any time during the term of a Contract, the Actual Margin is less than the Required Margin on your Account, the shortfall is immediately due and payable to us. A failure to pay the shortfall amount to us will constitute an Event of Default.
Clause 6.2 in GLX Terms and Conditions, p.11
Read from the broker's site on Open the reference

Where it sits: section 107 of 460 in the GLX Terms and Conditions, near the start.

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

Firms licensed by the FCA, under ESMA's rules or by ASIC must give retail clients negative balance protection, so a client cannot lose more than the money in the account. GLX's clause 6.2 makes the shortfall a debt due at once.

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

A company account at GLX must be guaranteed by each of its directors under clause 20.1. GLX can also demand a guarantor from anyone else in its absolute discretion. The guarantee is unconditional and irrevocable.

In plain words

Indemnities are money it says you owe it.

Why this matters

A director's own money stands behind the trading losses, and GLX can demand payment from the director without asking the company first. The guarantee holds even if the company's own obligation turns out to be unenforceable.

Exhibit 9CriticalRarely seen

Your obligations under the Agreements must be guaranteed: (a) where you are a company (including a trustee), by each director of the company; and (b) in any other circumstance where we determine, in our absolute discretion, that a guarantee is required.
Clause 20.1 in GLX Terms and Conditions, p.26
Read from the broker's site on Open the reference

Where it sits: section 261 of 460 in the GLX Terms and Conditions, 57% of the way through.

Our readingA personal guarantee plus indemnity is a commercial lending device. Pointed at a retail trading account, it reaches a director's personal assets over a margin call.

GLX can close out your contracts, refuse your orders, cut your position limit and change your leverage, with or without notice. Clause 13.2 lists the triggers, and one of them is GLX's own decision, in its absolute discretion.

Why this matters

A position can be shut at a price GLX picks, and your leverage can change between one trade and the next. If trading in your market stays suspended for five business days, GLX may close the contract and set the value itself.

Exhibit 14WarningHarder than usual

We may, with or without notice, and in addition to any other rights we may have under the Agreements:
Clause 13.1 in GLX Terms and Conditions, p.18
Read from the broker's site on Open the reference

Where it sits: section 179 of 460 in the GLX Terms and Conditions, 39% of the way through.

Our readingEvery CFD broker keeps close-out rights. The unusual part is a trigger that needs no reason at all, with written notice owed only afterwards.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Day 1 of a suspensionThe price of the suspended instrument freezes at the last price before the suspension.14.1
5 business daysGLX may close the contract, choosing both the date and the value.14.2

GLX may vary these terms at any time, with notice to you and no minimum notice period. It can also end the relationship on 7 days notice, or immediately after an event of default.

Why this matters

A term you relied on can change before your next trade, and your only answer is to close everything and leave. On termination GLX consolidates your accounts and deducts what it says you owe before paying you.

Exhibit 15WarningHarder than usual7 days

We may vary these Terms at any time, with notice to you. In doing so we must comply with any applicable law.
Clause 22.9 in GLX Terms and Conditions, p.32
Read from the broker's site on Open the reference

Buried at section 322 of 460 in the GLX Terms and Conditions, 70% of the way through.

Two companies, one licence and no name in the contract

No registered company name appears in any of the three GLX legal documents: all of them say Global Liquidity Exchange. The risk statement defines that as the company and any related corporate bodies that might exist from time to time. The footer names a Cambodian company holding licence 005 as a Central Counterparty, and a Saint Vincent company registered by the companies registrar there.

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 you contract with1 clause flagged

Every legal document calls your counterparty "Global Liquidity Exchange", which is not a registered company name. The risk statement defines it as that company "and any related corporate bodies that might exist from time to time". The footer names two different companies, in two countries.

Why this matters

You cannot tell which company took your deposit, so you cannot tell which court or regulator to approach. Clause 22.13 also lets GLX hand its rights to anyone without asking you.

Exhibit 7CriticalRarely seen2

GLX, we, us and our, means Global Liquidity Exchange and any related corporate bodies that might exist from time to time.
Clause 2.12 in GLX Risk Disclosure Statement, p.7
Read from the broker's site on Open the reference
Our own capture of web.archive.org, taken on Oct 10, 2026The claim, on Company address shown in the header of every GLX pageVisit this page on the broker's siteDownload the full size image file
Our own capture of web.archive.org, taken on Oct 10, 2026What the contract says, clause FooterVisit this page on the broker's siteDownload the full size image file

Buried at section 33 of 36 in the GLX Risk Disclosure Statement, 92% of the way through.

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

Firms licensed by the FCA or CySEC must name the contracting entity, its registered address and its regulator in the client agreement. None of the three GLX documents names a registered company.

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

Our readingOffshore brokers often run two entities. Defining the counterparty as a trading name plus any related company that might exist from time to time leaves the client with no identified party at all.

GLX put its entire price list on a website that is now for sale

Not one fee figure appears in the GLX Terms and Conditions. Clause 7.1 makes you pay whatever GLX publishes on glexchange.com, a domain now listed for sale. The contract names only two charges: a conversion fee of up to 1 per cent, and daily default interest at 3% over the central bank rate.

Cost disclosure3 clauses flagged

The contract names no commission, no spread and no deposit charge. Clause 7.1 makes you pay whatever GLX publishes on its website at the time. GLX can raise those charges on 30 days notice, and clause 7.3 drops the notice for circumstances it calls beyond its control.

Why this matters

You agreed to a price list you cannot now read. The contract lets GLX take those amounts straight from your account at close of business on the day they arise.

Exhibit 10WarningHarder than usual30 days

To view the commissions and charges applicable to your chosen product, please visit our website and select the relevant product from the list provided.
Clause 7.1 in GLX Terms and Conditions, p.12
Read from the broker's site on Open the reference

Where it sits: section 118 of 460 in the GLX Terms and Conditions, 26% of the way through.

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, in a form the client can keep. GLX's contract contains no figure at all.

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

  • Worse together with Exhibit 1The charges you agreed to pay existed only on the website, and the website has been sold.

Moving money between your own GLX accounts in different currencies costs up to 1 per cent. GLX sets the spot rate it applies, and clause 9.3 lets it waive the fee for whoever it chooses.

Why this matters

Convert $10,000 and up to $100 goes to GLX before you place a single trade. Closing a position converts your profit or loss again at GLX's rate.

Exhibit 11WarningHarder than usual1%

funds transferred between your Accounts that are denominated in different currencies, will be converted at the current spot rate for the conversion of the relevant funds into your nominated currency, minus a conversion fee of up to 1 per cent, which we will charge you; and
Clause 9.1(a) in GLX Terms and Conditions, p.14
Read from the broker's site on Open the reference

Where it sits: section 138 of 460 in the GLX Terms and Conditions, 30% of the way through.

What it costsA $10,000 transfer between two of your own accounts in different currencies can cost $100 under clause 9.1.

Owe GLX money and clause 8.2 adds the central bank rate plus 3%, debited from your account every day until it is paid. Clause 22.29 then treats each missed payment as an application for credit from GLX.

Why this matters

A margin shortfall becomes a growing debt with interest running daily. It also puts you on the footing of a credit applicant, which is how the privacy policy justifies a credit check.

Exhibit 12WarningRarely seen3%

The default interest rate will be the central bank target cash rate for the relevant Underlying Instrument plus 3% as determined by us. The amount of default interest will be debited from your Account daily until the amount owed to us is paid.
Clause 8.2 in GLX Terms and Conditions, p.13
Read from the broker's site on Open the reference

Where it sits: section 128 of 460 in the GLX Terms and Conditions, 28% of the way through.

Our readingDefault interest is ordinary. Deeming every missed payment an application for credit is not, and it is the hinge that joins this clause to the director guarantees and the credit checks.

  • Worse together with Exhibit 9A missed payment becomes an application for credit, and a director has already guaranteed it personally.

A withdrawal at GLX is a request the firm may decline

Clause 3.6 of the GLX terms turns a withdrawal into a request GLX may withhold in whole or in part. The contract sets no deadline for paying you, and one of the two stated grounds is circular. GLX's own page promised same day processing before 12:00, capped card payouts at what you had deposited, and sent anything above that out by bank wire taking up to 14 days.

Exit conditions1 clause flagged

Card withdrawals were capped at what you had deposited by that card. Anything above it had to leave by an earlier method or a bank wire, which GLX said takes up to 14 days. A newly added card had to receive a fresh deposit before it could pay out.

Why this matters

Your winnings leave by the slowest route on the list. A bank wire also carries intermediary fees that GLX says are yours to pay, not its own.

Exhibit 16WarningHarder than usual14 days

Should you wish to withdraw an amount in excess of the sum deposited by Verified by Visa /MasterCard Secure Credit / Debit Card, you will be required to utilize another deposit method used earlier or a bank wire option.
Quoted in Withdrawing Funds
Read from the broker's site on Open the reference

Our readingCard refunds are generally limited to the amount deposited on that card, which is a card scheme rule rather than GLX's choice. Asking for a new deposit to unlock a payout is GLX's own addition.

Three working days to object, and the complaints rules were never published

GLX gives you three working days to object in writing to any document it sends. After that, clause 12.9 treats the document as correct and conclusive. The clock starts when GLX sends the email, not when you read it. The complaints procedure itself sits in a Product Disclosure Statement that GLX never published, and both GLX domains are now listed for sale.

Complaint deadlines1 clause flagged

Where the contract and GLX's record of a trade disagree, clause 12.3 says the record wins. GLX also keeps the right to correct your account to the market value it decides applied when an error happened.

Why this matters

Your evidence of what you agreed is the contract, and the contract gives way to GLX's internal record. You would be arguing against the only record that counts.

Exhibit 13WarningHarder than usual

If there is a conflict between: (a) the Agreements; and (b) our records of the transaction concerning a Contract or an Order, our records of the transaction will prevail.
Clause 12.3 in GLX Terms and Conditions, p.16
Read from the broker's site on Open the reference

Where it sits: section 158 of 460 in the GLX Terms and Conditions, 34% of the way through.

Cambodian law, a non-exclusive court clause and three currencies

Clause 22.22 sends disputes to the courts of Phnom Penh on a non-exclusive basis, so GLX keeps the right to sue you elsewhere. The definitions say dollars mean the lawful currency used in Cambodia, while guarantors must pay in Australian dollars. The warranties still refer to Australian law.

Where you would sue1 clause flagged

Phnom Penh law governs the contract, and you submit to the courts there on a non-exclusive basis. GLX keeps the right to sue you in any other jurisdiction it finds relevant. The definitions then say dollars mean "the lawful currency used in Cambodia", while guarantors must pay in Australian dollars.

Why this matters

Suing GLX means going to Cambodia, while GLX can come to you. The contract defines the currency of payment three different ways, so what you owe depends on which clause is read.

Exhibit 17WarningRarely seen

The Agreements are governed by the laws in force in Phnom Penh, Cambodia and you submit to the non-exclusive jurisdiction of the courts of that place.
Clause 22.22 in GLX Terms and Conditions, p.33
Read from the broker's site on Open the reference

Buried at section 332 of 460 in the GLX Terms and Conditions, 72% of the way through.

Our readingA contract that defines its own payment currency three different ways is unusual. The Australian law and Australian dollar references show a template that was never finished for Cambodia.

GLX's privacy policy treats you as a credit applicant

The GLX privacy policy lists a Veda Check or other credit or bankruptcy check among the information it collects, and names credit reporting agencies among the parties it shares your data with. It also names the United Kingdom, the United States, Thailand, China and Russia as places your information may go. The protection it offers is that the recipient will not breach GLX's own policy.

Checks on you2 clauses flagged

GLX's privacy policy lists "a Veda Check or other credit or bankruptcy check" among the information it collects about you. It shares your data with credit reporting agencies, and with companies in the United Kingdom, the United States, Thailand, China and Russia. The July 2023 edition has the same wording.

Why this matters

A credit and bankruptcy check can leave a record with agencies you never dealt with. The safeguard GLX offers for sending your data abroad is that the recipient will not breach GLX's own policy.

Exhibit 19WarningRarely seen

a Veda Check or other credit or bankruptcy check; and/or
Clause 2.2 in GLX Privacy Policy, p.4
Read from the broker's site on Open the reference

Where it sits: section 23 of 80 in the GLX Privacy Policy, 29% of the way through.

Our readingBrokers run identity checks. A credit and bankruptcy check, with disclosure to credit reporting agencies, belongs to a lender rather than a broker, and Veda is an Australian credit bureau.

  • Worse together with Exhibit 12The contract turns a missed payment into an application for credit, and the privacy policy treats you as a credit applicant.

GLX can run anti-money laundering checks on you, pass on what it collects, and take "any associated action" without liability. Clause 1.8 says GLX has no obligation to tell you it has done so.

Why this matters

Action taken under this clause needs no explanation and carries no comeback. Nothing in the terms says what happens to your balance while a check runs.

Exhibit 20WarningHarder than usual

We may pass on information collected from you and relating to transactions as required by the AML/ CTF Policy or other applicable laws and regulations and we are under no obligation to inform you that we have done so.
Clause 1.8 in GLX Terms and Conditions, p.3
Read from the broker's site on Open the reference

Where it sits: section 26 of 460 in the GLX Terms and Conditions, near the start.

GLX is your counterparty, and says so once

The whole conflicts disclosure in the GLX terms is one sentence. Clause 23.1 says GLX may have a conflict of interest in acting as principal on both sides of a transaction. GLX quotes the prices, holds the records that outrank the contract, and may reprice your order on execution. Nothing says how that conflict is managed.

Both sides of the trade1 clause flagged

GLX is the other side of every trade you place, not your agent. It quotes the prices, keeps the records, and may move the execution price to the market value when your order arrives. Its entire conflicts disclosure is a single sentence.

Why this matters

Your loss is GLX's gain on the same contract. The contract tells you that once, near the end, and never says how GLX manages the conflict.

Exhibit 18WarningHarder than usual

We may have a conflict of interest in acting as principal on both sides of a transaction.
Clause 23.1 in GLX Terms and Conditions, p.35
Read from the broker's site on Open the reference

Buried at section 353 of 460 in the GLX Terms and Conditions, 77% of the way through.

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

Firms licensed by the FCA or CySEC must identify, manage and disclose conflicts of interest and keep a written conflicts policy. GLX's disclosure is clause 23.1, one sentence long.

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

Our readingDealing as principal is normal for a CFD broker. A one sentence conflicts disclosure, with nothing on how the conflict is managed, is not.

Where the marketing and the contract disagree

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

01

GLX promised segregated client accounts on the page that took deposits, while its contract pooled the money and let GLX invest it.

Said in public, in English

When funding your trading account, client money is held in Segregated Client Trust Accounts with Top-Tier International Banks.

Security of Funds section of the GLX deposit page

In the contract · clause 3.5(a)

your money is not kept separate from the money of other clients in our trust account

02

The website promised same day processing while the contract let GLX withhold any payment at its discretion, with no deadline to pay.

Said in public, in English

Withdrawal requests cut off time is 12:00. If your withdrawal is submitted before this time it will be processed on the day of receipt.

Important Notes on the GLX Withdrawing Funds page

In the contract · clause 3.6

Please note that we may at our discretion elect to withhold any payment requested by you (in whole or in part) if: (a) an amount is required to be maintained with us at all times under clause 1.2; or (b) we are entitled to withhold the amount.

03

A no fees promise sat on the deposit page while the contract made the charges whatever GLX chose to publish, changeable at short notice or none.

Said in public, in English

GLX does not charge any additional fees for deposits or withdrawals.

Bank Fees section of the GLX deposit page

In the contract · clause 7.1

You must pay us the applicable commissions and charges as published by us from time to time on our website at www.glexchange.com.

04

GLX told clients to read its disclosure documents while the document that governs complaints and overrides the terms was never published.

Said in public, in English

Prior to opening a trading account with GLX please ensure that you have read and understood our Account Terms and other disclosure documents as applicable.

Opening line of the GLX legal documents page

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

In the contract · clause 22.30

Please refer to the PDS for further information on how complaints are to be handled under the Agreements.

05

GLX showed a New York address at the top of every page while the footer of the same pages excluded the United States, and its legal documents give a Phnom Penh address.

Said in public, in English

1010 Avenue of the Moon, New York, NY 10018 US.

Company address shown in the header of every GLX page

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

In the contract · clause Footer

The information on this site and the products and services offered are not intended for distribution to the U.S., or any person in any country or jurisdiction where such distribution or use would be contrary to local law or regulation.

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

What changed quietly

First review of GLX. The version changes listed are between GLX's own editions, not between WIKILIX reviews.

  • REWRITTENClause · August 2019 to July 2023

    The only change to the privacy policy between the two editions is the date on the cover: the text is identical, down to the Australian credit check.

    JULY 2023
  • REMOVEDClause · August 2019 to July 2023

    The Risk Disclosure Statement was not part of the set GLX published from July 2023, when the legal page offered only the privacy policy, the website terms and the terms.

The documents this reading is based on

13 files, all published by GLX. 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 GLX publishes.

How this reading was done

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

This reading was published on .

Documents
0 of 13downloaded from the broker's site, none of them read end to end
Pages opened
33pages walked to find those documents, footer links included
Older copies
14earlier versions downloaded
Position measured
19clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

Global Liquidity Exchange

Every legal document says you contract with "Global Liquidity Exchange", which is not a registered company name. The risk statement defines that term as Global Liquidity Exchange "and any related corporate bodies that might exist from time to time". GLX's own footer names two companies. One is Global Liquidity Exchange Company Limited, registered in Cambodia as a Central Counterparty, number 00037736, with licence 005 from the Securities and Exchange Regulator of Cambodia. The other is Global Liquidity Exchange Limited, an International Business Company registered in Saint Vincent and the Grenadines under number 25664 IBC 2019, where the registration is a company registration rather than a trading licence. The copyright line says Global Liquidity Exchange Co., Ltd. The contract itself names a Cambodian regulator under a name it no longer uses, and spells it two ways. Nothing says which company takes your deposit, and clause 22.13 lets GLX pass its rights to anyone without asking you.

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 July 2023 terms are clearly written, numbered throughout and backed by a full definitions section, which is better than most offshore contracts. GLX published no bonus scheme, so none of the usual bonus lock and turnover traps exist. Nothing in the terms charges an inactivity or dormancy fee, and nothing lets GLX absorb a dormant balance. Clause 3.5(d) obliges GLX to put back any shortfall if an investment of client money comes back short. It also bars GLX from charging a fee for investing your money. The 2019 Risk Disclosure Statement is thorough, with a worked leverage example and a plain statement that losses can exceed deposits.

GLX publishes nothing today. Both glexchange.com and glexport.com are listed for sale by domain resellers. The client portal at secure.glexchange.com no longer resolves, and the.com.kh site does not answer. Every clause quoted here comes from copies of GLX's own documents kept by the Internet Archive. The newest copy of the contract is the July 2023 edition, and this review covers it in full. We also read the July 2023 privacy policy and website terms, the August 2019 risk disclosure, and GLX's deposit and withdrawal pages. The August 2019 edition of the contract survives only as a copy that stops partway through. Our comparison between editions covers only the part that can still be read. The 2019 website terms are not covered. No available copy includes a Product Disclosure Statement or a fee schedule, so the complaints procedure and the real charges are not covered.

How to check any of this yourself

Every quote above links to the GLX 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 GLX 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 GLX 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 10, 2026.

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

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