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Contract reading

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

Every clause below is published by ICM 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: ICM Capital Limited

sole discretionhidden feemarketing gapwithdrawalsdepositsgroup shieldkyc freezemargin callprofit voidingunilateral amendment

ICM's partner page promises negative balance protection. Clause 8.5 of the contract lets ICM claim your negative balance back from you. If ICM suspends your account for a rule breach, clause 18.14 annuls the profit you made. Suspicion of hedging can freeze your funds for 90 days.

Contract risk

Money at risk
7.4/10

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.
5
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
18
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
7
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
4

How the 18 break downThe same flagged clauses, split by how much each one can cost you. Severity is our reading of the clause, not the broker's label.

Critical5
Warning9
Notice4

section 157 of 180is where the deepest clause sits, 87% 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.

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

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

01

ICM's partner page tells you it provides negative balance protection. Clause 8.5 says the opposite. If your account goes below zero after a stop out, ICM can claim that money back from you. The stop out fires at 5% of your margin.

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

Negative balance protection means a loss cannot take you below zero. Without it you can end up owing ICM more than you deposited. Clause 8.11 confirms your account balance is not the limit of what you owe.

Exhibit 1CriticalHarder than usual5%

ICM Capital maintains the right to close any client position/positions when stop out level (equity/margin) falls at 5% of the total margin requirements or the level agreed with the client. In case the balance or equity becomes negative as a result of stop out, ICM Capital reserves the right to claim the balance from the client to adjust the equity back to zero.
Clause 8.5 in Terms and Conditions, p.17
Read from the broker's site on Open the reference
Our own capture of icm.com, taken on Aug 27, 2026The claim, on Partnership page, under the heading Cutting-Edge TechnologyVisit this page on the broker's siteDownload the full size image file
Our own capture of icm.com, taken on Aug 27, 2026What the contract says, clause 8.5Visit this page on the broker's siteDownload the full size image file
Our own capture of icm.com, taken on Aug 27, 2026Negative balance protection promised, then billed back (clause 8.5)Visit this page on the broker's siteDownload the full size image file

Where it sits: section 78 of 180 in the Terms and Conditions, 43% of the way through.

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

Firms licensed by the FCA, CySEC and other ESMA regulators must give retail clients negative balance protection. A retail loss cannot exceed the money in the account. This contract lets ICM claim the shortfall instead.

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

02

ICM can wipe out the profit you made if it suspends your account for breaking the rules. Clause 18.14 calls that annulment. Clause 16.3 lets ICM close or suspend the account whenever it decides to, with no reason given to you.

Why this matters

You keep your deposit, but the money you earned on top of it can be cancelled. ICM makes that decision alone, and the contract gives you no appeal.

Exhibit 2CriticalHarder than usual

If the Client’s account has been suspended due to the violation of the current Terms of Services or due to any other form of abuse by the Client, the earnings/profits will be annulled.
Clause 18.14 in Terms and Conditions, p.27
Read from the broker's site on Open the reference
Our own capture of icm.com, taken on Aug 27, 2026Profits annulled when ICM suspends your account (clause 18.14)Visit this page on the broker's siteDownload the full size image file

Buried at section 122 of 180 in the Terms and Conditions, 68% of the way through.

  • Worse together with Exhibit 3One clause decides your trading was abusive and the other deletes the profit that trading earned.
03

Trading that ICM treats as abusive can get your account frozen for up to 90 days while it investigates. Clause 4.12 lists hedging and arbitraging as prohibited, and it defines neither word. ICM can also cancel the trades and take back the profit.

Why this matters

Hedging means holding a buy and a sell on the same market at once, which many traders do routinely. If ICM decides yours was abusive, you cannot reach your money for three months.

Exhibit 3CriticalHarder than usual90 days

Investigate suspected Prohibited Trading Activities, during which investigation Participant trading accounts will be frozen and unable to withdraw funds for a period of up to ninety (90) days.
Clause 4.12 in Terms and Conditions, p.10
Read from the broker's site on Open the reference
Our own capture of icm.com, taken on Aug 27, 2026Hedging can freeze your funds for 90 days (clause 4.12)This 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

Where it sits: section 48 of 180 in the Terms and Conditions, 27% of the way through.

  • Worse together with Exhibit 6ICM sets the only price your trades are measured against and then judges whether that trading was abusive.
04

The deposits page tells you ICM pays all credit card deposit costs. Clause 10.3 says ICM may charge those costs to you instead. The Arabic version of the page makes the same promise to Arabic speaking clients.

Why this matters

You can be charged a card fee that the page told you does not exist. Nothing in clause 10.3 caps the amount or makes ICM tell you first.

Exhibit 4CriticalHarder than usual

In the event that charges are imposed by the credit or debit Card Company (or any other provider) used to deposit funds on to your account, these may be charged by us to you.
Clause 10.3 in Terms and Conditions, p.18
Read from the broker's site on Open the reference
Our own capture of icm.com, taken on Aug 27, 2026The claim, on Deposits and withdrawals page, answer to What Are the Charges for Credit Card Deposits?Visit this page on the broker's siteDownload the full size image file
Our own capture of icm.com, taken on Aug 27, 2026What the contract says, clause 10.3Visit this page on the broker's siteDownload the full size image file

Where it sits: section 85 of 180 in the Terms and Conditions, 47% of the way through.

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

Firms licensed by the FCA and CySEC must disclose costs and charges to a retail client before they trade. Here the public page and the contract say opposite things about the same fee.

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

05

Raise a dispute about a trade and ICM can close that position straight away. Clause 20.8 says it will not reopen the trade whatever the dispute decides. Clause 23.2 caps what ICM owes you at your realised profits.

Why this matters

Winning the argument does not get your position back. If that closed trade would have recovered, the loss stays yours. Clause 23.2 limits your recovery to profit you had already banked.

Exhibit 5CriticalHarder than usual

In the event of any query or dispute ICM Capital may at its discretion immediately close, at the prevailing ICM Capital quote or the first such quote available, any Position that is in dispute. No matter what the subsequent result of the dispute, ICM Capital will not reopen or reinstate any such closed trade.
Clause 20.8 in Terms and Conditions, p.30
Read from the broker's site on Open the reference
Our own capture of icm.com, taken on Aug 27, 2026Disputed trades are closed and never put back (clause 20.8)Visit this page on the broker's siteDownload the full size image file

Buried at section 138 of 180 in the Terms and Conditions, 77% of the way through.

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

Firms licensed by the FCA and CySEC must give retail clients access to an independent complaints body, such as an ombudsman. This contract names no external scheme and makes ICM's own decision the end of the matter.

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

  • Worse together with Exhibit 6ICM's own records are the evidence in a dispute about a price that only ICM quoted.

Three charges the contract creates but never prices

Clause 18.17 gives you one free withdrawal a calendar month, and only if you have traded 5 lots, then charges you for the second. Clause 10.5.3 starts a daily admin fee on swap-free positions after 14 days for currencies and 5 days for metals, with the amount left to a web page ICM can change. Clause 13.3 charges 2% a month, compounding, on anything you owe ICM.

Cost disclosure3 clauses flagged

ICM covers the cost of one withdrawal a calendar month, and only if you have traded at least 5 lots. Clause 18.17 charges you for the second one, and for any withdrawal if you have not traded. The deposits page does not mention this.

Why this matters

Taking your money out twice in one month costs you, and the contract never says how much. Clause 18.12 lets ICM add a further commission if you withdraw to a different method than you deposited from.

Exhibit 7WarningHarder than usual1

ICM will bear the fees for one withdrawal per calendar month as long as the client has traded a min. of 5 lots or there is a remaining balance in his account.
Clause 18.17 in Terms and Conditions, p.27
Read from the broker's site on Open the reference

Buried at section 127 of 180 in the Terms and Conditions, 71% of the way through.

Holding a position on a swap-free account past 14 days starts a daily admin fee. On metals it starts after 5 days. Clause 10.5.5 says the amount lives on the website, and the contract never states it.

Why this matters

You cannot work out what a long position costs you from the contract alone. The fee is added every day the position stays open, and ICM can change the amount whenever it likes.

Exhibit 8WarningHarder than usual14 days

An administrative fee (“Admin Fee”) shall apply to open positions on swap-free accounts after the applicable grace period, which is fourteen (14) calendar days for FX instruments and five (5) calendar days for Metals.
Clause 10.5.3 in Terms and Conditions, p.19
Read from the broker's site on Open the reference

Where it sits: section 88 of 180 in the Terms and Conditions, 49% of the way through.

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

Firms licensed by the FCA and CySEC must set out costs and charges before a retail client trades. This contract gives the trigger and the timing but leaves the amount to a web page it can change.

ICM 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
Day 5, metalsThe grace period ends on a metals position and the admin fee can start.10.5.3
Day 14, currenciesThe grace period ends on a currency position and the admin fee can start.10.5.3
Every day afterICM can add the fee again each day the position stays open.10.5.4

Money you owe ICM that is more than 5 days late collects 2% a month. Clause 13.3 compounds it and charges for part months too. ICM can take it from any account you hold with it.

Why this matters

That is 24% a year before compounding, on a debt that can appear from a negative balance you did not choose. Clause 13.4 also puts ICM's recovery costs on you.

Exhibit 9WarningHarder than usual2%

ICM Capital reserves the right to and shall be entitled to charge interest on all sums payable to ICM Capital under these Terms and Conditions which are not paid within 5 days of their due date until payment is made in full, ICM Capital shall charge you 2% per calendar month or part thereof cumulative on the sum owed to ICM Capital.
Clause 13.3 in Terms and Conditions, p.21
Read from the broker's site on Open the reference

Where it sits: section 97 of 180 in the Terms and Conditions, 54% of the way through.

What it costsA $1,000 debit balance left unpaid grows by $20 in the first month. After six months clause 13.3 has added about $126, because the interest compounds.

Profit on an open trade is not yours to withdraw

Clause 13.5 blocks withdrawal of unrealised profits under any conditions, so a winning position must be closed first. Clause 18.9 lets ICM refuse a withdrawal outright if you use a different method from the one you deposited with. Card withdrawals are capped at your original deposit, and ICM picks the method for anything above it.

Getting money out1 clause flagged

Profit on open trades cannot be withdrawn at all under clause 13.5. Clause 18.9 lets ICM refuse a withdrawal if you use a different method than you deposited with. Card withdrawals are capped at what you paid in.

Why this matters

You have to close a winning trade before the profit becomes yours to take. If the card you deposited with has expired, clause 18.14 sends the rest through a method ICM chooses.

Exhibit 10WarningHarder than usual

Unrealised profits will under no conditions be paid or be available for electronic withdrawal or offset your obligation to pay your realised losses.
Clause 13.5 in Terms and Conditions, p.21
Read from the broker's site on Open the reference

Buried at section 120 of 180 in the Terms and Conditions, 67% of the way through.

ICM can change the margin and the contract while you hold a position

Clause 8.8 lets ICM change the minimum margin and the stop out level without notice, and applies the new figures to positions you already hold. Clause 21.1 does the same for the contract itself, taking effect immediately on service and reaching open positions and unfilled orders. You get no notice period and no right to refuse.

Rules that move1 clause flagged

ICM can raise the margin you must hold and lift the stop out level without telling you first. Clause 8.8 applies the new numbers to positions you already hold. Clause 21.1 does the same for the contract itself.

Why this matters

A trade that was safely funded this morning can be closed this afternoon on rules that changed in between. You get no notice period to close out first and no right to reject the new wording.

Exhibit 11WarningHarder than usual

The minimum IMR for any market and stop out level may be changed from time to time by ICM Capital without notice to you (for example, during volatile market conditions or due to the illiquid nature of any Underlying Market). These new margin requirements and stop out level will be applied to all your existing Positions as well as any new Transactions.
Clause 8.8 in Terms and Conditions, p.17
Read from the broker's site on Open the reference

Buried at section 143 of 180 in the Terms and Conditions, 79% of the way through.

You sue ICM in Mauritius, ICM sues you at home

Clause 26.2 sends your claims exclusively to the courts of Mauritius while letting ICM sue you wherever you live or hold assets. Clause 26.3 removes any claim against ICM's parent, affiliates and sister companies, including the London, Abu Dhabi, Dubai and Zurich firms on the regulations page. A new clause 3.11 then routes your card payment through two of those very companies.

Where you can sue2 clauses flagged

You can only sue ICM in Mauritius. Clause 26.2 lets ICM sue you wherever you live, work or hold assets. Clause 26.3 blocks any claim against ICM's parent, affiliates or sister companies.

Why this matters

Bringing a case in Mauritius costs more than most retail balances are worth. The London, Abu Dhabi, Dubai and Zurich companies on the regulations page cannot be sued over your account.

Exhibit 15WarningHarder than usual

Any dispute arising out of, or in connection with, the interpretation of the Terms and Conditions and/or the performance of the parties obligations under these Terms and Conditions will be finally and exclusively settled by the courts of the Mauritius. However, ICM Capital may file any claim it might have against you before the courts where you have your headquarters or offices or residence or activities or assets.
Clause 26.2 in Terms and Conditions, p.34
Read from the broker's site on Open the reference

Buried at section 157 of 180 in the Terms and Conditions, 87% of the way through.

Your card payment can now be handled by ICM House AG in Switzerland, or by a London company also called ICM Capital Limited. Clause 3.11 arrived after December 2025. Clause 26.3 says you have no claim against either of them.

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.

Why this matters

The company that takes your card payment is not the company you contracted with. If that payment goes wrong, clause 26.3 leaves you with a claim against the Mauritius entity only.

Exhibit 16WarningRarely seenNew

Card transactions may be processed by any of the associated independent representatives: ICM House AG, with registration number CHE-497.911.976 and registered address 4 Industriestrasse 24, 6300 Zug, Switzerland; or ICM Capital Limited, with registration number 07101360 and registered address The Leadenhall Building Level 30, 122 Leadenhall Street, London EC3V 4AB, England.
Clause 3.11 in Terms and Conditions, p.8
Read from the broker's site on Open the reference

Where it sits: section 37 of 180 in the Terms and Conditions, near the start.

Our readingTwo separate companies share the name ICM Capital Limited: your Mauritius counterparty and UK company 07101360. A contract that names a same-named foreign company as your payment handler is unusual. Clause 26.3 then bars any claim against it.

  • Only applies after Exhibit 15Naming an outside payment handler only matters because another clause removes your right to claim against it.

Fifteen days to verify, and a privacy policy with no retention limit

ICM's AML policy gives you 15 days from account opening to supply identity documents, caps deposits at USD 2,000 meanwhile, and closes the account if the deadline passes. It does promise not to freeze funds without a money laundering suspicion. The privacy policy calls ICM a Data Processor rather than a controller, treats GDPR as voluntary, and sets no retention period.

Documents and data2 clauses flagged

You get 15 days from opening the account to send your identity documents. Until then the AML policy caps your deposits at USD 2,000. Miss the deadline and ICM closes the account.

Why this matters

The clock starts when the account opens, not when ICM asks you for anything. The same policy does promise not to freeze your funds unless it suspects money laundering.

Exhibit 13WarningStandard wording15 days

The clients are provided with a grace period of fifteen (15) days to provide the Company with their identification documents
Clause 5.1.2.d.ii in AML & KYC Policy, p.9
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 85 of 170 in the AML & KYC Policy, 50% of the way through.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Days 1 to 15You can deposit up to USD 2,000 while your identity documents are outstanding.5.1.2.d.ii
After day 15ICM closes the account if your verification is not finished.5.1.2.d.ii

ICM describes itself as a Data Processor for your personal information, twice. A firm that decides why and how your data is used is normally the controller, which carries more duties. The policy also treats GDPR as voluntary.

Why this matters

The policy sets no retention period and gives you no stated right to see, correct or delete your data. ICM can also change the policy at any time.

Exhibit 14NoticeHarder than usual

ICM Capital shall process your personal data as a Data Processor when you specifically opt-in and provide us with your consent, during your application to open a trading account.
Clause 2 in Privacy Policy, p.2
Read from the broker's site on Archived copyOpen the reference

ICM is your counterparty, your price source and your venue

ICM's order execution policy names ICM Capital as the sole execution venue for every trade and describes execution through a dealing desk. The partner page sells a Full ECN platform, which would send orders to an outside market. Clause 4.10 also lets ICM delete a trade it decides did not reflect real market prices.

Who takes the other side1 clause flagged

The partner page sells a Full ECN platform, which means client orders reach an outside market. The order execution policy describes a dealing desk and names ICM as the sole execution venue. Every trade you place goes to ICM itself.

Why this matters

ICM takes the other side of your trade, so it gains when you lose. It also sets the only price your trade is measured against, and clause 4.10 lets it delete a trade it decides did not match the real market.

Exhibit 6WarningStandard wording

ICM Capital is the sole execution venue for your trades placed via its internet portals or over the telephone.
Quoted in Order Execution Policy, p.5
Read from the broker's site on Archived copyOpen the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must disclose that they act as principal and must manage the conflict this creates. ICM does disclose it, on page 4 of the execution policy, while the partner page sells a Full ECN platform.

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

ICM charges nothing for leaving an account idle

Clause 17.4 is the only dormancy provision in ICM's contract, and it runs for six years. After that, and only where ICM has tried to trace you and failed, your balance stops being treated as client money. ICM undertakes to make good later valid claims, and no inactivity fee appears anywhere in the document set.

In plain words

Dormancy means an account left unused.

Dormant accounts1 clause flagged

Leave the account untouched for six years and ICM can stop treating your balance as client money. Clause 17.4 applies only where ICM has tried to trace you and failed. ICM promises to honour a later valid claim.

Why this matters

Six years is longer than most brokers give you, and this contract charges no inactivity fee along the way. Your money loses its client money protection at the end of that period, not before.

Exhibit 12NoticeStandard wording

In the event that there has been no movement on your account balance for a period of at least six years (notwithstanding any payments or receipts of charges, interest or similar items) and we are unable to trace you despite having taken reasonable steps to do so, you agree that we may cease to treat your money as client money, we shall make and retain records of all balances released and undertake to make good any future valid claims against released balances.
Clause 17.4 in Terms and Conditions, p.24
Read from the broker's site on Open the reference

Buried at section 113 of 180 in the Terms and Conditions, 63% of the way through.

The contract cites policies ICM never published

ICM's footer carries five legal documents. Clause 14.2 points to a Conflicts of Interest Policy and clause 18.10 to a Bonus and Awards policy, and neither is published. Clause 20.9 offers compensation from something it calls the Scheme without naming it, and ICM's risk disclosure identifies your counterparty as Capital APAC Pacific, a company named nowhere else.

The document set2 clauses flagged

The contract sends you to two policies that ICM does not publish. Clause 14.2 points to a Conflicts of Interest Policy, and clause 18.10 to a Bonus and Awards policy. The footer carries five documents and neither is among them.

Why this matters

You cannot read the terms that decide how ICM handles a conflict against you, or what happens to a bonus. Clause 20.9 also promises compensation from something it calls the Scheme, which the contract never names.

Exhibit 17NoticeHarder than usual

These are detailed in our Conflicts of Interest Policy which may be found online.
Clause 14.2 in Terms and Conditions, p.22
Read from the broker's site on Open the reference

Where it sits: section 102 of 180 in the Terms and Conditions, 57% of the way through.

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

Firms licensed by the FCA must belong to a named investor compensation scheme and must publish a conflicts of interest policy. This contract refers to a Scheme without identifying one anywhere in its pages.

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

The risk disclosure tells you your counterparty is Capital APAC Pacific. That name appears in no other ICM document and on no ICM page. A separate contract on the same website names ICM Capital LLC in Saint Vincent.

Why this matters

The document ICM tells you to read before trading names the wrong company. Your money sits with ICM Capital Limited in Mauritius, the only entity clause 26.3 lets you claim against.

Exhibit 18NoticeRarely seen

Customer enters a trade and opens a position with Capital APAC Pacific in its capacity as a counter party.
Quoted, p.3

Our readingA risk disclosure that names a different company as your counterparty reads as text carried over from another firm's document and never corrected. The same file has said this since at least June 2025.

Where the marketing and the contract disagree

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

01

The page promises negative balance protection while clause 8.5 reserves the right to claim a negative balance back from you.

Said in public, in English

With a Full ECN platform, ICM provides instant, stable execution and negative balance protection.

Partnership page, under the heading Cutting-Edge Technology

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

In the contract · clause 8.5

In case the balance or equity becomes negative as a result of stop out, ICM Capital reserves the right to claim the balance from the client to adjust the equity back to zero.

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

02

The page says ICM pays every card deposit cost while clause 10.3 lets ICM pass those costs to you.

Said in public, in English

ICM bares all costs for clients who deposit via credit card.

Deposits and withdrawals page, answer to What Are the Charges for Credit Card Deposits?

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

In the contract · clause 10.3

In the event that charges are imposed by the credit or debit Card Company (or any other provider) used to deposit funds on to your account, these may be charged by us to you.

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

03

The Arabic page repeats the free card deposit promise that clause 10.3 contradicts in both the English and the Arabic contract.

Said in public, in Arabic

تتحمّل آي سي إم جميع التكاليف المتعلقة بعمليات الإيداع التي تتم عبر البطاقات الائتمانية.

Word for word in English: ICM bears all the costs related to deposits made through credit cards.

Arabic deposits and withdrawals page, answer on credit card deposit charges

In the contract · clause 10.3

In the event that charges are imposed by the credit or debit Card Company (or any other provider) used to deposit funds on to your account, these may be charged by us to you.

04

A Full ECN platform sends orders to an outside market, while the execution policy makes ICM the only venue and describes a dealing desk.

Said in public, in English

With a Full ECN platform, ICM provides instant, stable execution and negative balance protection.

Partnership page, under the heading Cutting-Edge Technology

In the contract

ICM Capital is the sole execution venue for your trades placed via its internet portals or over the telephone.

What changed quietly

This is our first reading of ICM, so there is no earlier version of this page to compare it with.

  • ADDEDClause 3.11 · 2025-12-09 to 2026-08-27

    Section 3 ended at clause 3.10 in December 2025. The new clause lets two other companies handle your card payment.

    Card transactions may be processed by any of the associated independent representatives: ICM House AG, with registration number CHE-497.911.976 and registered address 4 Industriestrasse 24, 6300 Zug, Switzerland; or ICM Capital Limited, with registration number 07101360 and registered address The Leadenhall Building Level 30, 122 Leadenhall Street, London EC3V 4AB, England.

The documents this reading is based on

7 files, all published by ICM. 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 ICM publishes.

How this reading was done

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

This reading was published on .

Documents
4 of 7downloaded from the broker's site, and 4 read in full
Pages opened
22pages walked to find those documents, footer links included
Older copies
4earlier versions downloaded
Marketing pages
7public pages set against what the contract says
Languages
AR vs ENthe language it advertises in, against the language it contracts in
Position measured
15clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

ICM Capital Limited

You contract with ICM Capital Limited, registered in Mauritius under Financial Services Commission licence C118023357. The terms and conditions name it on the first page, and clause 26.3 confirms your relationship is with that company alone. The regulations page also lists ICM Limited in Abu Dhabi, ICM Mena Securities in Dubai and ICM House AG in Zurich. None of those three is your counterparty. A second, separately registered company also called ICM Capital Limited, UK number 07101360, appears in clause 3.11 as a card payment processor. A Saint Vincent contract for ICM Capital LLC sits on the same website, and the regulations page does not mention it.

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

ICM publishes all five legal documents in full Arabic as well as English. Most brokers translate the marketing and leave the contract in English only. The contract charges no inactivity fee at all. Clause 17.4 keeps unclaimed money as client money for six years, which is longer than most brokers allow. The AML policy also promises not to freeze client funds unless it suspects money laundering.

We read the terms and conditions, the AML and KYC policy, the order execution policy, the privacy policy and the risk disclosure in full. We also read the December 2025 terms and conditions from an archived copy, which is how we found the new card payment clause. We could not open three earlier copies: the December 2025 AML policy, the December 2025 privacy policy and the November 2025 order execution policy. Fingerprints for those three matched between December 2025 and February 2026, but we did not read them and cannot confirm they are unchanged today. ICM publishes the same five documents in Arabic. We checked the Arabic terms and conditions against the English one on fees and withdrawals only, and left the four other Arabic documents unread. We did not open the Malay, Thai, Indonesian or Spanish pages.

How to check any of this yourself

Every quote above links to the ICM 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 ICM 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 ICM 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 Aug 27, 2026.

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