The Persian version of the client agreement says PIPWISE combines your funds with other clients' funds. It may then use all of that pooled money to cover the default of any client. The English version contains no such clause.
Why this matters
Money you deposited can be spent on somebody else's loss, and you would have no way to know. The same Persian document promises, one paragraph above, that client funds are held separately.
Exhibit 1Every flagged clause gets its own number so you can point at this one. The number does not change, so a link to it keeps working.CriticalHow much this clause can cost you, in our reading. Critical can take your money or your profit. Warning can delay or limit it. Notice is simply worth knowing before you sign.Rarely seenHow ordinary this wording looks next to the contracts we read. This is our reading of the clause, not a count of other brokers.
مشتری درک میکند که شرکت وجوه خود را با وجوه دیگر مشتریان ترکیب کرده و این وجوه را در حساب بانکی مشتری نزد شرکت واریز میکند. مشتری متوجه است که شرکت ممکن است از تمامی وجوه واریز شده به حساب بانکی مشتری برای پوشش پیش فرض هر مشتری استفاده کند.
Firms licensed by the FCA and CySEC must keep retail client money separate from their own and may not use one client's money to meet another client's loss. The Persian agreement permits exactly that.
PIPWISE is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.
Our readingOur own comment on the clause, not the broker's words. Anything we quote is marked as a quotation.Pooling client money in one bank account is normal. A clause letting the firm apply all of that pooled money to any single client's default turns another person's loss into a claim on your balance.
- Same clause as Exhibit 9Both findings come from the same clause in the document.This pooling clause is the sharpest of the places where the Persian and English agreements say different things.

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