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Contract reading

What PKF Capital legally published, but does not want you to read

Every clause below is published by PKF Capital 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: PKF Capital Markets (Seychelles) Limited

sole discretionhidden feeclient moneydeemed acceptancemarketing gapaccount closurearbitrationburden of proofbusiness daycomplaint deadline

PKF Capital publishes six legal documents for its trading clients and not one price. Every fee, commission and margin requirement sits in a Rate Schedule, Product Schedule or Markets and Fees Schedule that is not on its website. One clause lets PKF Capital move your money out of the client trust account into an account its own documents say creditors could reach. You get one hour to query a trade, and no document says how long a withdrawal takes.

Contract risk

Money at risk
8.0/10

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.
8
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.
10
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.

Critical8
Warning10
Notice2

section 41 of 65is where the deepest clause sits, 63% 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 3 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 PKF Capital's own files

01

PKF Capital can move your money out of the segregated client account into what clause 26.1 calls a Buffer Account. The same clause says that account is not a trust account. Money sitting in it can be reached by the creditors of whoever holds it.

Why this matters

If the firm holding that buffer fails, your money sits in the queue with its other debts. PKF Capital alone decides how much to move, and the contract sets no ceiling.

Exhibit 1CriticalRarely seen

acknowledges and agrees that PKF Capital will withdraw funds from the PKF Capital bank account where Client Moneys are held (including, where relevant, the Segregated Funds Account) and deposit those funds in one or more Buffer Accounts;
Clause 26.1(b)(i) in PKF Capital Client Agreement (Margin), p.52
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus), ASIC (Australia)

Firms licensed by the FCA or CySEC must hold retail client money in a segregated trust account and may pay it away only in a short list of defined cases. Firms licensed by ASIC may not use a retail derivatives client's money to meet their own hedging obligations.

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

Our readingClient money normally leaves a trust account only to settle the client's own trades. This clause moves it out to post margin for PKF Capital's own hedging, in an amount PKF Capital picks, into an account the contract itself says is not a trust account.

  • Worse together with Exhibit 7One clause takes your cash out of the trust account, the other takes security over whatever is left.
02

PKF Capital keeps all its fees, commissions and margin requirements in three documents it calls the Rate Schedule, the Product Schedule and the Markets and Fees Schedule. Its own disclosure document says they are on its website. They are not there, and nothing else on pkf.sc shows a price.

Why this matters

You are agreeing to charges you cannot read before you deposit. The contract lets PKF Capital take each charge straight out of the account holding your money, whenever it falls due.

Exhibit 2CriticalHarder than usual

The most up-to-date versions are available from the PKF Capital website or by contacting us.
Clause 8 in Combined Financial Services Guide and Product Disclosure Statement (Margin), p.38
Downloaded from the broker's site on Open the reference
Our own capture of pkf.sc, taken on Oct 6, 2026The claim, on PKF Investment Platform page, opening paragraphVisit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus), ESMA (EU)

Firms licensed by the FCA or CySEC must give a retail client the costs and charges of a product before that client trades. PKF Capital's own risk statement tells you to ask it for written confirmation of every fee instead.

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

  • Worse together with Exhibit 11The daily markup on overnight positions is charged at a rate that lives in one of the unpublished schedules.
03

You are never entitled to a margin call from PKF Capital. The margin addendum says positions start closing automatically at a 100% risk level. The agreement adds that PKF Capital need not give you time to send funds first.

Why this matters

Your positions can be part closed at whatever price the market offers, with no warning you can rely on. The schedule puts the job of watching your margin on you, 24 hours a day.

Exhibit 3CriticalHarder than usual100%

The Client acknowledges and agrees that under no circumstances is it entitled to receive a margin demand, call or notice from PKF Capital.
Clause Schedule 7.2(c)(i) in PKF Capital Client Agreement (Margin), p.72
Read from the broker's site on Open the reference

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
80% margin usedA warning appears on the platform screen.Standard Margin Levels
100% risk levelPKF Capital closes part of your positions, oldest first, until margin use is back to 80%.Margin Breach Levels
Balance below zeroInterest runs daily on the shortfall at the bank cash base rate plus 15% a year.Remuneration and Costs (f)
  • Worse together with Exhibit 6A liquidation that does not catch the market leaves a debit balance, and the debit balance carries its own rate.
04

None of PKF Capital's contracts puts a deadline on paying your money out. The securities terms pay the balance on request, net of fees, once procedures including third party requirements are satisfied. The listed mandate promises a reasonable time and puts the cost of the transfer on you.

Why this matters

A payout you are waiting for has no date you can hold PKF Capital to. The margin agreement also lets PKF Capital hold the money while it treats a dispute with you as unresolved.

Exhibit 4CriticalHarder than usual

PKF shall, upon request by the Client and subject to clause 13.2, make payment to the Client of the balance standing to the credit of the Client in the Client Account net of any outstanding and/or applicable fees, subject to the satisfaction of the necessary procedures including but not limited to Third Party requirements.
Clause 13.3 in PKF Capital Markets (Seychelles) Limited Terms and Conditions, p.26
Read from the broker's site on Open the reference

Where it sits: section 18 of 65 in the PKF Capital Markets (Seychelles) Limited Terms and Conditions, 28% of the way through.

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

Firms licensed by the FCA or CySEC must pay a retail client's money back without undue delay and keep it available to that client meanwhile. These contracts set no outer limit at all.

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

05

You get one hour from receiving a trade confirmation to tell PKF Capital in writing that it is wrong. Miss it and clause 7.3 treats the confirmation as conclusive and binding, unless there is obvious error or fraud. PKF Capital gives itself three business days to raise the same kind of mistake.

In plain words

A manifest error means an obvious mistake by the broker.

Why this matters

A trade you notice the next morning is already final. The hour runs from when the confirmation reaches you, not from when you read it.

Exhibit 5CriticalRarely seen3 working days

The Client acknowledges and agrees that, if the Client believes that any Confirmation is not accurate, complete or correct, the Client must notify PKF Capital in writing within one hour of the time of receipt of the relevant Confirmation.
Clause 7.3(c)(ii) in PKF Capital Client Agreement (Margin), p.22
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must accept a retail complaint under a published procedure and keep the file for years afterwards. This contract closes the question in one hour.

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

Our readingComplaint windows in retail agreements are normally counted in days or months. This one is counted in minutes, and it starts when the confirmation is made available to you rather than when you see it.

PKF Capital publishes six trading documents and no prices

Three schedules carry every fee PKF Capital charges, and none of them is on pkf.sc. The contracts still let PKF Capital take each charge from the account holding your money, the moment it falls due. A debit balance runs at the bank cash base rate plus 15% a year. Every overnight position carries a markup PKF Capital sets itself.

Cost disclosure3 clauses flagged

PKF Capital charges the bank cash base rate plus 15% a year, accruing daily, on an account that goes into debit. Its disclosure document says margin trading can lose you substantially more than 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

You can end up owing PKF Capital money after a bad move, and that debt grows daily until you pay. Nothing in these documents writes off a negative balance.

Exhibit 6CriticalHarder than usual15%

PKF Capital will charge an overdrawn rate on each debit currency balance that will be at the prevailing bank cash base rate plus 15% per annum (accruing daily).
Clause Remuneration and Costs (f) in Combined Financial Services Guide and Product Disclosure Statement (Margin), p.8
Downloaded from the broker's site on Open the reference

What it costsOn a $1,000 debit balance the 15% part alone adds $150 over a year, before the bank base rate on top.

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

Firms licensed by the FCA or CySEC must give retail clients negative balance protection, so a client cannot lose more than the money in the account. These documents put the shortfall on you and price it.

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

Every position open at the close gets rolled over. PKF Capital then takes what its schedule calls Rollover Enhancement Income, the amount charged to you above its own wholesale cost. The money leaves the segregated account right after the close.

Why this matters

Holding a position for a week means paying that markup seven times, at a rate PKF Capital sets and publishes nowhere. Nothing in the documents caps it.

Exhibit 11WarningHarder than usual

The Client acknowledges and agrees that PKF Capital derives income ("Rollover Enhancement Income") when a Margin Transaction is rolled, being the cost or charge to the Client over and above the cost to PKF Capital of re-establishing a Margin Transaction at Close of Business in the wholesale market.
Clause Schedule 5.1(d) in PKF Capital Client Agreement (Margin), p.68
Read from the broker's site on Open the reference

PKF Capital can charge a fee it deems appropriate for a stop loss order, and take it from the segregated account the moment the order is placed. No rate is published. Its own risk statement says a stop loss may not hold at your price.

Why this matters

You pay an amount PKF Capital chooses for protection it does not guarantee. The fee leaves your money before you know whether the order ever works.

Exhibit 12WarningHarder than usual

PKF Capital may charge a fee it deems appropriate for the Stop Loss Order.
Clause Schedule 8.1(a)(ii) in PKF Capital Client Agreement (Margin), p.72
Read from the broker's site on Open the reference

PKF Capital can close your positions and sell your assets without asking

You are never entitled to a margin call, and positions start closing at a 100% risk level. The securities terms give PKF Capital a lien over every asset it holds for you, and the right to sell it. Fee schedules change the moment PKF Capital posts them, and a day out of contact counts as a default.

Firm discretion3 clauses flagged

The securities terms give PKF Capital a lien and a right of disposal over every asset it holds for you, at PKF Capital or elsewhere. That includes assets it holds in a fiduciary capacity. It can sell in its own name and set the proceeds against anything you owe now or later.

Why this matters

Your shares can be sold to cover a claim PKF Capital says you owe. On the listed mandate that can happen five days after a demand. PKF Capital can also require your holdings to leave custody at any time, without giving a reason.

Exhibit 7CriticalRarely seen5 days

PKF shall have a right of lien or security interest and a right of disposal over all assets held at PKF or elsewhere for the account of the Client and on all rights which it holds in a fiduciary capacity for the account of the Client, insofar as permitted by law.
Clause 17.1 in PKF Capital Markets (Seychelles) Limited Terms and Conditions, p.29
Read from the broker's site on Open the reference

Where it sits: section 21 of 65 in the PKF Capital Markets (Seychelles) Limited Terms and Conditions, 32% of the way through.

Our readingA general lien over all of a client's assets, with a right to sell them in the firm's own name, belongs to bank lending. Pointed at a retail securities account it turns your holdings into security for claims that have not been tested.

PKF Capital can change the Rate Schedule, Product Schedule and Margin Platform Addendum whenever it likes, and each change bites as soon as it is posted. Checking for changes is your job. The securities terms give 30 days notice for the main agreement and treat your silence as acceptance.

Why this matters

A charge can rise while your position is open, with no message to you. Leaving a trade open overnight counts as accepting the new terms.

Exhibit 16WarningHarder than usual30 days

Amendments to the Margin Platform Addendum, Product Schedule and the Rates Schedule can happen very regularly, and any amendment to any of these documents is effective immediately upon being posted on PKF Capital's website or a Trading Platform.
Clause 10 in Combined Financial Services Guide and Product Disclosure Statement (Margin), p.43
Downloaded from the broker's site on Open the reference

If PKF Capital cannot reach you for 24 hours when it wants instructions, that is an event of default under both trading contracts. On the margin agreement a default lets PKF Capital close out your positions.

Why this matters

A holiday without signal can put you in default while your positions are open. You do not have to miss a payment or break a rule for this one.

Exhibit 18WarningRarely seen

in the absence of the Client making alternative arrangements, the Client is not contactable by PKF Capital for any period of 24 hours in order for PKF Capital to obtain instructions relating to any Transaction, any order or any obligations of the Client under this Agreement or any Transaction
Clause 18.1(i) in PKF Capital Client Agreement (Margin), p.39
Read from the broker's site on Open the reference

Our readingAn event of default is normally a missed payment, a breach or an insolvency. Here it includes a day of silence, which the client may not even know has started.

One hour to query a trade, and arbitration if you want more

Clause 7.3 gives you one hour to challenge a trade confirmation before PKF Capital treats it as binding. PKF Capital gives itself three business days for the same kind of error. Its own certificate of what you owe counts as conclusive evidence, and a dispute it will not settle goes to arbitration in Seychelles.

Challenge windows3 clauses flagged

The securities terms make you cover PKF Capital against claims for loss you suffer on your own trades. The exceptions are its fraud, dishonesty or gross negligence. A separate clause says you may not require proof or evidence of any actual loss.

In plain words

Indemnities are money it says you owe it.

Why this matters

A demand under that cover can be made without showing what PKF Capital lost. The margin agreement extends the same cover to losses caused when PKF Capital closes out your trades.

Exhibit 8CriticalRarely seen

PKF shall not be liable for, and the Client hereby indemnifies PKF against, any claims for loss, expense or damage which the Client may suffer, howsoever such loss, expense or damage may arise or be suffered, in respect of the Transactions concluded by the Client.
Clause 25.1 in PKF Capital Markets (Seychelles) Limited Terms and Conditions, p.38
Read from the broker's site on Open the reference

Our readingA firm claiming under an indemnity normally has to show the loss it is claiming for. These clauses remove that step by agreement, so the amount demanded is simply the amount stated.

A certificate from PKF Capital of any amount payable counts as conclusive evidence under clause 37.1, unless you can show obvious error or fraud. Its platform records are treated as accurate, and you carry the burden of proving otherwise.

Why this matters

Arguing about a debit means proving PKF Capital's own record wrong, with that record already counted as proof. On the listed side a signed note from any director is accepted without proof of who signed it.

Exhibit 9WarningHarder than usual

A certificate by PKF Capital of any amount payable under this Agreement or any Transaction is, in the absence of manifest error or fraud, conclusive evidence for all purposes, including for any proceedings.
Clause 37.1 in PKF Capital Client Agreement (Margin), p.65
Read from the broker's site on Open the reference

Where it sits: section 33 of 65 in the PKF Capital Client Agreement (Margin), 51% of the way through.

PKF Capital names no ombudsman and no compensation scheme. Its disclosure document sends you to the regulator, and the complaints procedure itself is only available if you ask for it. The three trading contracts point at three different arbitration regimes, one of them a tribunal of three arbitrators.

Why this matters

Pursuing PKF Capital means arbitration seated in Seychelles, paid for by you. For most clients the cost of the forum is larger than the sum in dispute.

Exhibit 10WarningHarder than usual3

A copy of these procedures may be obtained by contacting us and requesting a copy.
Clause What do I do if I have a complaint? in Combined Financial Services Guide and Product Disclosure Statement (Margin), p.10
Downloaded from the broker's site on Open the reference

Buried at section 41 of 65 in the Combined Financial Services Guide and Product Disclosure Statement (Margin), 63% of the way through.

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

Firms licensed by the FCA or CySEC give a retail client access to an independent ombudsman, and to a compensation scheme if the firm fails. PKF Capital's documents name neither.

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

The hedging promise is in the disclosure, not in the contract

PKF Capital's disclosure document says it always hedges every client position and never trades against its clients. The client agreement only says it may hedge from time to time, and makes PKF Capital the price maker. The listed mandate still runs on the rules of Trop-x, an exchange the home page no longer names.

Promise against contract2 clauses flagged

PKF Capital's disclosure document says it always hedges every client position at the time of the trade and never trades against its clients. The client agreement only says it may hedge from time to time, and names PKF Capital the price maker.

Why this matters

Nothing you sign obliges PKF Capital to put your trade into the market. The price you deal at is PKF Capital's own, and the contract says other firms' prices do not apply.

Exhibit 14WarningHarder than usual

PKF Capital acts under this Agreement as a price maker;
Clause 7.1(b)(i) in PKF Capital Client Agreement (Margin), p.22
Read from the broker's site on Open the reference

The listed trading mandate is written on the rules of Trop-x and ends automatically if PKF Capital stops being a Trop-x member. The home page names SECDEX and MERJ instead. Its fee schedules point to Trop-X, AfriClear and AfriDep pages that are not on the site.

Why this matters

The rules deciding how your shares are held and charged for belong to an exchange PKF Capital does not claim to belong to. Clause 12 makes that membership the condition for your mandate existing at all.

Exhibit 15WarningRarely seen

Subject to that set out above, if PKF Capital for any reason ceases to be a member of Trop-x and/or ceases to be authorised by the Financial Services Authority (FSA) of the Seychelles to manage investments in the manner described in this mandate, this mandate shall automatically terminate with immediate effect.
Clause 12 in Client Agreement: Listed Non-Discretionary, p.2
Read from the broker's site on Open the reference

Where it sits: section 24 of 65 in the Client Agreement: Listed Non-Discretionary, 37% of the way through.

Our readingAn automatic termination clause keyed to membership of a named exchange is ordinary. What is unusual is that the exchange named in the mandate appears nowhere in PKF Capital's current description of itself.

PKF Capital can invest your deposit before it finishes checking you

Clause 9.6 lets PKF Capital take your deposit and buy securities while due diligence is still open. If onboarding fails, the refund comes net of fees and the securities may be hard to sell. PKF Capital accepts no liability for the delay, and a payment from anyone else's bank account is returned net of fees.

Onboarding risk1 clause flagged

PKF Capital can accept your deposit and buy securities while your due diligence is still running. If onboarding then fails, the refund comes net of fees and the securities may be hard to sell. PKF Capital accepts no liability for the delay.

Why this matters

Your deposit can be at market risk before PKF Capital has even accepted you as a client. A payment from an account in anyone else's name is returned net of fees and can get your account suspended.

Exhibit 17WarningHarder than usual

In the case of securities held, the securities may be illiquid and the time to liquidate these securities may be significant. PKF shall not be held liable for any delay in the refund of cash in this instance.
Clause 9.6 in PKF Capital Markets (Seychelles) Limited Terms and Conditions, p.24
Read from the broker's site on Open the reference

PKF Capital can move your money to fund its own hedging

Clause 26.1 lets PKF Capital take client money from the segregated account into a buffer account it says is not a trust account. The amount is whatever PKF Capital decides it needs for margin and what the clause calls a substantial additional buffer. PKF Capital is also paid by those same hedging counterparties on the volume of business it sends them.

Whose side the firm is on1 clause flagged

PKF Capital is paid by its hedging counterparties on the volume of business sent to them, and higher volume means a higher payment. The securities terms say only the third party must tell you about such payments. PKF Capital is under no such duty.

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.

Remuneration means payments it receives.

Why this matters

The firm quoting your price earns more the more you trade, and it does not have to tell you how much. Introducing brokers are paid out of the same charges, on your trade volume and frequency.

Exhibit 13WarningHarder than usual

PKF Capital is reimbursed an amount of income from its hedging counterparties, which is based upon the volume of transactions executed with that counterparty. Higher volume generally relates to a higher reimbursement.
Clause Remuneration and Costs (b) in Combined Financial Services Guide and Product Disclosure Statement (Margin), p.7
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus), ESMA (EU)

Firms licensed by the FCA or CySEC must tell a retail client about any payment they take from a third party in connection with that client's business. These documents put the duty on the third party instead.

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

A Seychelles contract that counts business days in Auckland

The margin agreement defines a business day by whether banks are open in Auckland, and sets trading hours from 7am New Zealand time. Seychelles law governs and Seychelles courts have jurisdiction. Every notice period and payment date in the contract runs on that New Zealand calendar.

Where the clock runs1 clause flagged

The margin agreement counts a business day as a day banks are open in Auckland. Normal trading hours start at 7am New Zealand time. Seychelles law governs the contract.

Why this matters

A deadline in this contract can land on a day Seychelles banks are closed. A New Zealand public holiday can move it.

Exhibit 20NoticeRarely seen

a day (not being a Saturday or Sunday) on which banks and foreign exchange markets are open for business in Auckland
Clause 1.1 in PKF Capital Client Agreement (Margin), p.3
Read from the broker's site on Open the reference

Our readingA Seychelles contract would normally count business days where the firm or the client is. This one counts them in New Zealand, a country the agreement otherwise has nothing to do with.

PKF Capital Markets (Seychelles) Limited holds licence SD001 and names no compensation scheme

A trading client contracts with PKF Capital Markets (Seychelles) Limited, company number 8410175-1, licensed by the Seychelles Financial Services Authority as a securities dealer. Client money is pooled, and the disclosure document says a default by another client in that account can reach yours. No document names a compensation scheme or an ombudsman.

Who you are dealing with1 clause flagged

A trading client contracts with PKF Capital Markets (Seychelles) Limited, company number 8410175-1, holder of Securities Dealer Licence SD001. Client money is pooled in one account. No document names a compensation scheme or an ombudsman.

Why this matters

A shortfall caused by another client in that pooled account can reach your balance, as the disclosure document admits. If PKF Capital fails, no scheme named in these documents pays you back.

Exhibit 19NoticeStandard wording

Client Money of the Client is pooled with client money of other clients of PKF Capital;
Clause 10.2(b) in PKF Capital Client Agreement (Margin), p.28
Read from the broker's site on Open the reference

Where the marketing and the contract disagree

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

01

The disclosure document says client funds are out of reach of general creditors, while the client agreement moves them into an account where creditors can reach them.

Said in public, in English

In brief, this means that those funds are not available to pay general creditors in the event of receivership or liquidation by PKF Capital.

Combined Financial Services Guide and Product Disclosure Statement (Margin), section 16, How We Handle Your Money, page 55

In the contract · clause 26.1(b)(ii)

each Buffer Account is not a trust account or a segregated funds account, such that any funds in that account may, subject to Applicable Law, be available to the creditors generally of the account holder

02

The disclosure document promises every position is always hedged, while the contract makes hedging something PKF Capital may do from time to time.

Said in public, in English

PKF Capital always hedges every position it has with its clients at the time the trade is executed and does not run its own positions and does not trade against its clients.

Combined Financial Services Guide and Product Disclosure Statement (Margin), section 11, Liquidity Buffers, page 46

In the contract · clause 26.1(a)

From time to time, PKF Capital may effect hedging and other transactions with or through third parties, including its Associates, in order to hedge its exposure under this Agreement and Transactions.

03

The currency page offers pricing from many leading banks, while the contract says other firms' prices do not apply to your dealings.

Said in public, in English

Best quote pricing from the world’s leading FX banks – not limited to the rates of a single bank or provider

Deliverable FX page, Our clients benefit from

In the contract · clause 7.1(b)(iii)

accordingly, by reason of PKF Capital’s Preferred Side, prices and rates that may be quoted and/or traded upon from time to time by other price and/or market makers or third parties do not apply to Transactions and dealings between PKF Capital and the Client.

04

The home page names SECDEX and MERJ, while the mandate a listed client signs depends on membership of Trop-x.

Said in public, in English

The firm is a member of the SECDEX Stock Exchange and a registered Sponsor Advisor for companies listed or seeking listing on MERJ Exchange and SECDEX Exchange in Seychelles.

home page, Welcome to PKF Seychelles

In the contract · clause 12

Subject to that set out above, if PKF Capital for any reason ceases to be a member of Trop-x and/or ceases to be authorised by the Financial Services Authority (FSA) of the Seychelles to manage investments in the manner described in this mandate, this mandate shall automatically terminate with immediate effect.

05

PKF Capital sells the platform on low cost while the schedule holding its actual fees is not on the website it points to.

Said in public, in English

PKF’s Investment Platform leverages technology to provide clients with the ability to design their own portfolio through an innovative online investment tool whilst avoiding the heavy costs associated with traditional fund managers.

PKF Investment Platform page, opening paragraph

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

In the contract · clause 10.1

are set out in the applicable Markets and Fees Schedule as furnished via the Website or as otherwise notified by PKF and/or its Associates to the Client or its clients generally.

The documents this reading is based on

10 files, all published by PKF Capital. 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 PKF Capital publishes.

How this reading was done

Every clause above was read out of a document PKF Capital publishes itself

This reading was published on .

Documents
8 of 10downloaded from the broker's site, and 8 read in full
Pages opened
52pages walked to find those documents, footer links included
Older copies
2earlier versions downloaded, 2 identical to the copy we hold by fingerprint
Marketing pages
6public pages set against what the contract says
Position measured
5clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

PKF Capital Markets (Seychelles) Limited

A trading client contracts with PKF Capital Markets (Seychelles) Limited, company number 8410175-1, which its own client agreement identifies as the holder of Securities Dealer Licence SD001. The same website publishes corporate services terms for two other companies, International Investment Services Limited and PKF Corporate Services Limited, and its card payment page sends you to iisoffshore.com. The KYC guide carries a footer saying PKF International Limited does not accept responsibility for the actions of any member firm. Read the entity name on the document you are signing, because only one of those companies is your broker.

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

No inactivity fee, no dormancy ladder and no bonus scheme appears anywhere in the documents we read. The Margin Platform Addendum states the stop out levels in plain numbers, 80% for a warning and 100% for liquidation, which most offshore brokers never publish. The 2017 disclosure document is unusually frank: it says margin trading can lose you more than your deposit, it admits a default by another client in the pooled account can reach your money, and it states there is no cooling off period. The February 2022 terms give 30 days notice before an amendment takes effect and promise monthly statements.

We could not open the PKF Corporate Services Limited terms, so we did not read it. We read the costs, margin, client money, complaints and amendment sections of the 64 page margin disclosure document, not every page of it. The three schedules that carry the actual numbers, the Rate Schedule, the Product Schedule and the Markets and Fees Schedule, are not published, so the fees themselves cannot be read by anyone outside the firm. The trading platform sits behind a login, so we could not see what a client sees after depositing. PKF Capital publishes in English only, so there was no translated promise to hold against an English contract. The two earlier copies available for comparison are identical to the files PKF Capital serves today.

How to check any of this yourself

Every quote above links to the PKF Capital 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 PKF Capital 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 PKF Capital 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 6, 2026.

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

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