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Contract reading

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

Every clause below is published by SinoSound 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: Sino Sound Holdings Limited

sole discretionhidden feemarketing gapdeemed acceptancewithdrawalscomplaint windowforum waiverkyc freezerisk controlsunilateral amendment

SinoSound keeps 6% of a withdrawal if you have not traded 30% of your last deposit. Its contract lets it lend your money to itself, deduct profit it suspects, and treat your silence after two days as agreement. The English FAQ promises no slippage, scalping and fully protected funds. The agreement it asks you to sign says the opposite on all three.

Back to SinoSound

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.
6
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
23
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
8
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
14

How the 23 break downThe same flagged clauses, split by how much each one can cost you. Severity is our reading of the clause, not the broker's label.

Critical6
Warning15
Notice2

section 55 of 67is where the deepest clause sits, 82% 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.

4 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.

Critical6%Fee you were not shown. Jump to the clause this comes from.6% taken from your withdrawal if you barely tradeCritical2 daysTime to complain. Jump to the clause this comes from.Two days to object or the statement becomes finalCritical3%In the contract. Jump to the clause this comes from.Loss capped at your balance in the FAQ onlyCritical$5Fee on an unused account. Jump to the clause this comes from.Five dollars a month until the balance reaches zero

What the documents say

23 clauses worth knowing about, worst first, each quoted from SinoSound's own files

01

Withdraw money without trading at least 30% of your last deposit, and SinoSound keeps 6% of what you take out. Withdraw without ever placing a trade and it closes the account as well.

Why this matters

A $1,000 withdrawal arrives as $940, and the company's own example uses exactly that figure. The charge is for your own money coming back, not for a service.

Exhibit 1CriticalRarely seen6%

Withdrawals are generally free. Fees apply if: 1. Trading volume is less than 30% of the latest deposit (minimum 6% administrative fee).
Clause Important Notes 1 in Trading Rules & Specifications (English)
Read from the broker's site on Open the reference
Our own capture of gold2u.net, taken on Oct 4, 20266% taken from your withdrawal if you barely trade (clause Important Notes 1)Visit this page on the broker's siteDownload the full size image file

What it costsA $10,000 deposit, less than $3,000 of it used as margin, then a $1,000 withdrawal costs $60. SinoSound prints that same example on its own FAQ page.

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

Firms licensed by the FCA and CySEC have to show a retail client all costs and charges before they trade. SinoSound tells you withdrawals are generally free, then names the 6% in a note under the fee table.

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

Our readingA withdrawal fee usually pays for a transfer. This one is a penalty for not trading. Both language versions call 6% a minimum, and no ceiling appears anywhere.

02

SinoSound can pledge your money, pledge it again, invest it or lend it to itself. Its client agreement asks you to authorise that, while its FAQ tells you client funds are fully protected.

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

If SinoSound runs into trouble while your balance sits with somebody else, you join the queue of creditors. Its own risk warning says recovering deposited money depends on local law and can take a long time.

Exhibit 2CriticalRarely seen

客戶亦授權漢聲以單獨地或者與其他客戶的財產一起的形式，將客戶作為保證金或擔保物的任何財產進行抵押、再抵押、投資或出借於漢聲自身或其他方。
Clause 14Read the source

Buried at section 41 of 67 in the Client Agreement (English), 61% of the way through.

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 segregated accounts and must not use it for their own account. This contract asks you to authorise the opposite.

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

Our readingA general lien plus a right to lend client assets to the firm itself belongs in commercial broking. Pointed at a retail gold account, it means your margin can fund the company holding it.

  • Worse together with Exhibit 23No regulator sets a client money rule here, and the contract lets the firm lend what it holds.
03

If SinoSound suspects your trading is arbitrage or manipulation, it can deduct the profit from that trading, cancel the trades and close your account. It can also freeze your withdrawals until the matter is fully resolved, with no deadline on that.

Why this matters

Opening and closing positions quickly is enough to put you in this category, and the contract never defines how quick is too quick. Your money stays with SinoSound while it decides, and it decides alone.

Exhibit 3CriticalHarder than usual

若漢聲懷疑任何客戶或賬戶從事操控，漢聲保留對該客戶或有關賬戶進行調查及審核等的相關權利，並從涉嫌賬戶中扣除由相關活動所賺取的盈利款項。
Clause 13Read the source
Our own capture of gold2u.net, taken on Oct 4, 2026The claim, on English FAQ, Trading tab, answer on what counts as normal tradingThis 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

Buried at section 40 of 67 in the Client Agreement (English), 60% of the way through.

  • Worse together with Exhibit 7A frozen withdrawal sits behind a review that has no deadline, so the money waits twice.
  • Worse together with Exhibit 20The same undefined abnormal trading that voids profit also cancels your promotion reward.
04

Your statements count as correct, final and binding unless you object in writing within two days of delivery. SinoSound counts a notice as delivered whether or not you actually receive it.

Why this matters

Query a wrong fill or an unexpected fee on the third day and the contract treats you as having agreed to it. The clock runs from delivery, not from the day you read the statement.

Exhibit 4CriticalHarder than usual2 days

訂單的確認報告（如日結單、月結單等）和客戶的賬戶報表將被視作正確、終結、並對客戶具有約束力，除非客戶在收到漢聲網上交易平臺或其他方式送達的報告兩日之內立即作出書面反對。
Clause 22Read the source

Buried at section 49 of 67 in the Client Agreement (English), 73% of the way through.

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

Firms licensed by the FCA and CySEC must acknowledge a retail complaint and investigate it, with weeks allowed for that work. This contract gives you two days before a statement binds you.

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

  • Worse together with Exhibit 19Past the two days, the only route left is arbitration in Hong Kong conducted in English.
05

SinoSound tells you in its FAQ that a price gap can only cost you the money in your account. Clause 8 of its agreement says your loss may exceed everything in the account. Clause 10 then makes you liable for the shortfall, plus interest at the prime rate plus 3%.

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 weekend gap can leave you owing SinoSound money on top of what you put in. The FAQ says it usually does not chase that debt, and usually is not a term of the contract.

Exhibit 5CriticalHarder than usual3%

The Client agrees to bear all losses resulting from failure to meet margin calls in time, which may exceed the Client's initial margin, i.e., all funds in the account.
Clause 8 in Client Agreement (English)
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 37 of 67 in the Client Agreement (English), 55% of the way through.

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

Firms licensed by the FCA or CySEC, and firms under ESMA rules, must give retail clients negative balance protection, so a client cannot lose more than the account holds. This contract makes you liable for the deficit and charges interest on it.

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

06

Leave the account alone for three months with money in it, and SinoSound charges $5 a month for platform maintenance. The Chinese rules keep the charge running until the balance is zero, then mark the account dormant.

Why this matters

You cannot withdraw less than US$100 in dollars or Hong Kong dollars. A $60 remainder cannot leave, and the monthly fee eats it.

Exhibit 6CriticalHarder than usual$5

Accounts with no trading, deposit, or withdrawal activity for over three months will be charged a USD 5 monthly platform maintenance fee until the balance reaches zero.
Clause Important Notes 6 in Trading Rules & Specifications (English)
Read from the broker's site on Open the reference
Our own capture of gold2u.net, taken on Oct 4, 2026Five dollars a month until the balance reaches zero (clause Important Notes 6)Visit this page on the broker's siteDownload the full size image file

What it costsA $40 balance left idle for three months is gone after eight monthly charges of $5.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Three months with no trade, deposit or withdrawalSinoSound starts charging $5 a month for platform maintenance.6
Every month after thatIt takes another $5 from whatever is left.6
Balance reaches zeroThe company marks the account dormant.6
To use the account againYou have to apply to SinoSound to restore it.6
  • Worse together with Exhibit 7A balance under US$100 cannot be withdrawn in dollars, and the monthly fee keeps taking from it.

The FAQ answers and the agreement do not match

SinoSound's English FAQ promises losses limited to your account balance, no slippage, instant fills for scalping and no extra charges. The agreement makes you liable for a deficit plus interest at the prime rate plus 3%. It prohibits scalping and lets the firm charge fees without notice. The FAQ also says the product has no minimum, while the risk disclosure says it suits professional investors only.

Promise against contract3 clauses flagged

SinoSound's FAQ says a gold buy breaks even when the price rises 50 cents an ounce. That covers the $0.50 spread and nothing else. The same page charges $50 a lot in commission, which doubles the move you need.

Why this matters

One lot of gold is 100 ounces, so the spread costs $50 and the commission costs $50. Gold has to rise a full dollar an ounce before your trade is level.

Exhibit 10WarningHarder than usual$50

A buy order breaks even when price rises by 0.50 (Gold) or 0.05 (Silver) per ounce.
Clause Trading Procedures FAQ in FAQs (English)
Read from the broker's site on Open the reference

What it costsA one lot buy of London Gold starts $100 behind: $50 of spread and $50 of commission. The price has to rise $1.00 an ounce to cover it.

The risk disclosure says this product suits professional institutions or experienced investors who can absorb losses far beyond their deposit. The FAQ says there is no minimum threshold and that opening an account takes two minutes.

Why this matters

You sign a warranty that you have enough experience and money to carry the risk. No test of that appears anywhere on the site, and a $388 first deposit earns a gift.

Exhibit 21WarningHarder than usual$388

OTCGOLD交易僅適合專業機構或投資經驗豐富的人士，其財政狀況能夠承受也許遠超過保證金或存款金價值的損失。
Clause 風險披露聲明 2

Where it sits: section 7 of 67 in the Client Agreement (English), near the start.

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

Firms licensed by the FCA or CySEC must run an appropriateness test before selling a complex leveraged product to a retail client. SinoSound asks you to warrant your own experience instead.

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

The English FAQ says SinoSound supports Alipay, WeChat Pay, bank cards and USDT. The Chinese FAQ says its online payment system does not include Alipay.

Why this matters

Pick a deposit route from the wrong page and it is not there when you try. Only the English page mentions paying in USDT, and no legal document on the site mentions crypto at all.

Exhibit 22NoticeHarder than usual

Yes. We currently support Alipay, WeChat Pay, bank cards, and USDT.
Clause Deposits/Withdrawals FAQ in FAQs (English)
Read from the broker's site on Open the reference

The fee that costs most is the one for not trading

SinoSound keeps 6% of a withdrawal when the margin you used since your last deposit is under 30% of it. Its fee clause lets it charge statement fees, idle account fees and cancellation fees without prior notice, and prints no prices. The overnight financing rate appears on the site twice, as 2.5% and as 2.75%.

Cost disclosure4 clauses flagged

The fee clause lets SinoSound take statement fees, idle account fees, order cancellation fees and transfer fees out of your account. The same clause says it may charge commissions, fees and charges without prior notice, and it prints no amount for any of them.

Why this matters

You cannot work out what an account costs from the contract, because the contract names the fees and not the prices. The agreement also disagrees with itself: the introducing broker section promises you prior notice of any commission or fee.

Exhibit 8WarningHarder than usual

漢聲可能不經通知收取傭金、費用及/或收費。
Clause 11

Where it sits: section 38 of 67 in the Client Agreement (English), 57% 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. This clause lets SinoSound introduce a charge and deduct it with no notice at all.

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

The trading rules page charges 2.75% a year to hold a long gold position overnight. The FAQ on the same site says 2.5% and works its example at that rate. Nothing says which one your account pays.

Why this matters

One lot of gold bought at $3,000 costs $20.83 a night at the FAQ rate and $22.92 at the rules page rate. Hold it for a month and that gap is $62.50 you could not predict.

Exhibit 9WarningHarder than usual2.75%

Buy -2.75%, Sell 0.25%
Clause Overnight Interest (Swap) in Trading Rules & Specifications (English)
Read from the broker's site on Open the reference
Our own capture of gold2u.net, taken on Oct 4, 2026The claim, on English FAQ, Trading Procedures tab, answer on the overnight feeThis 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
Our own capture of gold2u.net, taken on Oct 4, 2026What the contract says, clause Overnight Interest (Swap)Visit this page on the broker's siteDownload the full size image file

What it costsOne lot of gold at $3,000 costs $20.83 for one night at 2.5%, the figure the FAQ calculates itself. At 2.75% the same night costs $22.92.

The published gold spread is $0.50 an ounce, which is $50 on one lot. SinoSound reserves the right to adjust that spread at any time without prior notice. The Chinese version adds that the company alone decides and interprets the spread it charges.

Why this matters

The firm on the other side of your trade sets your entry cost, and can move it without telling you first. The English version of the page leaves out the sentence on who interprets the charge.

Exhibit 11WarningHarder than usual$0.5

Standard spreads apply under normal conditions. Spreads may widen during periods of high volatility or important data releases. The Company reserves the right to adjust spreads at any time without prior notice.
Clause Important Notes 2 in Trading Rules & Specifications (English)
Read from the broker's site on Open the reference

SinoSound converts your deposit at one rate and your withdrawal at another, both set by a payment provider each morning. It admits there is a spread between the two and publishes no figure for it.

Why this matters

Money that goes in and comes out without a single trade still comes back smaller. The agreement puts every exchange rate difference on you, and lets SinoSound convert currency whenever it decides to.

Exhibit 12WarningHarder than usual

No. Both rates are provided daily by our third-party payment provider around 10:00 AM, and there is a spread between them.
Clause Deposits/Withdrawals FAQ in FAQs (English)
Read from the broker's site on Open the reference

Your money leaves the balance before it leaves the company

SinoSound accepts a withdrawal only after reviewing and approving every field in your portal, with no deadline on that review. You get one request a day, inside Hong Kong office hours, and you cannot cancel it. After approval the published timetable is fast, with money out on the first working day.

Exit conditions1 clause flagged

SinoSound accepts a withdrawal request only after it has reviewed and approved all the information in your portal. You can ask once a day, during Hong Kong office hours, and you cannot cancel a request once it is in.

Why this matters

Nothing in the contract puts a time limit on that review, and you agreed not to hold SinoSound liable for a slow withdrawal. The money leaves your balance the moment the request is confirmed.

Exhibit 7WarningHarder than usual$100

The Client agrees not to hold SinoSound liable for any failure to process the withdrawal request in a timely manner.
Clause 8 in Client Agreement (English)
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 35 of 67 in the Client Agreement (English), 52% of the way through.

The referral reward is paid out of your friends' commission

SinoSound pays $15 for every 2.5 lots a referred friend trades, up to $210 a friend inside 30 days. At the published $50 a lot, that friend pays $1,750 in commission for the referrer to collect $210. Cash rewards can be withdrawn once paid, and SinoSound keeps the final say on who qualifies.

Promotion terms1 clause flagged

SinoSound advertises gifts and cash worth over $600 for referring friends. Collecting it takes three friends trading 35 lots each within 30 days, at $15 for every 2.5 lots traded.

Why this matters

Your friends pay for your reward. 105 lots of gold costs $5,250 in commission at the published $50 a lot, and the referrer collects $630 of it.

Exhibit 20WarningHarder than usual$210

每位好友在成功開戶30天有效期內，每交易2.5手，推薦人可獲得15美元“交易獎”，最高可獎勵210美元。
Clause 活動細則 三【交易獎】①

What it costsThree friends at 35 lots each pay $5,250 in commission at $50 a lot. The referrer receives $630.

The protections you set can be removed before you need them

SinoSound's Chinese rules cancel every pending order each week, stop loss and take profit included, before the weekend close. Over a weekend the stop-out becomes equity under $6,000 a lot instead of 30% of margin, and the company raised that figure in April 2026 with one day of notice. It can also close your positions with no notice where it decides protective measures are needed.

Platform control4 clauses flagged

The Chinese trading rules say all pending order settings, stop loss and take profit included, last only for the current week. The system cancels them before the weekend and before holidays, and you have to set them again.

Why this matters

A position you left protected on Friday is unprotected when the market gaps on Monday. The English version of the same page mentions pending orders and leaves stop loss and take profit out.

Exhibit 13WarningRarely seen

本公司交易平台上所有掛單設置（包括掛單及止損止盈）的默認期限為當週有效，週末或國際節假日休市前，系統會自動取消所有未執行的掛單設置，客戶可于開市後重新設置，或在交易時間內進行修改或刪除設置。
Clause 注意事項 3

Our readingOn MT4 a stop loss belongs to the position and stays until it is hit or you remove it. Clearing every stop and target at the weekly close puts the job of re-arming your own protection back on you.

  • Worse together with Exhibit 14Your stop is cancelled on Friday, and the weekend stop-out level is the one that then applies.

During the week SinoSound closes all your positions when equity falls to 30% of the opening margin. Over a weekend or holiday the trigger is equity below $6,000 a lot. On one lot of gold at $3,000 that is the entire opening margin.

Why this matters

Equity that is comfortably safe on Thursday can be a closing event on Friday evening. SinoSound raised this figure in April 2026 with one day of notice, and its agreement lets it raise margin with no reason given.

Exhibit 14WarningHarder than usual$6000

During holidays and weekends, forced liquidation occurs when equity is below USD 6,000 per lot.
Clause Forced Liquidation in Trading Rules & Specifications (English)
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
In the trading weekAll positions close when equity falls to 30% of the opening margin.Forced Liquidation
Before the weekend closeThe system cancels every unexecuted pending order.Important Notes 3
Over a weekend or holidayPositions close when equity drops below $6,000 a lot.Forced Liquidation
On a gapping openAll orders fill at the opening price, whatever level you set.Overnight / Holiday Margin Requirement

SinoSound can liquidate your positions, cancel your orders and take a lien over your funds if it decides protective measures are needed. It does not have to make a margin call first or give you any notice.

Why this matters

The trigger list ends with any other circumstance in which the company ought to take protective measures, which means whatever it decides. It can also refuse any instruction you give without explaining why.

Exhibit 15WarningHarder than usual

任何其他漢聲應當采取保護措施的情況或變化
Clause 10 vi

Where it sits: section 37 of 67 in the Client Agreement (English), 55% of the way through.

SinoSound can amend any term or add new ones, publish the change on its website, and treat your next order as acceptance. It asks you to check the terms page regularly.

Why this matters

You can be bound by a clause you never read, on the day you place a trade. No notice period appears anywhere in the agreement.

Exhibit 16WarningHarder than usual

客戶在有關修改、變更或增補在漢聲網站公布後作出的任何買賣或交易指令將被視為同意及接受此有關修改、變更或增補的行為。
Clause 23

Buried at section 50 of 67 in the Client Agreement (English), 75% of the way through.

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

Firms licensed by the FCA and CySEC must give a retail client advance notice of a change to their agreement. This contract publishes the change and counts your next trade as agreement to it.

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

Two signed copies of one contract, two prevailing languages

The Chinese file SinoSound asks you to sign says English prevails. The English file and both web versions say Chinese prevails. Disputes go to one arbitrator in Hong Kong, and the proceedings are held in English.

Governing text2 clauses flagged

The Chinese file SinoSound asks you to sign says the English version wins if the two differ. The English file, and both web versions, say the Chinese version wins.

Why this matters

When the two texts differ you cannot tell which words bind you. Both files are dated 1 March 2018 and both sit on the same download page.

Exhibit 18WarningRarely seen

若本協議中英文版本不一致，應以英文版為準。
Quoted in 漢聲集團-客戶協議-20180301-繁中 (signable Chinese client agreement), p.14
Read from the broker's site on Open the reference

Our readingA prevailing language clause exists to settle which text wins. Two copies of the same contract, each pointing at the other language, leave the question open.

Any dispute goes to a single arbitrator at the Hong Kong International Arbitration Centre. The proceedings run in English, while the version of the contract that governs is the Chinese one.

Why this matters

You cannot take a small claim to a free complaints body, because the contract names none. Arbitration in English in Hong Kong is a serious step for a client who signed a Chinese contract.

Exhibit 19WarningHarder than usual

指定仲裁員的機構是香港國際仲裁中心（“HKIAC”），仲裁員為一人。
Clause 27

Buried at section 54 of 67 in the Client Agreement (English), 81% 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 scheme that costs the client nothing. This contract names arbitration in Hong Kong instead.

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

ID and bank card to open, credit checks by agreement

SinoSound asks for both sides of your ID card and the front of your bank card before you can trade or withdraw. The agreement lets it investigate your credit standing and your past investment activity with banks and credit agencies. The privacy policy covering all of it is one paragraph long.

Data and documents1 clause flagged

SinoSound asks for both sides of your ID card and the front of your bank card. The agreement also lets it check your credit standing and your past investment activity. Its whole privacy policy is one paragraph.

Why this matters

Failing to hand over a document SinoSound asks for is listed as a reason to liquidate your account. The privacy policy names no retention period and no way to ask what is held about you.

Exhibit 17WarningStandard wording

The Client authorises SinoSound, or its employees, to investigate the Client's credit standing and to verify the Client's information with relevant banks, financial institutions and credit agencies. The Client further authorises SinoSound to investigate the Client's current and past investment activities.
Clause 28 in Client Agreement (English)
Read from the broker's site on Archived copyOpen the reference

Buried at section 55 of 67 in the Client Agreement (English), 82% of the way through.

Hong Kong law, a gold exchange number, no financial regulator named

You contract with Sino Sound Holdings Limited, a Hong Kong company incorporated in 2012. The agreement names Hong Kong law and a single arbitrator. No financial regulator, deposit protection scheme or ombudsman appears in any document we read, while the English site says every transaction is regulated.

Who stands behind it1 clause flagged

The agreement names Hong Kong law, Hong Kong arbitration and no financial regulator. SinoSound's own risk disclosure warns that off-exchange trading may be subject to less regulation. The English site tells you the opposite.

Why this matters

No deposit protection scheme and no ombudsman appears anywhere in the documents. The agreement points you to Hong Kong law and a single arbitrator, and nothing else.

Exhibit 23Notice

Moreover, off-exchange transactions may be subject to less regulation or different regulatory systems.
Clause Risk Disclosure 4 in Client Agreement (English)
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 9 of 67 in the Client Agreement (English), near the start.

Where the marketing and the contract disagree

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

01

The page selling easy withdrawals does not mention the 6% charge that the trading rules page applies to a client who deposits and does not trade.

Said in public, in Chinese

漢聲取款，靈活支取，高效無憂。

Word for word in English: SinoSound withdrawals: flexible access, efficient and free of worry.

Chinese withdrawal procedure page, the line above the withdrawal instructions

In the contract · clause 注意事項 1

戶口的交易量(保証金使用)少於最近一次注資金額的30%，本公司將收取不少於取款金額的6%作為行政費。

02

The FAQ promises no extra charges while the fee clause lists four kinds of fee and allows new ones with no notice.

Said in public, in English

No. Opening a SinoSound live account is completely free – all funds are used for trading with no extra charges.

English FAQ, Account Opening tab

In the contract · clause 11

SinoSound may charge commissions, fees and/or charges without prior notice.

03

Funds described as fully protected in segregated custody are funds the agreement lets the firm lend to itself.

Said in public, in English

Client funds are held in segregated custody accounts under the company's name, independently verified by external auditors with regular asset reports. Your funds are fully protected.

English FAQ, Deposits/Withdrawals tab

In the contract · clause 14

The Client also authorises SinoSound to pledge, re-pledge, invest or lend, whether separately or together with the property of other clients, any property of the Client held as margin or collateral, to SinoSound itself or to other parties.

04

The FAQ advertises instant fills for scalping and the agreement prohibits scalping outright.

Said in public, in English

No. SinoSound guarantees market orders are executed at the quoted price – no slippage, no trading restrictions, and instant fills for scalping.

English FAQ, Trading tab, answer on slippage

In the contract · clause 12

"Arbitrage", "arbitrage trading" or "scalping", as well as activities that exploit price differences through rapid position opening and closing due to network delays or the use of external software (i.e., any third-party auxiliary software not published by SinoSound) (collectively referred to as "Arbitrage"), are not permitted in the over-the-counter market where clients trade directly with market makers.

05

Clients are told there are no abnormal trading rules, while the clause on abnormal trading allows profit to be deducted on suspicion alone.

Said in public, in English

Our Client Agreement prohibits arbitrage-style trading. Most clients trade normally, so we do not have specific abnormal trading rules.

English FAQ, Trading tab, answer on what counts as normal trading

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In the contract · clause 13

If SinoSound suspects that any client or account is engaged in Manipulation, SinoSound reserves the right to investigate and audit such client or account and to deduct from the suspected account any profits generated from such activities.

06

The FAQ caps your loss at the account balance and clause 8 says the loss may exceed every dollar in the account.

Said in public, in English

In case of gaps causing losses, we ensure losses are limited to account balance only, reducing risk to the minimum.

English FAQ, Trading tab, answer on how pending orders are executed

In the contract · clause 8

The Client agrees to bear all losses resulting from failure to meet margin calls in time, which may exceed the Client's initial margin, i.e., all funds in the account.

07

A negative balance the FAQ says is usually not pursued is a debt the contract makes payable on demand with interest.

Said in public, in English

Typically, we do not recover negative amounts – your balance resets to zero when you resume trading.

English FAQ, Trading tab, answer on why an account goes negative

In the contract · clause 10

Upon demand by SinoSound, the Client shall immediately be liable for all debts in the Client's account, including any corresponding interest (at the lower of the prime rate plus 3% or the maximum rate permitted by law) and other related costs.

08

The overnight financing rate is 2.5% in the FAQ and 2.75% in the trading rules, and no page says which one applies.

Said in public, in English

Long positions: 2.5% p.a. / Short positions: 0.5% p.a.

English FAQ, Trading Procedures tab, answer on the overnight fee

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In the contract · clause Overnight Interest (Swap)

Buy -2.75%, Sell 0.25%

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09

The break-even figure covers the spread only, and leaves out the $50 a lot commission that doubles it.

Said in public, in English

A buy order breaks even when price rises by 0.50 (Gold) or 0.05 (Silver) per ounce.

English FAQ, Trading Procedures tab, answer on how to break even

In the contract · clause Fees

Trading Commission: USD 50 per lot

10

The Chinese rules cancel stop loss and take profit each week, and the English version of the same note leaves both out.

Said in public, in English

All pending orders are valid for the current trading week only. Unexecuted pending orders will be automatically cancelled before weekends or international holidays.

English trading rules page, Important Notes 3

In the contract · clause 注意事項 3

本公司交易平台上所有掛單設置（包括掛單及止損止盈）的默認期限為當週有效，週末或國際節假日休市前，系統會自動取消所有未執行的掛單設置，客戶可于開市後重新設置，或在交易時間內進行修改或刪除設置。

11

The claim of no restrictions around payroll data sits against a standing notice that refuses and deletes stop orders for 2.5 hours around it.

Said in public, in English

You may engage in short-term trading allowed with no restrictions around NFP/data releases.

English FAQ, Company Information tab, answer on key advantages

In the contract · clause 二、2

止損掛單：重要消息/數據公佈期間的2.5小時內、系統將不接受任何止損掛單的設置，且此前所設置的所有止損掛單均會被系統自動取消。

12

The Chinese file points at the English text and the English file points at the Chinese text, so neither settles which version governs.

Said in public, in Chinese

若本協議中英文版本不一致，應以英文版為準。

Word for word in English: If the Chinese and English versions of this Agreement are inconsistent, the English version shall prevail.

the signable Chinese client agreement, final page above the signature block

In the contract

In the event of any inconsistency between the English and Chinese versions of this Agreement, the Chinese version shall prevail.

13

The English FAQ offers Alipay and USDT while the Chinese FAQ says Alipay is not available.

Said in public, in English

Yes. We currently support Alipay, WeChat Pay, bank cards, and USDT.

English FAQ, Deposits/Withdrawals tab, answer on Alipay

In the contract · clause 注資/取款

我們的網上支付系統暫時未有包括支付寶，但請放心，只要客戶持有的銀行卡開通了網上銀行功能，即可通過環迅支付、銀聯等支付系統辦理注資業務，直接支付人民幣，最快即時到賬。

14

The FAQ says the accounts are regulated by the Hong Kong government while the agreement warns that this off-exchange trading may be less regulated.

Said in public, in English

All accounts are audited regularly and regulated by the Hong Kong government.

English FAQ, Deposits/Withdrawals tab, answer on where funds are held

In the contract · clause Risk Disclosure 4

Moreover, off-exchange transactions may be subject to less regulation or different regulatory systems.

The documents this reading is based on

8 files, all published by SinoSound. 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 SinoSound publishes.

How this reading was done

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

This reading was published on .

Documents
7 of 8downloaded from the broker's site, and 7 read in full
Pages opened
54pages walked to find those documents, footer links included
Older copies
3earlier versions downloaded
Languages
EN vs ZHthe language it advertises in, against the language it contracts in
Position measured
12clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

Sino Sound Holdings Limited

You contract with Sino Sound Holdings Limited, a Hong Kong company incorporated in December 2012. The agreement names no other entity. The same company takes your deposit, quotes your price and may stand on the other side of your trade, which its own cross trading clause allows. The only registration numbers it publishes are a company number and a business registration number, plus a membership number at a gold exchange.

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 fee schedule is public and specific: $50 commission a lot, a $0.50 gold spread, 2% margin and a $5 monthly inactivity fee. The withdrawal timetable is concrete, with money sent out on the first working day and bank arrival times listed bank by bank. Promotion cash can be withdrawn once it is paid, with no turnover lock on it. The anti-fraud page names the only three domains the firm uses, and warns you that its staff never ask for an SMS code. The whole client agreement is published in three languages and in two signable files, which is more than most firms in this product publish at all.

We read the client agreement, the trading rules, the deposit and withdrawal pages, the FAQ and the promotion terms on SinoSound's own site. We read them in Chinese and in English. We also read both signable copies of the agreement, the Chinese file of 14 pages and the English one of 20. No earlier copy of the disclaimer or the privacy policy was available, so we cannot say whether either has changed. The client portal needs an account, so any terms shown during sign up are not covered in this review. The agreement counts the account application form as part of the contract, and that form is not published.

How to check any of this yourself

Every quote above links to the SinoSound 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 SinoSound 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 SinoSound 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 4, 2026.

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

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