Wikilix
Contract reading

What Thunder Markets legally published, but does not want you to read

Every clause below is published by Thunder Markets 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: Thunder Markets Ltd

withdrawalshidden feesole discretionunilateral amendmentclient moneycomplaint windowdata retentiondata rightsdeemed acceptancedispute barrier

Thunder Markets Ltd stopped trading on October 30, 2025. The site still tells you a withdrawal is possible at any time. The contract setting those withdrawal rules is no longer published. It let the firm bill a dormant account 30 EUR a month and reverse every past trade.

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Contract risk

Money at risk
8.5/10

Where this contract sitsHow far this contract goes, overall. Under 2 is nothing beyond the ordinary; 6 to 9 means several clauses put money you have already earned at risk; 9 and above reads as designed to make payout refusable.

0510
CriticalClauses that can cost you money you have already earned or deposited, or that remove your ability to challenge it.
5
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
11
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
3
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
2

How the 11 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
Warning5
Notice1

section 16 of 24is where the deepest clause sits, 67% 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.

Critical2Withdrawal limit. Jump to the clause this comes from.Withdrawals invited while the governing contract is goneCritical$30Fee on an unused account. Jump to the clause this comes from.Dormant accounts charged 30 EUR a monthCritical3Time to complain. Jump to the clause this comes from.Contract gives no address for client notices

What the documents say

11 clauses worth knowing about, worst first, each quoted from Thunder Markets's own files

01

Thunder Markets tells you to log in and withdraw your money. The contract that sets the withdrawal rules is no longer on its site. Only two legal documents remain: a privacy policy and a complaint policy.

Why this matters

You cannot check what Thunder Markets owes you, or on what terms, because the agreement you accepted is no longer published. The firm holds your money under rules you can no longer read.

Exhibit 1CriticalRarely seen2

A withdrawal of your funds is possible at any time. Please login to your client portal to update the relevant account information and request the withdrawal of your funds.
Quoted in Business closure notice to clients
Read from the broker's site on Open the reference
Our own capture of thundermarkets.com, taken on Sep 7, 2026The claim, on Business closure notice on the Thunder Markets home pageVisit this page on the broker's siteDownload the full size image file
Our own capture of web.archive.org, taken on Sep 7, 2026What the contract says, clause 7.6Visit this page on the broker's siteDownload the full size image file
Our own capture of thundermarkets.com, taken on Sep 7, 2026Withdrawals invited while the governing contract is goneVisit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must give a retail client the terms of business and keep them available while the relationship runs. Thunder Markets has taken its client agreement off its website while it still holds client money.

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

Our readingBrokers normally keep the client agreement published through a wind-down, because it is the document that governs how the money goes back. Here every legal address on the site returns the closure notice instead.

  • Worse together with Exhibit 2The fee that eats a dormant balance sits in the one document a client can no longer open.
02

Stop trading for three months and Thunder Markets can bill your account every month. Clause 4.3 sets the charge at 0.25% of your balance, with a floor of 30 EUR.

Why this matters

A small balance pays the 30 EUR floor rather than the percentage, so a quiet account drains fast. Trading stopped for everyone on October 30, 2025, which makes every account left open inactive.

Exhibit 2CriticalHarder than usual$30

If the Client Account is inactive for three (3) months or more (i.e. there is no trading, no open positions, no withdrawals or deposits)
Clause 4.3 in Client Services Agreement
Downloaded from the broker's site on Open the reference
Our own capture of web.archive.org, taken on Sep 7, 2026Dormant accounts charged 30 EUR a month (clause 4.3)Visit this page on the broker's siteDownload the full size image file

What it costs0.25% of a 1,000 EUR balance is 2.50 EUR a month, so the 30 EUR floor applies instead. Twelve months of that floor is 360 EUR.

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

Firms licensed by the FCA or CySEC must disclose costs and charges to a retail client before they trade. This fee sits in a contract Thunder Markets no longer publishes, and it points to a website fee page that no longer exists.

Thunder Markets 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
Three months with no tradeThunder Markets can treat the account as inactive.4.3
Each month after thatA charge of 0.25% of the balance applies, with a floor of 30 EUR.4.3
Every quarterThe firm collects the accumulated inactivity fees.4.3
03

Thunder Markets can close your account with no notice and then reverse or cancel every trade you ever made. Clause 21.3 gives it that power. A listed trigger is trading that upsets the platform in any manner.

Why this matters

Your profit is not safe once you have earned it. Thunder Markets decides whether your trading upset its platform, and the clause sets no test and gives you no appeal.

Exhibit 3CriticalRarely seen

The Company may terminate this Agreement immediately without giving prior written notice, and the Company have the right to reverse and/or cancel all previous Transactions on a Client's account, in the following cases:
Clause 21.3 in Client Services Agreement
Downloaded from the broker's site on Open the reference
Our own capture of web.archive.org, taken on Sep 7, 2026Every past trade can be reversed without notice (clause 21.3)Visit this page on the broker's siteDownload the full size image file

Our readingVoiding trades for proven market abuse is ordinary. Reversing all previous transactions because trading affected the platform in any manner has no ceiling and no defined test. Clause 13.2, by contrast, ties its voiding power to the market abuse definition in the Seychelles Securities Act 2007.

  • Worse together with Exhibit 8Trades are reversed first, then the resulting balance is set off without notice under clause 25.1.
04

Thunder Markets left three drafting placeholders in the contract clients accepted. The address for every notice you send the firm reads [Email to be added] in clause 20.1.

Why this matters

You must give written notice to close your account, and the contract never says where to send it. The address for your data rights requests in clause 16.8 is blank as well.

Exhibit 4CriticalRarely seen3

Any notice, instruction, request or other communication to be given to the Company by the Client under the Agreement shall be in writing and shall be sent to the Company's email address at [Email to be added].
Clause 20.1 in Client Services Agreement
Downloaded from the broker's site on Open the reference
Our own capture of web.archive.org, taken on Sep 7, 2026Contract gives no address for client notices (clause 20.1)Visit this page on the broker's siteDownload the full size image file

Our readingA published contract normally has its notice and contact fields filled in. Here the drafting markers survived into the version clients accepted, so the notice clause names no recipient at all.

  • Worse together with Exhibit 1The clause that names no address is itself in the document the site no longer publishes.
05

Your money can sit in an omnibus account, which means it is pooled with other people's. Clause 7.3 then says you have no claim against any specific sum if the holder becomes insolvent.

Why this matters

If the firm holding the pool fails, you join a queue rather than point at your own balance. Thunder Markets also declines responsibility for any resulting losses.

Exhibit 5CriticalHarder than usual

The third party to whom the Company will pass money may hold it in an omnibus account and it may not be possible to separate it from the Client's money, or the third party's money in which case the Client will not have any claim against a specific sum in a specific account in the event of insolvency. The Company does not accept any liability or responsibility for any resulting losses.
Clause 7.3 in Client Services Agreement
Downloaded from the broker's site on Open the reference
Our own capture of web.archive.org, taken on Sep 7, 2026The claim, on Annex 1, Conflicts of Interest Policy, under the heading Segregation of Company's assets from clients' assetsVisit this page on the broker's siteDownload the full size image file
Our own capture of web.archive.org, taken on Sep 7, 2026What the contract says, clause 7.3Visit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must hold retail client money in segregated accounts and belong to a compensation scheme that pays out if the firm fails. Thunder Markets names no compensation scheme, and clause 7.3 removes your claim to a specific sum.

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

  • Same clause as Exhibit 9Both sit in section 7, which governs client money and every transfer out of it.
  • Worse together with Exhibit 8You hold no claim to a specific sum, and the firm can still set off against the account without notice.

Thunder Markets can change charges without asking you

Clause 4.1 lets Thunder Markets change its charges with no consultation and no consent from the client. The same clause makes the website the fee schedule. The website now carries a closure notice and no prices at all.

Cost disclosure1 clause flagged

Thunder Markets can change its charges without asking you, under clause 4.1. That clause points to a fee schedule on its website, and the site publishes none.

Why this matters

You agreed to fees you cannot now look up. The contract treats the website as the price list, and the website is a closure notice.

Exhibit 7WarningHarder than usual

The Client further agrees that the Company is entitled to change its charges without any consultation or prior consent from the Client.
Clause 4.1 in Client Services Agreement
Downloaded from the broker's site on Open the reference

Thunder Markets invites withdrawals under rules it no longer publishes

Thunder Markets stopped trading on October 30, 2025 and still tells clients a withdrawal is possible at any time. The contract that set those rules, including clause 7.6 on reversing a withdrawal, is no longer on the site. Clause 7.3 also says pooled client money carries no claim against a specific sum in insolvency.

Exit conditions1 clause flagged

Money must go back the way it came in, to the same person. Thunder Markets can refuse a method, ask for more documents, then reverse the withdrawal under clause 7.6.

Why this matters

You pay your bank's charges on a withdrawal the firm undoes. If the payment method you used has since closed, the contract offers no route back.

Exhibit 9WarningHarder than usual

For this purpose, Client's withdrawals should be made using the same method used by the Client to fund his Client Account and to the same remitter.
Clause 7.6 in Client Services Agreement
Downloaded from the broker's site on Open the reference

Thunder Markets can take from any of your accounts without notice

Clause 25.1 lets Thunder Markets set off any liability at any time and without notice, across any account a client holds. It reaches liabilities that are contingent or future. Clause 21.4 lets the firm retain assets after closure for contingent obligations.

Balance control1 clause flagged

Thunder Markets can take money from any account you hold with it, at any time and without telling you. Clause 25.1 covers liabilities that are contingent or still in the future.

Why this matters

Your balance can drop with no warning and no statement explaining it. Clause 21.4 also lets the firm keep what it judges necessary for contingent obligations after your account closes.

Exhibit 8WarningHarder than usual

The Company may at any time and without notice to the Client set-off any liability under this Agreement or any other agreement entered into between the parties and between any account(s) of the client (whether actual or contingent, present or future).
Clause 25.1 in Client Services Agreement
Downloaded from the broker's site on Open the reference

Sixty business days to answer, and no address to write to

Thunder Markets allows itself 60 business days for a final answer to a complaint, and the only escalation named is the FSA in Seychelles. Clause 20.1 gives the address for client notices as [Email to be added]. Three such placeholders survived into the published contract.

Complaint route1 clause flagged

Thunder Markets gives itself up to 60 business days to send you a final answer on a complaint. After that, your only escalation is the FSA in Seychelles.

Why this matters

Sixty business days is close to three months of waiting before you can take the matter further. No ombudsman can order Thunder Markets to pay you.

Exhibit 6WarningHarder than usual60 working days

A final response should be provided to the Client within 60 business days the latest from the date he submitted his complaint;
Quoted in Complaint Handling Policy
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 10 of 24 in the Complaint Handling Policy, 42% of the way through.

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

Firms licensed by the FCA or CySEC must give a final response within eight weeks, and the client can then go to a free independent ombudsman that can order redress. Thunder Markets allows itself 60 business days and points you to the regulator instead.

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

Passport and bank details held with no deletion date

The Thunder Markets privacy policy collects passports, bank accounts and card details, and sets no retention period. It can be changed for any reason by posting a new version, and continued use of the site counts as agreement. The agreement's address for a deletion request is blank.

Your data1 clause flagged

Thunder Markets can rewrite its privacy policy for any reason and simply post it. Using the site afterwards counts as your agreement, and no clause says when your data is deleted.

Why this matters

Your passport, bank details and card details sit with a firm that has stopped trading. The contract's route for asking for deletion is a blank address.

Exhibit 10WarningHarder than usual

The Company reserves the right to make changes to this Privacy Policy from time to time for any reason and the client will be notified of such changes by posting an updated version of this Privacy Policy on the website.
Quoted in Privacy Policy
Read from the broker's site on Open the reference

Buried at section 16 of 24 in the Privacy Policy, 67% of the way through.

Thunder Markets Ltd, Seychelles licence SD067, no compensation scheme

Clients contract with Thunder Markets Ltd, registered in Seychelles under number 8427682-1 and licensed as a Securities Dealer under SD067. The privacy policy spells the name Thunder Markets Limited. Neither published document names a compensation scheme.

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.

The counterparty1 clause flagged

You contract with Thunder Markets Ltd, registered in Seychelles under number 8427682-1 and licensed as a Securities Dealer under SD067. The privacy policy calls it Thunder Markets Limited.

Why this matters

Two office numbers appear for the same company, 9A in the policies and 8E in the footer. Neither published document names a compensation scheme that would pay you if the firm cannot.

Exhibit 11Notice

Thunder Markets is the trade name of Thunder Markets Limited a company regulated as a Securities Dealer by the Financial Services Authority of Seychelles with license number SD067
Quoted in Privacy Policy
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 home page promises withdrawal at any time while the contract lets Thunder Markets reverse a withdrawal whose paperwork does not satisfy it.

Said in public, in English

A withdrawal of your funds is possible at any time.

Business closure notice on the Thunder Markets home page

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

In the contract · clause 7.6

Where applicable, if the Company is not satisfied with any documentation provided by the Client or if the company has reasonable grounds for suspecting that a Client violates Applicable regulations, then the Company will reverse the withdrawal transaction and deposit the amount back to the Client's Account and the Client will suffer the relevant Client's bank account provider's charges.

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

02

Annex 1 promises segregation that survives bankruptcy while clause 7.3 removes any claim to a specific sum in insolvency.

Said in public, in English

In addition, the Company has legally secure segregation of clients' assets from the Company's assets in case the Company becomes bankrupt.

Annex 1, Conflicts of Interest Policy, under the heading Segregation of Company's assets from clients' assets

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

In the contract · clause 7.3

The third party to whom the Company will pass money may hold it in an omnibus account and it may not be possible to separate it from the Client's money, or the third party's money in which case the Client will not have any claim against a specific sum in a specific account in the event of insolvency.

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

What changed quietly

This is our first reading of Thunder Markets, so there is nothing to compare it against. The privacy policy and the complaint policy on the site are unchanged since March 2026.

  • REMOVEDClause 7.6 · 2025-04-16 (archived) to 2026-09-07

    The clause setting how a withdrawal is handled is no longer published on the site that invites clients to request one.

The documents this reading is based on

3 files, all published by Thunder Markets. 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 Thunder Markets publishes.

How this reading was done

Every clause above was read out of a document Thunder Markets publishes itself

This reading was published on .

Documents
3 of 3downloaded from the broker's site, and 3 read in full
Pages opened
24pages walked to find those documents, footer links included
Older copies
3earlier versions downloaded, 2 identical to the copy we hold by fingerprint
Position measured
2clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

Thunder Markets Ltd

Thunder Markets Ltd is a Seychelles company, registration number 8427682-1, trading as Thunder Markets and previously as Thunder Forex. It is licensed as a Securities Dealer by the Financial Services Authority of Seychelles under SD067. Its own footer says the site is not directed at EU residents and falls outside MiFID II. No European regulator stands behind it. The privacy policy calls the same company Thunder Markets Limited.

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

Clause 7.1 requires client money to sit in a segregated client bank account, and Annex 1 promises separate books for each client. Clause 25.2 makes the firm get FSA approval before an amendment reaches clients, which is stronger than the usual notice by posting. The Complaint Handling Policy sets no deadline for a client to complain, so a claim does not expire in days, and it prints the FSA's full contact details. Clause 13.2 ties the firm's voiding power to the market abuse definition in the Seychelles Securities Act 2007 rather than leaving it undefined. Clause 4.6 exempts retail clients from the 1% deposit and withdrawal fee. The closure notice sits on the front page rather than buried.

The Client Services Agreement and the Conflicts of Interest Policy are no longer published on thundermarkets.com. Every legal address on the site now returns the closure notice instead. We read both documents on an archived copy of Thunder Markets' own pages from April 2025, and every quotation credited to the agreement comes from there. We read that agreement in part, not end to end: sections 1 to 3, 5, 6 and 10 to 12 were not examined clause by clause. Thunder Markets publishes no risk disclosure, no payment terms and no anti money laundering policy, so there is nothing to read on deposit and withdrawal timings, minimums or card fees. The closure notice names a client portal, but the site links to none, so we could not see what a client sees there.

How to check any of this yourself

Every quote above links to the Thunder Markets 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 Thunder Markets 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 Thunder Markets 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 Sep 7, 2026.

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

Back to the Thunder Markets profile