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Contract reading

What Windsor Brokers legally published, but does not want you to read

Every clause below is published by Windsor Brokers 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: Windsor Brokers International Ltd

hidden feesole discretiondeemed acceptancelanguage arbitragewithdrawalscomplaintscost shiftingdormancyprofit voidingaccount transfer

Windsor Brokers promises, in English, Arabic and Chinese, never to interfere with your account. Its contract lets it close your trades for any reason. Withdrawals wait for Windsor's approval and can be held on 'reasonable doubt'. Trading after a complaint settles it, and statements bind you after 24 hours. Windsor keeps balances under $50 when it closes an account, and its '$5 million client insurance' insures Windsor's own liability.

Back to Windsor Brokers

Contract risk

Money at risk
7.5/10

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.
7
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
25
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
14
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
8

How the 25 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.

Critical7
Warning16
Notice2

section 133 of 197is where the deepest clause sits, 68% 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.

Critical7 daysWithdrawal limit. Jump to the clause this comes from.Withdrawals need Windsor's approval and can be heldCritical$50Fee you were not shown. Jump to the clause this comes from.Balances under $50 are zeroed when the account closesCritical60 daysBonus requirement. Jump to the clause this comes from.Any withdrawal wipes out the whole deposit bonusCritical1 daysTime to complain. Jump to the clause this comes from.24 hours to challenge a statement, no limit for Windsor

What the documents say

25 clauses worth knowing about, worst first, each quoted from Windsor Brokers's own files

01

Every withdrawal waits for Windsor's approval. Windsor can hold or refuse all or part of one if it has 'reasonable doubt' about your account, with no time limit. Larger withdrawals can take up to 7 days.

Why this matters

The website promises withdrawals within 1 working day and with no restrictions. The contract lets your money wait until Windsor is satisfied. The Seychelles agreement also lets Windsor delay withdrawals on suspicion alone, while its Kenyan agreement has the same abuse clause without that power.

Exhibit 1CriticalHarder than usual7 days

The Client further acknowledges and agrees that the Company reserves the right to withhold or reject (partially or in whole) the Client’s request for withdrawal in cases where:
Clause 29.3 in Client Account Agreement, p.21
Read from the broker's site on Open the reference

Where it sits: section 111 of 197 in the Client Account Agreement, 56% of the way through.

  • Worse together with Exhibit 3A dispute lets Windsor hold your withdrawal under clause 29.3(d), and any trade you place while you wait settles that dispute under clause 9.8.
02

Windsor's insurance page tells you, in Arabic, Chinese and English, that it keeps no right to interfere with your trading account. The client agreement lets Windsor close your open trades and sell your property 'for any reason whatsoever', without notice.

Why this matters

If Windsor closes a losing trade, the loss becomes real and your deposit pays for it. The promise on the insurance page gives you no rights, because the contract you sign says the opposite.

Exhibit 2CriticalHarder than usual

at any time the Company deems it necessary for its protection for any reason whatsoever, the Company may, in the manner it deems appropriate, close out the Client's open trades in whole or in part, sell any or all of the Client's property held by the Company
Clause 14(f) in Client Account Agreement, p.12
Read from the broker's site on Open the reference

Where it sits: section 66 of 197 in the Client Account Agreement, 34% of the way through.

03

If you complain and then place any trade, Windsor treats that trade as settling your complaint. You accept the account as it stood on the day you complained, and you promise never to reopen the case.

Why this matters

Windsor can take weeks to answer a complaint. One trade in that time, even one placed to manage the positions in dispute, can end your claim.

Exhibit 3CriticalRarely seen

Furthermore, the Client acknowledges and agrees that initiating any transaction in any of their accounts subsequent to filing a complaint and/or other claim regarding their accounts signifies their acceptance of the account's status as of the complaint's filing date.
Clause 9.8 in Client Account Agreement, p.10
Read from the broker's site on Open the reference

Where it sits: section 55 of 197 in the Client Account Agreement, 28% of the way through.

Set against a regulated standard: FCA (UK), ASIC (Australia)

Firms licensed by the FCA or ASIC must give every complaint a final response within a set time and tell the client about an independent complaints scheme. This agreement lets one trade end your complaint before any response arrives.

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

Our readingA settlement normally needs both sides to agree to it in words. This clause turns an ordinary act, placing a trade, into your agreement to drop the complaint, whether or not you meant it that way.

04

When your account is closed with less than $50 in it, Windsor keeps the rest and calls it an 'administration charge'. It can do the same to a larger balance if it says it cannot refund you, for example after you close your bank account.

Why this matters

Windsor can close your account for any reason on 7 days' notice, or at once if your first month passes without a deposit or trade. It then keeps any amount under $50 and owes you no refund.

Exhibit 4CriticalRarely seen$50

The Client further acknowledges and accepts that an administration charge (e.g. for the account review, monitoring etc.) will be applied to the Client’s account on termination where the balance is below US$50 (or currency equivalent). In such cases, the Company will zero out any remaining balance below the threshold and will have no obligation to refund the Client.
Clause 5.4 in Client Account Agreement, p.7
Read from the broker's site on Open the reference

Where it sits: section 37 of 197 in the Client Account Agreement, near the start.

What it costsAn account closed with $49 in it pays you $0. Windsor keeps the full $49 as its 'administration charge'.

Our readingThe charge has no price of its own: it is whatever is left in the account, so a $5 balance and a $49 balance both go to zero. Windsor's Key Facts Statement extends it to any balance Windsor says it is unable to refund.

05

Windsor's deposit bonus adds trading credit worth 20% to 100% of each deposit. Any withdrawal, of any size, removes all of it. So do 60 days of inactivity and a stop-out, when your trades are closed for lack of margin.

Why this matters

If your open trades lean on the bonus as margin, taking out any amount can collapse them. Clause 24 of the bonus terms says Windsor is not liable for any loss, liquidation or stop-out the removal causes.

Exhibit 6CriticalHarder than usual60 days

Active bonus credit shall be cancelled and removed from the relevant trading account if any of the following events occur:
Clause 22 in Deposit Trading Bonus Promotion Terms & Conditions, p.3
Downloaded from the broker's site on Open the reference

What it costsAt the 100% tier, a $1,000 deposit adds $1,000 of bonus credit. A withdrawal of any amount removes all $1,000 of it.

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

Under ESMA's CFD rules, which CySEC and the FCA apply, a firm may not offer retail clients a bonus or other monetary incentive to trade CFDs. Windsor offers retail clients a deposit bonus of up to $60,000 in total, which any withdrawal removes.

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

  • Worse together with Exhibit 21Removing the bonus cuts your margin at once, and Windsor sends no margin call warning before it starts closing trades.
06

Windsor advertises up to $5,000,000 of client insurance, and its Chinese page says each client is covered for that sum. The certificate shows professional indemnity cover for Windsor's own errors, with one $5 million limit shared by all group companies for a year.

In plain words

Indemnities are money it says you owe it.

Why this matters

You are not a party to the policy, and the insurance broker's letter says it makes no one else an insured. Every claim against the group in a year, plus legal costs, comes out of the same limit.

Exhibit 5Warning$5000000

Insured: Windsor Brokers International Ltd
Quoted in Confirmation of Insurance, p.1
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

If an FCA-licensed firm fails, its clients can claim from the Financial Services Compensation Scheme, and clients of CySEC firms can claim from the Investor Compensation Fund. None of Windsor's documents names a compensation scheme, and its insurance covers Windsor's own liability rather than your deposit.

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

Suspicion is enough to reverse your trades

Clause 17.11 of Windsor Brokers' Seychelles agreement lets it reverse trades, cut balances and delay withdrawals on 'reasonable suspicion' of abuse, without notice. Clause 17.8 lets it take back past profits it can show came from price errors, at any time. Clause 14 hands Windsor the profit on any trade placed from a negative balance, while you keep the loss.

Profit reversal2 clauses flagged

If Windsor suspects you of abusing its systems, it can reverse your trades, cut your balance and delay withdrawals, without notice. For profits it can show came from price errors, it can take them back at any point while you are a client.

Why this matters

Suspicion is enough for the reversals and the withdrawal delay, and Windsor alone decides what counts as abuse. The clause sets no deadline for a decision and no test beyond Windsor's own suspicion.

Exhibit 8CriticalHarder than usual

In the event of any such act or any reasonable suspicion thereof, the Company may, at its absolute discretion and without prior notice, suspend or terminate access (including placing accounts in close-only mode), cancel and/or reverse transactions, adjust balances to remove any unjust enrichment, decline or delay withdrawals
Clause 17.11 in Client Account Agreement, p.15
Read from the broker's site on Open the reference

Where it sits: section 86 of 197 in the Client Account Agreement, 44% of the way through.

  • Same clause as Exhibit 1Clause 17.11 is both a clawback and a withdrawal hold, so one suspicion can freeze your money and shrink it.

If you trade while your balance is below zero, without Windsor's express permission, Windsor can keep any profit. Any loss stays with you, shared with your introducer if you have one.

In plain words

Jointly and severally liable means each person can be made to pay the whole amount alone. If the broker treats two accounts as linked, it can ask either holder for all of it, not half each.

Why this matters

It is a one-way bet in Windsor's favour, decided at Windsor's discretion. The same clause makes Windsor's figures for market value and margin conclusive, so you cannot challenge them.

Exhibit 16WarningHarder than usual

profits on any transactions executed without the Company's express permission, for the Client’s account that is debit/deficit at the time the order/request is placed, shall be for the Company's account if the Company in its discretion so elects.
Clause 14 in Client Account Agreement, p.13
Read from the broker's site on Open the reference

Where it sits: section 67 of 197 in the Client Account Agreement, 34% of the way through.

One trade can end your complaint

Windsor Brokers gives you 24 hours to dispute a statement and three months to sue, but may take 90 days to answer a complaint. Clause 9.8 adds a trap: any trade you place after complaining counts as settling the complaint. Clause 9.1 makes you repay Windsor's costs of defending a claim you bring, and clause 28 bars card chargebacks.

Complaint barriers3 clauses flagged

Trade confirmations and statements bind you unless you report an error in writing within 24 hours, and before the next business day starts. Windsor keeps the right to correct any error it finds, with no deadline at all.

Why this matters

Miss a weekend or a day offline and a wrong balance becomes your agreed balance. The same clause lets Windsor correct a mistake in its own favour at any time.

Exhibit 7CriticalHarder than usual1 days

Confirmation of transactions, balances, equity, order/request, margin calls etc, either through statements of accounts or through Online Trading Platform(s), shall be binding on the Client for all purposes, unless the Client calls any error therein to the Company's attention in writing prior to the start of business on the next business day following such occurrence and within maximum 24 hours.
Clause 22 in Client Account Agreement, p.18
Read from the broker's site on Open the reference

Where it sits: section 96 of 197 in the Client Account Agreement, 49% of the way through.

  • Worse together with Exhibit 3An error you miss within 24 hours binds you, and a complaint about it ends the moment you trade again.

You cannot bring any action against Windsor more than three months after the problem arose. If you do sue, the agreement makes you repay Windsor's costs of defending your claim, including its lawyers' fees.

Why this matters

Windsor can take up to 90 days to answer a complex complaint, about as long as the three months you have to sue. Windsor also decides what counts as a complaint. Clause 45.2 says a plain email to Compliance does not qualify, yet clause 45.3 lists that address as a way to complain.

Exhibit 17WarningHarder than usual

No action, regardless of form, arising out of transactions under this Agreement may be brought by the Client after three months have elapsed from the day that the cause of action arose.
Clause 33 in Client Account Agreement, p.25
Read from the broker's site on Open the reference

Buried at section 125 of 197 in the Client Account Agreement, 63% of the way through.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Within 24 hoursReport any error in a statement in writing, or the statement binds you.22
Within 2 working daysWindsor sends a written acknowledgment of a valid complaint.45.4
Within 21 business daysWindsor aims to send its final response.45.5
Up to 90 daysWindsor may take this long for a complaint it calls complex.45.5
Three months after the cause of actionYou can no longer bring any action against Windsor.33
  • Worse together with Exhibit 3While the three-month clock runs, a single trade can settle the complaint you are waiting on.

A chargeback is a refund you ask your own card issuer for. Windsor's agreement says you give up that route once a transaction is executed, and makes you pay for any dispute, staff time included.

Why this matters

If a card payment goes wrong, the contract steers you away from the one remedy that does not depend on Windsor. Clause 28.4 also lets Windsor hold the disputed amount in reserve until the dispute ends.

Exhibit 18WarningHarder than usual

The Client further confirms and acknowledges that the right of the Chargeback shall not be permitted in cases when the Company has already executed a requested transaction.
Clause 28.1 in Client Account Agreement, p.20
Read from the broker's site on Open the reference

Where it sits: section 104 of 197 in the Client Account Agreement, 53% of the way through.

Windsor's safety promises are not in its contract

Windsor Brokers' Chinese page promises each client up to $5 million of insurance, and its Arabic page says Windsor never interferes with your account. The certificate Windsor publishes covers its own liability under one group-wide limit, and the client agreement lets it close your trades for any reason. Its 2% interest and swap-free promises also shrink under the loyalty terms.

Promise versus contract2 clauses flagged

Windsor advertises up to 2% interest that you 'earn even when you are not trading'. It is paid in loyalty points, needs Gold status, and stops if Windsor moves you back to Silver for trading too little.

Why this matters

The loyalty terms let Windsor change the rate at any time without notice. The client agreement goes further: Windsor pays no interest, and you waive any right to it.

Exhibit 11WarningHarder than usual2%

The Client acknowledges that the Company will not pay any interest to the Client on any funds held on the Client’s behalf or otherwise under this Agreement and the Client further waives any entitlement to interest on such funds.
Clause 8.5 in Client Account Agreement, p.9
Read from the broker's site on Open the reference

Where it sits: section 48 of 197 in the Client Account Agreement, near the start.

What it costsAt Gold, $10,000 of equity earns 0.4% a year, which is 40 points. Redeemed in a batch under 100 points, each point pays $1, so the year is worth $40.

Windsor's Arabic account page ticks 'account without overnight fees' on every account type. Its loyalty terms limit that to 7 days per trade for new clients, and let Windsor apply swaps, the overnight financing fee, 'at any time if deemed necessary'.

Why this matters

The same terms offer swap-free accounts only in 'specific regions', naming Latin America and South-East Asia but no Arabic-speaking country. Past the grace period you pay swaps, or 'storage', which Windsor's agreement says is always a charge.

Exhibit 12WarningHarder than usual7 days

Storage is always a negative amount and may apply per position after an instrument-specific grace period
Clause 42.8 in Client Account Agreement, p.28
Read from the broker's site on Open the reference

Buried at section 133 of 197 in the Client Account Agreement, 68% of the way through.

The homepage says no charges; the contract lists several

Windsor Brokers keeps any balance under $50 when it closes an account and calls it an administration charge. Its agreement adds a 1% to 2% margin on currency conversions and puts deposit and withdrawal costs on you. Windsor can also charge the full transfer fee when it doubts a deposit's purpose. If Windsor never tells you about a charge, clause 5.2(d) says you should ask.

Cost disclosure3 clauses flagged

Windsor's homepage says there are no charges on deposits or withdrawals, yet its own withdrawal table lists $3 per transaction for several methods. The agreement puts deposit and withdrawal costs on you, and lets Windsor charge the full fee whenever it thinks a deposit was not for trading.

Why this matters

A fee Windsor can switch on by judging your purpose is a fee you cannot plan for. Clause 17.8 also lets Windsor recover charges it never applied before if it merely suspects abuse.

Exhibit 10WarningHarder than usual$3

The Client hereby agrees and acknowledges that the Company shall consider only the net amounts received while costs related to deposits and withdrawals shall be borne by the Client.
Clause 29.2 in Client Account Agreement, p.21
Read from the broker's site on Open the reference

Where it sits: section 110 of 197 in the Client Account Agreement, 56% of the way through.

When your profits, losses or charges are in another currency, Windsor converts them at a rate up to 2% away from the market rate. The Key Facts Statement mentions conversion costs but gives no figure.

Why this matters

Every profit or loss in another currency loses up to 2% in conversion, on top of the spread and any commission. The rate is one Windsor sets itself, and it may differ from public interbank rates.

Exhibit 13WarningHarder than usual2%

The Company is hereby authorized to convert funds in the Client's accounts into and from such foreign currency, at such currency conversion rate based on the prevailing market rate plus/minus 1% up to 2%.
Clause 11.1 in Client Account Agreement, p.11
Read from the broker's site on Open the reference

Where it sits: section 60 of 197 in the Client Account Agreement, 30% of the way through.

What it costsA profit worth $1,000 in another currency, converted 2% below the market rate, reaches your balance as $980.

If Windsor does not tell you about a charge, for whatever reason, the agreement says you should ask for an explanation. The agreement leans on a separate Trading Conditions document, but the link with that name on Windsor's documents page opens the client agreement again.

Why this matters

You cannot check a cost against a document you cannot find. Windsor's Kenyan agreement promises that every charge appears on your account statement; the Seychelles agreement leaves that promise out.

Exhibit 15WarningHarder than usual

d. in cases where the notification of specific charge/costs is not provided to the Client, for whatsoever reason, the Client should inquire and obtain the reasonable explanation for such charge/costs;
Clause 5.2(d) in Client Account Agreement, p.7
Read from the broker's site on Open the reference

Where it sits: section 35 of 197 in the Client Account Agreement, near the start.

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

Firms licensed by the FCA or CySEC must tell a retail client about all costs and charges before the first trade, and send a statement of the costs actually paid at least once a year. This agreement makes it your job to ask about any charge Windsor did not tell you about.

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

Windsor can change the rules without telling you directly

Windsor Brokers can change its agreement by posting the new terms online, with immediate effect, and your next trade counts as acceptance. It can also raise margin on positions you already hold, with or without notice. It sends no margin call warning, and starts closing trades below a 20% margin level.

Unilateral control2 clauses flagged

Windsor can change the agreement by posting the change on its website, with immediate effect. The first trade you place afterwards counts as your acceptance of the new terms.

Why this matters

You may never see the notice, but you will keep trading, and that is enough. The bonus terms go further and allow changes without any notice at all.

Exhibit 20WarningHarder than usual

the Client acknowledges and agrees that the first transaction in any of the Client’s accounts initiated by the Client, following a change to the terms and conditions of this Agreement as abovementioned, shall constitute the Client’s acceptance of the change as of the effective date of the amendment or variation
Clause 30.1 in Client Account Agreement, p.22
Read from the broker's site on Open the reference

Where it sits: section 113 of 197 in the Client Account Agreement, 57% of the way through.

Windsor will not tell you when your account reaches a margin call, the level where your money only just covers the margin your trades need. It can raise margin on trades you already hold, with or without notice, and starts closing positions below 20%.

Why this matters

An unannounced margin change can push you to stop-out, and Windsor then closes your trades, worst loss first. Clause 15.2 even lets Windsor cut your leverage, the multiple of your money you can trade, for using it to chase returns.

Exhibit 21WarningHarder than usual20%

The Client will not receive any notification or message informing them that their Account is on margin call.
Clause 12.3 in Client Account Agreement, p.12
Read from the broker's site on Open the reference

Where it sits: section 64 of 197 in the Client Account Agreement, 32% of the way through.

What it costsAt a 20% stop-out, trades that need $1,000 of margin are closed once your equity drops below $200.

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

Under ESMA's CFD rules, which CySEC and the FCA apply to retail clients, leverage on major currency pairs is capped at 30 to 1, and a firm must close positions once margin falls to 50% of the requirement. Windsor advertises leverage of up to 1:2000 and sets its stop-out at 20%.

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

Silence lets Windsor move your account to another firm

Windsor Brokers can assign your account to another financial institution on 5 days' notice. Unless you object in writing before the date, your silence binds you, and the new firm may answer to a different regulator.

Account transfer1 clause flagged

Windsor can assign your account to another financial institution by telling you its name 5 days ahead. If you do not object in writing before that date, your silence counts as agreement.

Why this matters

The new firm could be in another country, under a different regulator. Five days leaves little time to check it, and doing nothing binds you.

Exhibit 19WarningHarder than usual5 days

The Company may assign the Client's account to another financial institution by notifying the Client of the name of the intended assignee and the date of the assignment, five (5) days prior to the assignment.
Clause 36 in Client Account Agreement, p.25
Read from the broker's site on Open the reference

Buried at section 126 of 197 in the Client Account Agreement, 64% of the way through.

Stale details can stop your money, and data risk is yours

Windsor Brokers can refuse a deposit or withdrawal whenever it judges any of your details unverified or out of date. The agreement makes you cover Windsor's losses linked to your data when outside providers handle it. The privacy policy treats any use of the website as consent.

Data and verification2 clauses flagged

Windsor can refuse a deposit or withdrawal if any of your details is not fully verified or up to date, in Windsor's judgement. It can also end the agreement at once if it believes you moved without telling it.

Why this matters

A verification check can come up again at the moment you ask for your money, not only when you deposit. Until Windsor is satisfied, the withdrawal waits.

Exhibit 22WarningStandard wording

The Company reserves the discretion to decline deposit and withdrawal transactions if the email, telephone number, identity, address, or any other information provided or collected by the Client is not fully verified or up to date, as determined by the Company.
Clause 29.5 in Client Account Agreement, p.22
Read from the broker's site on Open the reference

Where it sits: section 113 of 197 in the Client Account Agreement, 57% of the way through.

The agreement makes you cover Windsor's losses linked to your information whenever it uses outside service providers. The privacy policy treats your use of the website as consent, and disclaims liability for misuse of your data, even through 'malicious intervention'.

Why this matters

If a provider Windsor chose leaks your data, the contract points the cost back at you. The privacy policy also says Windsor 'may not always comply' with your data requests.

Exhibit 24NoticeHarder than usual

The Client furthermore indemnifies the Company and holds the Company harmless from and against any and all liabilities, losses, costs, or expenses related to the Client’s information in cases where Service Providers are used in the execution of their obligations towards the Company and that of the Client
Clause 24.1 in Client Account Agreement, p.19
Read from the broker's site on Open the reference

Where it sits: section 100 of 197 in the Client Account Agreement, 51% of the way through.

Your introducer's pay can come out of your spread

Windsor Brokers is the other side of every trade you place, and its staff may trade against you. Clause 26.2 lets it charge introduced clients more, through wider spreads or extra fees, to pay their introducer. Its partner offer promises introducers rebates of up to 60%.

Who profits1 clause flagged

If an introducer referred you, Windsor may charge you more to cover what it pays that introducer. The extra can come as a wider spread, the gap between buy and sell prices, or as higher commission and fees.

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

Your costs can depend on who sent you, and Windsor's partner offer promises introducers rebates of up to 60%. Windsor is also the other side of your trades, and its staff may trade against you.

Exhibit 23WarningHarder than usual

The Client acknowledges, agrees and confirms that additional costs, including but not limited to increased spread, commission, fees etc, and may be applicable in cases where the Client is introduced to the Company through introducer, since the Company may be required to pay commissions, fees or other related costs to the introducer and associated persons.
Clause 26.2 in Client Account Agreement, p.20
Read from the broker's site on Open the reference

Where it sits: section 103 of 197 in the Client Account Agreement, 52% of the way through.

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

Firms licensed by the FCA or CySEC must tell clients about payments they make to third parties such as introducers, and must give clients a description of their conflicts of interest policy. Clause 26.2 lets introduced clients pay more to fund those payments, and we found no conflicts policy in Windsor's legal section, although its Key Facts Statement says one is there.

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

Six quiet months freeze the account and start a fee

After six months without a trade, Windsor Brokers stops your account trading and may charge a monthly fee of unstated size. Windsor then treats the account as dormant and removes it from its systems, and on closure keeps any balance under $50.

In plain words

Dormancy means an account left unused.

Dormancy rules1 clause flagged

After six months without a trade, your account stops trading and a monthly inactivity fee may start. Windsor then treats it as dormant and removes it from its systems. No Windsor document says how big the fee is.

Why this matters

A dormant account can be closed, and Windsor keeps any balance under $50 when it closes. Six idle months also reset your loyalty points, and any interest paid in them, to zero.

Exhibit 14WarningHarder than usual

Such inactive accounts will no longer be available for trading and will be subject to relevant charge/costs relating to the maintenance/administration of such inactive accounts.
Clause 21.1 in Client Account Agreement, p.17
Read from the broker's site on Open the reference

Where it sits: section 89 of 197 in the Client Account Agreement, 45% of the way through.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
First month with no deposit or tradeWindsor may close a new account without further notice.21.7
One month idle at zero balanceThe account counts as inactive.21.2
Six months without a tradeThe account is inactive: trading stops and maintenance charges apply.21.1
Once inactiveWindsor treats the account as dormant and removes it from its systems.21.4
Closure with under US$50Windsor zeroes the remaining balance and owes no refund.5.4
  • Worse together with Exhibit 4Inactivity leads to dormancy and closure, and closure is where clause 5.4 keeps any balance under $50.

Segregated on paper, pledgeable in the small print

Windsor Brokers International Ltd, licensed in Seychelles under licence SD 072, is the counterparty under the agreement. Clause 8.4 says client funds are segregated, yet clause 19.2 lets Windsor pledge or invest property it holds for clients. No Windsor document names a compensation scheme, and payments may pass through two Cypriot companies the website names.

Who holds your money2 clauses flagged

Windsor's insurance page calls your money 'fully protected' in segregated accounts. The agreement lets Windsor pledge or invest your property, and its risk statement warns that if Windsor fails, you may not get your funds back.

Why this matters

Segregation only helps if the money stays put. A right to pledge or invest client property, keeping the income, lets Windsor put your assets to work for itself.

Exhibit 9WarningHarder than usual

The Client hereby grants to the Company the right to pledge, repledge, hypothecate, or invest either separately or with the property of other clients, any securities or other property held by the Company for the Client’s accounts or as collateral therefore
Clause 19.2 in Client Account Agreement, p.16
Read from the broker's site on Open the reference
Our own capture of windsorbrokers.com, taken on Oct 24, 2026The claim, on Arabic insurance page, Security panelVisit this page on the broker's siteDownload the full size image file

Where it sits: section 88 of 197 in the Client Account Agreement, 45% of the way through.

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

Under MiFID rules applied by CySEC, and under the FCA's client money rules, a firm must keep retail client money segregated, may not use it for its own account, and may not take it under a title transfer arrangement. Clause 19.2 of this agreement lets Windsor pledge, re-pledge or invest property it holds for you and keep the income.

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

The Seychelles agreement makes Windsor Brokers International Ltd your counterparty, licensed by the Seychelles Financial Services Authority under licence SD 072. The website names two Cypriot companies, WB Global Ltd and WIT IT Solutions Ltd, as facilitators of client payments.

Why this matters

Your protection is what Seychelles rules give you, and no published document names a compensation scheme. The website also lists a British Virgin Islands company, and the loyalty terms a Palestinian one, with no agreement published for either.

Exhibit 25NoticeStandard wording

Windsor Brokers International Ltd (the “Company”) is a Seychelles Company regulated by the Seychelles Financial Services Authority (“FSA”).
Quoted in Client Account Agreement, p.3
Read from the broker's site on Open the reference

Where it sits: section 2 of 197 in the Client Account Agreement, near the start.

Where the marketing and the contract disagree

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

01

The Arabic page says Windsor keeps no right to interfere with your account; clause 14(f) lets it close your trades for any reason.

Said in public, in Arabic

نحن لا نحتفظ بأي حق في التدخل في حسابات التداول، والتي تبقى تحت السيطرة الكاملة لعملائنا.

Word for word in English: We do not retain any right to interfere in trading accounts, which remain under the full control of our clients.

Arabic insurance page, Security panel

In the contract · clause 14(f)

at any time the Company deems it necessary for its protection for any reason whatsoever, the Company may, in the manner it deems appropriate, close out the Client's open trades in whole or in part, sell any or all of the Client's property held by the Company

02

The Chinese page promises each client up to $5 million; the certificate shows one $5 million limit for all claims against the whole group each year.

Said in public, in Chinese

考虑到这一点，我们希望通过为每个客户提供高达5,000,000美金的客户保险来增加额外的安全保障！

Word for word in English: With this in mind, we want to add an extra layer of security by providing each client with up to US$5,000,000 of client insurance!

Simplified Chinese insurance page, opening paragraph

In the contract

Limit of Liability: USD5,000,000 each and every Loss and in the aggregate all Claims from all companies, in the annual aggregate including Costs

03

The page promises withdrawals with no restrictions; clause 29.3 lets Windsor hold or refuse all or part of a withdrawal on nine grounds.

Said in public, in English

You can use your capital to trade, redeem your loyalty points at any time, and withdraw your balance and cash rewards with no restrictions!

Interest Rate APY page, panel headed 'Withdraw instantly, anywhere, anytime.'

In the contract · clause 29.3

The Client further acknowledges and agrees that the Company reserves the right to withhold or reject (partially or in whole) the Client’s request for withdrawal in cases where:

04

The FAQ promises every withdrawal within 1 working day; the agreement says withdrawals need approval and are generally processed within a few business days.

Said in public, in English

All withdrawals are processed within 1 working day from the request date.

Deposits and Withdrawals page, FAQ on withdrawal processing time

In the contract · clause 29.3

The withdrawals are affected only upon receipt and approval of such request by the Company and are generally processed within a few business days

05

The homepage says no charges on deposits or withdrawals; clause 29.2 puts those costs on you.

Said in public, in English

No charges on deposits or withdrawals*

Homepage deposits and withdrawals panel, with an asterisk pointing to the client portal for full details

In the contract · clause 29.2

The Client hereby agrees and acknowledges that the Company shall consider only the net amounts received while costs related to deposits and withdrawals shall be borne by the Client.

06

The Arabic page ticks swap-free for every account; the loyalty terms limit it to Kenyan clients and Seychelles clients in 'specific regions' whose examples include no Arabic-speaking country.

Said in public, in Arabic

حساب بدون رسوم تبيت

Word for word in English: Account without overnight (swap) fees

Arabic account types page, feature row ticked for PRIME, ZERO and VIP ZERO

In the contract · clause Trading Benefits A.1

Swap-free accounts are available ONLY to Clients of Windsor Markets (Kenya) Limited and to Clients of Windsor Brokers International Ltd. residing in specific regions, such as Latin America (LATAM) and South-East Asia (China, Indonesia, Vietnam, Thailand, and Korea).

07

The page says you earn even when you are not trading; the loyalty terms let Windsor downgrade you for trading too little, and the Silver tier earns 0%.

Said in public, in English

Earn even when you are not trading

Interest Rate APY page, headline and benefits list

In the contract · clause Earning Activities A.4

In addition to the upgrade and reset rules, Clients who do not meet the required trading activity within specific timeframes may be downgraded to the previous Loyalty Status.

08

The Arabic page calls your funds fully protected; the agreement's risk statement warns that if Windsor fails, you may not recover them.

Said in public, in Arabic

تُحفظ أموال عملائنا في حسابات منفصلة وهي محمية بالكامل.

Word for word in English: Our clients' funds are kept in separate accounts and are fully protected.

Arabic insurance page, Security panel

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

In the contract · clause Risk Disclosure Statement 2

Counterparty risk is inherent in OTC transactions, meaning that if the Company fails to meet its obligations, you may not recover your funds.

The documents this reading is based on

14 files, all published by Windsor Brokers. 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 Windsor Brokers publishes.

How this reading was done

Every clause above was read out of a document Windsor Brokers publishes itself

This reading was published on .

Documents
9 of 14downloaded from the broker's site, and 9 read in full
Pages opened
28pages walked to find those documents, footer links included
Marketing pages
11public pages set against what the contract says
Languages
AR vs EN vs ZHthe language it advertises in, against the language it contracts in
Position measured
23clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

Windsor Brokers International Ltd

The Seychelles agreement names Windsor Brokers International Ltd as your counterparty. It is registered in Seychelles under number 8425783-1 and licensed by the Seychelles Financial Services Authority under licence SD 072. Windsor's regulation page says this company serves the rest of the world except the USA and the EEA. Kenyan clients contract with Windsor Markets (Kenya) Limited, regulated by the Capital Markets Authority. Seldon Investments Limited is the Jordanian company regulated by the Jordan Securities Commission. The English version of Seldon's agreement repeats the complaint, 24-hour, three-month and $50 clauses described here. No reviewed document names a Cyprus company holding a CySEC licence, and the website footer says the services are not offered in Europe. The website is run by WIT IT Solutions Ltd of Cyprus. The website terms name it, together with WB Global Ltd, as a facilitator of client payments.

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

Windsor Brokers publishes its full client agreement, a Key Facts Statement that sets out costs and loss scenarios, and the insurance certificate behind its marketing. That means a reader can check each claim against Windsor's own files. The agreement puts negative balance protection in writing in clause 42.7, so your losses cannot exceed what you deposited. There is one carve-out: clause 17.3 treats trading designed to exploit that protection as abuse. The agreement confirms client money is segregated (8.4). It gives a 14-day right to cancel as long as you have not yet deposited or traded (30.6). It also sets a 21-business-day target for answering complaints, with a route to the Seychelles regulator (45.5, 45.6). Windsor's Kenyan agreement is gentler in two places: it promises that every charge appears on your statement, and it has no power to delay withdrawals on suspicion.

This review covers Windsor's Seychelles and Kenyan client agreements, its privacy, cookie and risk pages, its Key Facts Statement, its website terms, both insurance certificates, the complaint form, and the English text of its bonus and loyalty terms. It does not cover the translations inside the bonus and loyalty files. Both files say the English version prevails. The Arabic agreement of Seldon Investments Limited (Jordan) could not be read, because its text would not open in a readable form. That company's English agreement is covered only for the clauses discussed. On Windsor's documents page, each 'Trading Conditions' link opens either the client agreement again or, for Jordan, the Arabic agreement, so no separate Trading Conditions document appears on the page. The review does not cover the client portal, where Windsor says more fee details are kept. Windsor publishes no amount for the monthly inactivity fee. The review compares marketing pages in English, Arabic and Simplified Chinese, but not the Thai, Indonesian, Vietnamese, Korean, Portuguese or Spanish versions. No earlier version of any document is available for comparison.

How to check any of this yourself

Every quote above links to the Windsor Brokers 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 Windsor Brokers 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 Windsor Brokers 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 24, 2026.

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

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