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Contract reading

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

Every clause below is published by Wingo 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: Wingo Group LTD

sole discretionhidden feeforum waiverkyc freezeprofit voidingdeemed acceptanceunilateral amendmentwithdrawalsbonus lockcountry restriction

Wingo Markets advertises a Rial deposit channel to Persian readers, then puts the whole question of whether you may trade onto you in one sentence. Two clauses let Wingo take 5% of your money: one when it returns your own deposit, one when you do not keep enough of your balance in open trades. If Wingo decides you abused a credit, it can forfeit your entire balance, and you agreed in advance not to dispute it. The contract names no governing law, no court and no way to complain.

Contract risk

Money at risk
8.4/10

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.
21
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
6
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
5

How the 21 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
Warning13
Notice2

section 29 of 31is where the deepest clause sits, 94% 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.

1 of these 3 figures comes from a clause we rate critical, which means it can take your money or your profit rather than only delay it.

What the documents say

21 clauses worth knowing about, worst first, each quoted from Wingo Markets's own files

01

Wingo's Persian pages advertise a Rial payment gateway beside cards and crypto. The same Persian homepage says Wingo is registered with the United States Treasury. Clause 1.5 of the Terms then makes you, alone, responsible for whether you are allowed to receive the service where you live.

Why this matters

You put money in through a channel Wingo built and advertised to you, and the contract says the legality of that is your problem. If the channel is frozen or the account closed over it, nothing in these documents promises your money back.

Exhibit 1CriticalRarely seen

You may only use our Website and services, if you are not legally prohibited from receiving our services under the laws where you are residing, registered.
Clause 1.5 in Terms of Service, p.2
Downloaded from the broker's site on Open the reference
Our own capture of wingomarkets.com, taken on Sep 8, 2026The claim, on Payment methods section of the Persian homepageVisit this page on the broker's siteDownload the full size image file
Our own capture of wingomarkets.com, taken on Sep 8, 2026What the contract says, clause 1.5Visit this page on the broker's siteDownload the full size image file

Where it sits: section 2 of 31 in the Terms of Service, near the start.

Our readingBrokers normally publish a list of countries they will not accept and refuse registration from them. Wingo publishes no such list in any of its five documents. It instead builds a local currency deposit channel, advertises it in that language, and moves the whole legal question onto the client in one sentence.

  • Worse together with Exhibit 11The contract names no governing law and no court, so a client who deposits through the Rial channel and loses access has no forum written into the agreement.
02

If Wingo decides you abused a credit or bonus, one listed consequence is forfeiture of all existing account balances, not just the bonus and not just the profit. Wingo decides this alone, and clause 3.4 says a shared IP address or matching account data can be treated as conclusive.

Why this matters

Money you deposited yourself can be taken, not only money the bonus produced. The forfeiture is limited to balances affected by the abusive trading, but Wingo decides what was affected and says it need not justify that to you.

Exhibit 2CriticalRarely seen

Forfeiture of all existing account balances, if derived from or affected by the abusive trading.
Clause Credit and Bonus Terms 3.5 in Terms of Service, p.18
Downloaded from the broker's site on Open the reference
Our own capture of wingomarkets.com, taken on Sep 8, 2026Your whole balance can be forfeited over a credit dispute (clause Credit and Bonus Terms 3.5)Visit this page on the broker's siteDownload the full size image file

Buried at section 27 of 31 in the Terms of Service, 87% of the way through.

Our readingCancelling a bonus and stripping bonus profit is ordinary. Reaching past that into the client's own deposited balance is not, and declaring the firm's own evidence conclusive removes the usual check that the client can contest what it showed.

  • Worse together with Exhibit 8The one account per IP rule turns two family members on one home connection into the shared IP address that clause 3.4 treats as conclusive evidence of abuse.
  • Worse together with Exhibit 5Accepting the credit is also the moment you waive the right to dispute the forfeiture, so the two clauses close the loop on each other.
03

If Wingo decides you did something prohibited and chooses to return your money, clause 14.3 lets it keep 5% of everything you deposited into that account. Clause 14.4 says the fee comes out of your funds before Wingo releases them.

Why this matters

This is a charge on your own principal, not on a profit and not on a trade. You pay it for having been investigated, and clause 6.3 on page 6 told you Wingo charges nothing on deposits or withdrawals.

Exhibit 3CriticalRarely seen5%

Where the Company elects to return the initial deposited funds pursuant to this Section, it reserves the right to apply an administrative and compliance commission fee equal to five percent (5%) of the total deposited amount of the affected account.
Clause 14.3 in Terms of Service, p.14
Downloaded from the broker's site on Open the reference
Our own capture of wingomarkets.com, taken on Sep 8, 2026Wingo keeps 5% of your deposit when it gives it back (clause 14.3)Visit this page on the broker's siteDownload the full size image file

Buried at section 20 of 31 in the Terms of Service, 65% of the way through.

What it costsDeposit $10,000, then have the account closed under section 14. Wingo keeps $500 and returns $9,500.

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 that client trades. Wingo's Terms say on page 6 that no fees apply to deposits or withdrawals, and set out this 5% charge eight pages later under a heading about enforcement.

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

Our readingBrokers commonly withhold profit from activity they call abusive. Charging a percentage of the client's own deposited capital as the stated cost of the firm's enforcement work is a different mechanism, and it takes money that was never in dispute.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Wingo decidesWingo determines on its own that your activity was abusive, manipulative or otherwise prohibited.14.1
Account suspendedWingo suspends or closes the account and takes any enforcement action it thinks fit.14.1
Refund cappedAny refund is limited to the money first deposited into that one account, even if you hold others.14.2
5% takenWingo applies a commission of five percent of the total you deposited into the affected account.14.3
Deducted before releaseThe fee comes out of your money before Wingo sends the remainder back.14.4
  • Worse together with Exhibit 6Section 13 and section 14 each carry a separate 5% commission, so one account can be charged twice on two different findings.
04

Wingo's homepage and accounts page both carry the heading Deposit Instantly & Withdraw Without Limits. Clause 6.7 of the Terms says a daily limit on withdrawals in ordinary currency exists and is set in advance. The contract never says what it is.

Why this matters

You cannot plan around a cap nobody publishes. If you need a large sum out on a given day, the only way to find the ceiling is to hit it, and the contract gives you no figure to hold Wingo to.

Exhibit 4CriticalHarder than usual

The daily fiat currencies withdrawal limit is predefined and aligned with the limitations of banking system.
Clause 6.7 in Terms of Service, p.6
Downloaded from the broker's site on Open the reference
Our own capture of wingomarkets.com, taken on Sep 8, 2026The claim, on Section heading on the English account types page and on the English homepageVisit this page on the broker's siteDownload the full size image file
Our own capture of wingomarkets.com, taken on Sep 8, 2026What the contract says, clause 6.7Visit this page on the broker's siteDownload the full size image file

Where it sits: section 7 of 31 in the Terms of Service, near the start.

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

Firms licensed by the FCA or CySEC must make sure a financial promotion is fair, clear and not misleading, and must not state a benefit without the limits that apply to it. Wingo states the benefit as a page heading and puts the limit in a PDF clause that gives no number.

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

  • Same clause as Exhibit 7The same section 6 that hides the daily cap also freezes withdrawals for 72 hours and locks you into the method you deposited with.
05

Taking a credit or bonus means agreeing in advance that you give up all rights to dispute how Wingo enforces the abuse clause. Wingo may explain a decision but says it is not obliged to. None of the five documents sets out a complaints procedure, a deadline, an escalation path or an outside body.

Why this matters

You have no written route to challenge a forfeiture. There is no complaints address, no time limit Wingo must answer within, and no regulator or ombudsman to escalate to, because none of the documents names one.

Exhibit 5CriticalRarely seen

By accepting any Credit or bonus offer, the Client explicitly waives all rights to dispute the enforcement of this clause once evidence of abuse or prohibited trading is reasonably established.
Clause Credit and Bonus Terms 3.6 in Terms of Service, p.18
Downloaded from the broker's site on Open the reference
Our own capture of wingomarkets.com, taken on Sep 8, 2026You waive the right to dispute, and no complaints route exists (clause Credit and Bonus Terms 3.6)Visit this page on the broker's siteDownload the full size image file

Buried at section 27 of 31 in the Terms of Service, 87% of the way through.

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

Firms licensed by the FCA or CySEC must run a written complaints procedure, answer within set time limits, and tell the client about an independent scheme that will look at the complaint free of charge. Wingo publishes no complaints procedure and names no independent scheme.

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

Our readingClient agreements normally set a window to complain and a procedure, even a short and unhelpful one. A waiver of the right to dispute an outcome, signed before the outcome exists, removes the challenge rather than shortening the time to bring it.

  • Worse together with Exhibit 11With no complaints procedure inside the contract and no governing law or court named by it, there is no stated place at all to take a dispute.

Two separate 5% commissions sit eight pages after the promise of no fees

Clause 6.3 tells you on page 6 that Wingo Markets charges nothing for deposits or withdrawals. Clause 14.3 then lets Wingo keep 5% of everything you deposited when it returns your money after an enforcement decision, taken out before release. Clause 13.4 adds a second 5% commission if you fail to keep a tenth of your deposit continuously working as margin.

Cost disclosure1 clause flagged

Clause 13.3 requires you to keep at least 10% of everything you deposited tied up as margin in open positions at all times. Fall below that and Wingo can call it exchange-like activity, and clause 13.4 lets it charge 5% of the value of the transactions or of your profits.

In plain words

Dormancy means an account left unused.

Why this matters

Sitting in cash between trades becomes a chargeable event. A cautious trader who closes positions and waits is exactly who this clause catches, and 5% of turnover can be far more than 5% of what you made.

Exhibit 6CriticalRarely seen5%

the Client must ensure that no less than ten percent (10%) of the total deposited funds is continuously utilized as margin in active trading positions.
Clause 13.3 in Terms of Service, p.14
Downloaded from the broker's site on Open the reference
Our own capture of wingomarkets.com, taken on Sep 8, 2026A 5% charge for not keeping enough money in open trades (clause 13.3)Visit this page on the broker's siteDownload the full size image file

Buried at section 20 of 31 in the Terms of Service, 65% of the way through.

What it costsDeposit $10,000 and Wingo expects at least $1,000 working as margin at all times. On $50,000 of turnover it later reclassifies, the charge is $2,500.

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

Firms licensed by the FCA or CySEC must set out costs and charges before a retail client trades, and must not make a client take on market risk as the condition of avoiding a fee. Wingo makes continuous market exposure the test and prices the shortfall at 5%.

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

Our readingMinimum activity rules usually take the form of a small monthly dormancy fee. Requiring a continuous proportion of the deposit to sit in live market risk, and pricing the shortfall as a percentage of turnover or profit, penalises holding cash rather than penalising an idle account.

What Wingo promises on the page is not what its contract allows

Wingo Markets advertises a Rial deposit channel to Persian readers on the same page that claims registration with the United States Treasury, then makes the client alone responsible for whether they may lawfully trade. Its English pages promise withdrawals without limits and support 24/7, while clause 6.7 confirms an unpublished daily cap and clause 12.3 closes support at weekends. A site on one of Wingo's own domains tells readers the broker is registered in Canada, a country no Wingo document names.

Language arbitrage2 clauses flagged

The stat strip on Wingo's English and Persian homepages reads 24/7 DEDICATED SUPPORT. Clause 12.3 of the Terms sets support hours as Monday to Friday only, and states that Saturday and Sunday are closed.

Why this matters

If a position goes wrong on a Saturday, nobody at Wingo has to answer. Crypto markets trade at the weekend and the contract gives you no one to call while they do.

Exhibit 17WarningStandard wording

Saturday and Sunday: Closed
Clause 12.3.1.2 in Terms of Service, p.12
Downloaded from the broker's site on Open the reference
Our own capture of wingomarkets.com, taken on Sep 8, 2026The claim, on Statistic in the hero strip of the English homepageThis 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 wingomarkets.com, taken on Sep 8, 2026What the contract says, clause 12.3.1.2Visit this page on the broker's siteDownload the full size image file

Where it sits: section 17 of 31 in the Terms of Service, 55% of the way through.

The site at wingomarketsbroker.com says Wingo Markets is registered in Canada and sends its signup buttons through a Wingo tracking link on client.wingomarkets.com. Its footer says it is not the official website. No Wingo document mentions Canada.

Why this matters

Canada tells a reader there is a real regulator and a compensation scheme behind the account. The contract you actually sign points at Saint Lucia, Comoros and the European Union, and names no regulator at all.

Exhibit 18WarningRarely seen

This Privacy Policy is governed, construed, interpreted, and enforced in accordance with the laws of Comoros, and the European Union.
Quoted in Privacy Policy, p.1
Read from the broker's site on Open the reference
Our own capture of wingomarketsbroker.com, taken on Sep 8, 2026The claim, on Opening paragraph on wingomarketsbroker.com, a domain recorded as Wingo's, whose signup buttons link to client.wingomarkets.comVisit this page on the broker's siteDownload the full size image file
Our own capture of wingomarkets.com, taken on Sep 8, 2026What the contract saysVisit this page on the broker's siteDownload the full size image file

Our readingAn unofficial fan or education site is ordinary. One sitting on a domain recorded as the broker's own, running the broker's signup funnel through the broker's own client subdomain while disclaiming that it speaks for the broker, puts a country claim in front of readers that nobody has to stand behind.

Almost every Wingo withdrawal triggers a fresh identity check

Clause 6.9 sends anything over USDT 100 back through final identity verification, plus a notification to a personal support agent on a channel Wingo chooses, with no deadline on either. Money deposited in ordinary currency is frozen for 72 hours, and clause 6.6 means funds can only leave by the route they arrived on.

Getting money out1 clause flagged

Anything over USDT 100 is only processed after final identity verification and after you notify a personal support agent through a channel Wingo picks. Money deposited in ordinary currency is frozen for 72 hours, and you can only take funds out by the route they came in.

Why this matters

A $100 threshold means almost every real withdrawal triggers a re-check, and the contract sets no deadline for finishing it. If your card or bank channel stops working, clause 6.6 gives you no other way out.

Exhibit 7WarningHarder than usual$100

Withdrawals exceeding USDT 100 or its fiat currency equivalent are only processed after final identity verification and notification to the personal support agent via communication channels defined by us.
Clause 6.9 in Terms of Service, p.7
Downloaded from the broker's site on Open the reference

Where it sits: section 9 of 31 in the Terms of Service, 29% of the way through.

Wingo can decide alone that your profit, or your balance, is not yours

Wingo can forfeit all existing account balances over credit abuse it determines by itself, on evidence such as a shared IP address that clause 3.4 calls conclusive. Clause 4.9 lets it cancel any trade it finds irrational, a word the contract never defines, and section 9.7 lets it declare profits from trades it classifies as high frequency invalid and reverse them.

Exit conditions1 clause flagged

Clause 4.9 lets Wingo cancel any trade it finds irrational, unusual or suspicious, at its sole discretion. The word irrational is never defined. On trades it classifies as high frequency, section 9.7 lets Wingo declare the profits invalid, null and void and reverse them.

Why this matters

A profitable run can be undone after the fact on a test only Wingo applies. You could not show a trade was rational, because the contract never says what rational means.

Exhibit 9WarningHarder than usual

In the event of detecting irrational, unusual, or suspicious trades, the Company reserves the right to cancel such trades at its sole discretion.
Clause 4.9 in Terms of Service, p.5
Downloaded from the broker's site on Open the reference

Where it sits: section 6 of 31 in the Terms of Service, near the start.

Requesting a withdrawal is itself a reason to remove your credit

Clause 2.3 of the Wingo Credit and Bonus Terms lets Wingo adjust, remove or cancel the credit in part or in full as soon as you ask to withdraw, judged on the size of the request and how the account has traded. Clause 1.3 lets Wingo end any bonus programme at any time without prior notice, and clause 4 lets it remove credit or the profit made with it on suspicion alone.

Credit strings1 clause flagged

Clause 2.3 of the Credit and Bonus Terms lets Wingo adjust, remove or cancel your credit in part or in full the moment you request a withdrawal, based on how much you asked for and how the account has traded. Clause 1.3 lets Wingo end any bonus programme at any time without telling you first.

Why this matters

The margin holding your open positions can shrink because you asked for your own money back. Positions sized around the credit may then be closed out, and the contract sets no notice and no amount you can safely withdraw.

Exhibit 10WarningHarder than usual

If a Client initiates a fund withdrawal from a Credit-supported account, the Company reserves the right to adjust, remove, or cancel the Credit amount partially or in full, depending on withdrawal size and account activity.
Clause Credit and Bonus Terms 2.3 in Terms of Service, p.16
Downloaded from the broker's site on Open the reference

Buried at section 24 of 31 in the Terms of Service, 77% of the way through.

One account per connection, terms that move, and rules that contradict

Clause 2.11 allows Wingo Markets clients one trading account per IP address, and clause 12.4.2 treats a matching IP or device fingerprint as sufficient on its own to confirm unauthorised behaviour. Clause 11.3 lets Wingo change the terms whenever it thinks necessary and clause 11.2 counts notice as delivered whether you got it or not. Clause 4.13 permits automated trading tools while clause 9.4 bans them.

Account rules3 clauses flagged

Clause 2.11 allows you one trading account per IP address. Clause 12.4.2 says matching device fingerprints, IP addresses or access characteristics are on their own sufficient grounds to confirm unauthorised behaviour, and Wingo can then suspend accounts and void profits.

Why this matters

Two people trading from the same home, office or phone network break this rule without doing anything wrong. The contract treats the shared connection as proof, so you would be arguing against a conclusion Wingo has already called sufficient.

Exhibit 8WarningHarder than usual1

You may create maximum 3 (three) demo accounts and one trading account with the Company per the same IP address.
Clause 2.11 in Terms of Service, p.3
Downloaded from the broker's site on Open the reference

Where it sits: section 3 of 31 in the Terms of Service, near the start.

  • Worse together with Exhibit 2A shared IP address satisfies this rule and is the first item on the credit abuse evidence list that can end in forfeiture of the whole balance.

Clause 11.3 lets Wingo update the rules and terms whenever it thinks it necessary, with no notice period. Clause 11.2 says anything Wingo posts or sends is treated as delivered to you personally, whether you received it or not. None of the five documents carries a version number or a date.

Why this matters

You are bound by a version you may never have seen, and you cannot check when it last changed because Wingo does not stamp its documents. Clause 11.5 uses the same route to move the margin call level on your open positions.

Exhibit 15WarningHarder than usual

The Company reserves the right to update the rules and terms of service if necessary. Such changes will be communicated through official channels.
Clause 11.3 in Terms of Service, p.12
Downloaded from the broker's site on Open the reference

Where it sits: section 17 of 31 in the Terms of Service, 55% of the way through.

Clause 4.13 says robots and automated trading tools may be used on Wingo's platform if they behave logically. Clause 9.4, under Prohibited Activities, bans the use of certain automated trading systems or Expert Advisors. Neither clause says which ones.

Why this matters

You cannot tell whether your own automated strategy is permitted until Wingo decides, and by then section 9.6 lets it close the account and charge you a penalty. The word certain is doing all the work in the ban.

Exhibit 16WarningHarder than usual

Using certain trading techniques commonly known as "arbitrage trading", "picking/ sniping" or the use of certain automated trading systems or "Expert Advisors".
Clause 9.4 in Terms of Service, p.8
Downloaded from the broker's site on Open the reference

Where it sits: section 11 of 31 in the Terms of Service, 35% of the way through.

Wingo's contract names no governing law and no court at all

The Wingo Markets Terms of Service contain no governing law clause and name no forum. Its AML and KYC Policy says clients are identified under Saint Lucia law, and its Privacy Policy says it is governed by the laws of Comoros and the European Union. Wingo's own pages add addresses in Montenegro, Cyprus and the Comoros.

Which law applies1 clause flagged

Wingo's Terms of Service contain no governing law clause and name no court. The AML and KYC Policy says Wingo identifies clients under Saint Lucia law. The Privacy Policy says it is governed by the laws of Comoros and the European Union.

Why this matters

You cannot tell which country's law your contract sits under or where a claim would be heard, because the document that creates the relationship does not say. Working that out would be the first argument in any dispute, before anyone looked at your money.

Exhibit 11WarningRarely seen

Wingo Group LTD does not give individual the option of dealing with them anonymously, or under a pseudonym, as Wingo Group is required to identify all trading client under the Saint Lucia Anti-Money Laundering and Terrorist Financing Law, as amended.
Clause 1 in AML / KYC Policy, p.2
Read from the broker's site on Open the reference
Our own capture of wingomarkets.com, taken on Sep 8, 2026The claim, on Risk warning in the footer of the Persian homepageVisit this page on the broker's siteDownload the full size image file
Our own capture of wingomarkets.com, taken on Sep 8, 2026What the contract says, clause 1Visit this page on the broker's siteDownload the full size image file

Where it sits: section 4 of 41 in the AML / KYC Policy, near the start.

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

Firms licensed by the FCA or CySEC must give a retail client an agreement stating the law that applies and the courts that will hear a dispute. Wingo's Terms state neither, and its other documents point at different countries.

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

Our readingA governing law and jurisdiction clause appears in essentially every client agreement, including offshore ones. Its complete absence, in a document that elsewhere calls the firm's own determinations final and binding, leaves the client with obligations spelled out and a forum that is not.

Wingo widened what it does with your data and stopped saying for how long

Wingo Markets deleted its 2024 promise not to give client personal data to third parties for marketing, and now lists marketing and advertising firms among the recipients. A stated seven year retention period became a fixed term with no figure, and photo, video and audio biometrics were added to what Wingo collects. Its AML policy says Wingo need not tell you why an order, an account or a document demand was refused.

Your data3 clauses flagged

The 2024 Privacy Policy told you plainly that Wingo does not sell or provide your personal information to third parties for marketing purposes. That sentence is gone. The current policy instead lists marketing and advertising companies among the third parties Wingo may pass your data to.

Why this matters

The information you handed over to pass identity checks, including your income, your employment and your trading history, can now go to advertisers. Wingo added debt recovery agencies to the same list.

Exhibit 12WarningHarder than usualNew

Third parties, including those in the fintech, brokerage industry, marketing and advertising sectors, to use personal data in order to let a person know about services which may be of interest to such person in accordance with the Applicable Legislation;
Clause Disclosure of Personal Data, item 7 in Privacy Policy, p.10
Read from the broker's site on Open the reference

The AML and KYC Policy says Wingo need not tell you why it refused to execute your trading order, refused to open your account, or demanded more documents. Wingo can also demand original documents whenever it has any doubt, and non-compliance ends the agreement at its sole discretion.

Why this matters

A rejected order or a frozen account comes with no explanation you can act on. You cannot fix a problem Wingo will not describe, and the same policy makes not fixing it grounds to close you down.

Exhibit 13WarningHarder than usual

In addition, the Company is not obliged to inform you or other people about any suspicions about the reasons for the refusal of execution of your trading order, refusal to open the account, need for providing any documents, etc.
Clause 5 in AML / KYC Policy, p.4
Read from the broker's site on Open the reference

Buried at section 33 of 41 in the AML / KYC Policy, 80% of the way through.

The 2024 Privacy Policy said Wingo could hold your records for seven years after the relationship ended. The current one drops that and says only that data is stored for a fixed term, without saying how long. The same rewrite added photo, video, audio and other biometric identifiers to what Wingo collects.

Why this matters

You no longer have a date after which your identity documents and trading history should be gone. Your face and voice are now on the list, held for as long as everything else, which is a period Wingo does not state.

Exhibit 14NoticeHarder than usualNew

As required by the AML and CFT requirements, we must store any collected information within a fixed term from relationship termination.
Clause Right to Erasure in Privacy Policy, p.11
Read from the broker's site on Open the reference

Wingo may execute your order against itself at its own price

Clause 3.4 authorises Wingo Markets to execute your orders with counterparty banks, with liquidity providers, or with the Company itself, whichever it deems appropriate. Clause 3.1 obliges you to accept Wingo's quoted prices as the basis for every trade, and no document names an outside reference price. Wingo publishes no conflict of interest policy and no execution policy.

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.

Liquidity providers are outside banks and brokers.

Who is on the other side1 clause flagged

Clause 3.4 lets Wingo execute your orders with counterparty banks, with liquidity providers, or with itself, whichever it thinks appropriate. Clause 3.1 obliges you to accept Wingo's own quoted prices as the basis for every trade. Wingo publishes no conflict of interest policy.

Why this matters

When Wingo takes the other side, your loss is its gain, and it also sets the price you lost at. There is no outside benchmark named anywhere in the documents and no policy explaining how the conflict is managed.

Exhibit 19WarningHarder than usual

Unless instructed by the Client to the contrary in writing, the Company is authorized to execute all Orders with such counterparty banks, financial institutions, registered participants, or the Company itself, as the Company deems appropriate.
Clause 3.4 in Terms of Service, p.4
Downloaded from the broker's site on Open the reference

Where it sits: section 4 of 31 in the Terms of Service, near the start.

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

Firms licensed by the FCA, CySEC or under ESMA rules must keep a conflicts of interest policy, disclose to a retail client when they deal on their own account, and take all sufficient steps to get the best result on execution. Wingo publishes no conflicts policy and no execution policy.

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

Wingo names no regulator and does not say your money is kept separate

Wingo Group LTD's own AML policy says it answers to the local regulator without naming it, and none of the five documents mentions MISA, FinCEN or any supervisor. No document says client money is held separately from the company's own funds, and none names a compensation scheme. The Credit and Bonus Terms also override a General Terms and Conditions of Business that Wingo does not publish.

What is missing2 clauses flagged

The Credit and Bonus Terms say they form part of Wingo's General Terms and Conditions of Business and override that document where the two conflict. No document by that name is published. Wingo also publishes no payment terms, no complaints procedure, no conflict of interest policy and no copy trading terms.

Why this matters

You are told which document wins a conflict without being shown the loser. Wingo's social trading pages advertise provider performance fees of 5% to 30%, and no contract anywhere on the site sets out how those are charged.

Exhibit 20WarningHarder than usual

In the event of conflict between this Agreement and the General Terms and Conditions of Business, this Agreement shall prevail with respect to Credit and Bonus matters.
Clause Credit and Bonus Terms 5.2 in Terms of Service, p.19
Downloaded from the broker's site on Open the reference

Buried at section 29 of 31 in the Terms of Service, 94% of the way through.

Wingo's own AML and KYC Policy says it follows requirements set by the local regulator, without naming which one. None of the five documents mentions MISA, FinCEN or any supervisor. None says client money is held separately from the company's own, and none names a compensation scheme.

Why this matters

If Wingo Group LTD fails, nothing you signed says your balance is ring-fenced or that anyone would pay you back. The licence numbers on the website appear in no document you are bound by.

Exhibit 21NoticeStandard wording

Wingo Group LTD (referred to as the "Company" or "Wingo group") is obliged to follow certain requirements as set out by the local regulator for preventing and suppressing money laundering activities
Quoted in AML / KYC Policy, p.1
Read from the broker's site on Open the reference

Where it sits: section 2 of 41 in the AML / KYC Policy, near the start.

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

Firms licensed by the FCA or CySEC must hold retail client money in segregated accounts separate from the firm's own funds, and clients are covered by a statutory compensation scheme. Wingo's documents contain no segregation clause and name no scheme.

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

Where the marketing and the contract disagree

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

01

Wingo advertises withdrawals without limits while its Terms confirm a daily limit exists and never say what it is.

Said in public, in English

Deposit Instantly & Withdraw Without Limits

Section heading on the English account types page and on the English homepage

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

In the contract · clause 6.7

The daily fiat currencies withdrawal limit is predefined and aligned with the limitations of banking system.

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

02

Wingo builds and advertises a Rial deposit channel in Persian, then makes the client alone responsible for whether they are permitted to use the service.

Said in public, in Persian

برای اینکه دغدغه واریز و برداشت نداشته باشید، چندین روش پرداخت برایتان در نظر گرفته‌ایم. از درگاه پرداخت بین‌المللی و ارزهای دیجیتال تا درگاه پرداخت ریالی.

Word for word in English: So that you have no worry about deposit and withdrawal, we have arranged several payment methods for you. From the international payment gateway and digital currencies to the Rial payment gateway.

Payment methods section of the Persian homepage

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

In the contract · clause 1.5

You may only use our Website and services, if you are not legally prohibited from receiving our services under the laws where you are residing, registered.

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

03

Persian readers are told the company is a Comoros entity licensed in Mwali, while its own AML policy says it identifies clients under Saint Lucia law.

Said in public, in Persian

وینگو مارکتس توسط Wingo Group LTD اداره می‌شود؛ شرکتی ثبت‌شده در جزیره خودمختار موالی (موهلی)، اتحادیه کومور، با شماره ثبت HY00523010 و دارای مجوز از سازمان خدمات بین‌المللی موالی (MISA) تحت مجوز کارگزاری و تسویه بین‌المللی شماره T2023302.

Word for word in English: Wingo Markets is operated by Wingo Group LTD, a company registered on the autonomous island of Mwali (Moheli), Comoros Union, with registration number HY00523010 and licensed by the Mwali International Services Authority (MISA) under international brokerage and clearing licence number T2023302.

Risk warning in the footer of the Persian homepage

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

In the contract · clause 1

Wingo Group LTD does not give individual the option of dealing with them anonymously, or under a pseudonym, as Wingo Group is required to identify all trading client under the Saint Lucia Anti-Money Laundering and Terrorist Financing Law, as amended.

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

04

The homepage promises support every day of the week and the Terms close it for two of them.

Said in public, in English

24/7 DEDICATED SUPPORT

Statistic in the hero strip of the English homepage

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

In the contract · clause 12.3.1.2

Saturday and Sunday: Closed

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

05

A Wingo domain tells readers the broker is registered in Canada while its own documents point at Comoros, the European Union and Saint Lucia.

Said in public, in English

Registered in Canada, we offer access to Forex and other financial instruments through reliable platforms.

Opening paragraph on wingomarketsbroker.com, a domain recorded as Wingo's, whose signup buttons link to client.wingomarkets.com

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

In the contract

This Privacy Policy is governed, construed, interpreted, and enforced in accordance with the laws of Comoros, and the European Union.

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

What changed quietly

This is our first reading of Wingo Markets, so there is nothing to compare it against yet.

  • REMOVEDClause Who may we disclose your information to? · 2024-11-12 to current, undated

    Wingo deleted its promise not to give client personal data to third parties for marketing.

  • ADDEDClause Disclosure of Personal Data, item 7 · 2024-11-12 to current, undated

    Marketing and advertising companies were added to the list of third parties Wingo may share client data with.

    Third parties, including those in the fintech, brokerage industry, marketing and advertising sectors, to use personal data in order to let a person know about services which may be of interest to such person in accordance with the Applicable Legislation;
  • REWRITTENClause Right to Erasure · 2024-11-12 to current, undated

    A stated seven year retention period became a fixed term with no number attached.

    As required by the AML and CFT requirements, we must store any collected information within a fixed term from relationship termination.
  • ADDEDClause Information we collect, Biometrics · 2024-11-12 to current, undated

    Wingo added biometric collection, including photo, video and audio, which the 2024 policy did not mention.

    Photo, video, audio of personal data subject, other biometric identifiers and/or biometric information of personal data subject.

The documents this reading is based on

6 files, all published by Wingo 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 Wingo Markets publishes.

How this reading was done

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

This reading was published on .

Documents
3 of 6downloaded from the broker's site, and 3 read in full
Pages opened
80pages walked to find those documents, footer links included
Older copies
2earlier versions downloaded
Marketing pages
6public pages set against what the contract says
Languages
EN vs FAthe language it advertises in, against the language it contracts in
Position measured
18clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

Wingo Group LTD

You contract with Wingo Group LTD, spelled that way in the AML and KYC Policy and as Wingo Group Ltd in the Privacy Policy, the Cookies Policy and the Terms. Its own documents point at three countries. The AML and KYC Policy says Wingo identifies clients under Saint Lucia law. The Privacy Policy says it is governed by the laws of Comoros and the European Union. The Terms name no country at all. Wingo's pages add more: a registered office in Podgorica, Montenegro, a Comoros address in Fomboni, an office in Limassol, Cyprus, and on wingomarketsbroker.com the statement that the broker is registered in Canada. None of the five documents names a regulator. The AML and KYC Policy refers only to the local regulator without saying which one.

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

Wingo charges no dormancy or inactivity fee. No such clause exists anywhere in the five documents, and most offshore brokers have one. The minimum withdrawal is USDT 10, which is genuinely low. Clause 6.3 states plainly that Wingo charges nothing for deposits or withdrawals. Every document is a free download with no login. The current Privacy Policy sets out a legal basis for each processing purpose and a full list of your data rights, which is more than most brokers this size publish. The Credit and Bonus terms sit inside the main Terms file rather than in a separate document a client would never find.

The text layer of the Terms of Service PDF is corrupted in places, so roughly a quarter of its clauses could not be read. Clauses 2.1, 5.1, 5.2, 6.1, 9.5, 9.6.2, 9.6.3, 9.6.5, 9.7.1, 9.7.2, 14.2 and parts of the Credit and Bonus terms are not quoted here, and they may hold more than we report. An August 2025 copy of the Terms exists and we could not read that either, so we cannot say clause by clause what changed. The earlier file ran to 41 pages and today's runs to 19. We read the 2024 Privacy Policy in full, and the version comparison below rests on it. Wingo publishes an IB rebate document we could not read. Wingo publishes no payment terms, no complaints procedure, no conflict of interest policy and no copy trading terms, so its fee schedule and its social trading performance fees of 5% to 30% could not be checked against any contract. The Investments page shows only the words COMING SOON, so we did not quote it.

How to check any of this yourself

Every quote above links to the Wingo 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 Wingo 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 Wingo 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 8, 2026.

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