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Contract reading

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

Every clause below is published by ZXCM 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: ZX Capital Markets Ltd

contradictionsole discretionhidden feekyc freezewithdrawalsdispute deadlinedormancyforum waiverjurisdictionmissing document

ZXCM advertises a Seychelles licence. Its sign-up form registers you with its St Lucia company, and that contract names no regulator at all. One clause lets ZXCM take up to 4.5% of your withdrawal because you did not trade twice a month, while every payment page promises no withdrawal fees. Two of ZXCM's own documents disagree on whether you can lose more than you deposit.

Back to ZXCM

Contract risk

Money at risk
8.3/10

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.
16
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
12
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
10

How the 16 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
Warning8
Notice1

section 21 of 21is where the deepest clause sits: the very end of 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.

Critical2In the contract. Jump to the clause this comes from.The advertised licence belongs to a different companyCritical4.5%Fee you were not shown. Jump to the clause this comes from.Up to 4.5% taken from a withdrawal for trading too littleCritical7Account limit. Jump to the clause this comes from.Three different lists of countries ZXCM will not acceptCritical5 working daysTime to complain. Jump to the clause this comes from.Five business days to object, then the trade is final

What the documents say

16 clauses worth knowing about, worst first, each quoted from ZXCM's own files

01

ZXCM's sign-up form asks you to tick a box agreeing to register with its St Lucia company. Every page on the site leads with a Seychelles licence held by a different company of the same name. The contract you sign names no regulator in its 39 pages.

Why this matters

You are contracting with a company that supervises itself. If ZXCM keeps your money, the Seychelles regulator whose licence number drew you in has no authority over the firm holding it. Your only route is a court in Saint Lucia.

Exhibit 1CriticalRarely seen2

This Agreement shall be governed by and construed in accordance with Saint Lucia law.
Clause 21. Governing Law and Jurisdiction in Client Agreement and Condition, p.35
Read from the broker's site on Open the reference
Our own capture of zxcm.com, taken on Sep 12, 2026The claim, on Homepage footer, repeated on every page of the siteVisit this page on the broker's siteDownload the full size image file
Our own capture of zxcm.com, taken on Sep 12, 2026What the contract says, clause 21. Governing Law and JurisdictionVisit this page on the broker's siteDownload the full size image file
Our own capture of my.zxcm.com, taken on Sep 12, 2026The claim, on Required checkbox on the ZXCM account registration formVisit this page on the broker's siteDownload the full size image file
Our own capture of zxcm.com, taken on Sep 12, 2026What the contract says, clause 2. General, Information about usVisit this page on the broker's siteDownload the full size image file

Buried at section 88 of 98 in the Client Agreement and Condition, 90% of the way through.

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

Firms licensed by the FCA or CySEC must tell a retail client before they trade which legal entity they deal with and which regulator supervises it. ZXCM's Client Agreement names its Saint Lucia company and no regulator at all.

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

Our readingTwo companies sharing one name, one licensed and one not, with the sign-up form assigning clients to the unlicensed one. Brokers with several entities usually tell you which regulator covers yours.

  • Worse together with Exhibit 10The company you contract with also offers no regulator to complain to, so the switch removes both the supervisor and the appeal.
02

If you do not place two trades a month, ZXCM can charge a commission of up to 4.5% when you withdraw. Clause 2.10.1 sets the rate by how many quiet months passed: 2% after one, 3% after three, 4.5% after six.

Why this matters

You are charged for not trading. Deposit $10,000, decide the market is not for you, and wait seven months before asking for it back, and ZXCM can keep $450. Every payment page on the site tells you withdrawals are free.

Exhibit 2CriticalRarely seen4.5%

The Company reserves a right to raise commission on withdrawal up to 4.5% in case there is no sufficient trading activity between last deposits and withdraw request which the customers will be given prior notice of.
Clause 2.10.1 in Client Service Agreement, p.12
Read from the broker's site on Archived copyOpen the reference
Our own capture of zxcm.com, taken on Sep 12, 2026The claim, on Headline benefit badge on the deposit and withdrawal methods page, above a fee table reading None for every methodVisit this page on the broker's siteDownload the full size image file
Our own capture of zxcm.com, taken on Sep 12, 2026What the contract says, clause 2.10.1Visit this page on the broker's siteDownload the full size image file
Our own capture of zxcm.com, taken on Sep 12, 2026The claim, on Raw Spreads panel on the ZXCM homepageVisit this page on the broker's siteDownload the full size image file
Our own capture of zxcm.com, taken on Sep 12, 2026What the contract says, clause 2.10.1Visit this page on the broker's siteDownload the full size image file

Where it sits: section 18 of 80 in the Client Service Agreement, near the start.

What it costsA $10,000 withdrawal after seven months without two trades a month is charged at 4.5%. That is $450 to ZXCM, leaving you $9,550.

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

Firms licensed by the FCA or CySEC must disclose costs and charges to a retail client before they trade. ZXCM puts this one on page 12 of a 53 page PDF and prints the word None on its public fee table.

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

Our readingA withdrawal fee triggered by low trading volume, rather than by the cost of the payment, charges you for not producing spread revenue. The trigger sits in a glossary twelve pages from the fee.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Fewer than two trades in a monthThe month counts against you under ZXCM's own definition of sufficient activity.Table of Definitions and Interpretations
1 month to 3 monthsZXCM can take 2% of whatever you withdraw.2.10.1
3 months to 6 monthsZXCM can take 3% of whatever you withdraw.2.10.1
More than 6 monthsZXCM can take 4.5% of whatever you withdraw.2.10.1
  • Worse together with Exhibit 8A quiet account pays $25 a month while it sits still, then up to 4.5% of what is left when you try to take it out.
03

Anyone who has worked for ZXCM or been a business associate may not hold an account without written approval. If ZXCM decides someone is trading without it, directly or through another person, the account closes and every penny in it is taken.

Why this matters

The clause takes your whole balance, not just your profit, and it never expires after you leave. It also reaches trading done through a third party, so ZXCM can apply it to an account in your partner's name.

Exhibit 3CriticalRarely seen

In such circumstances the employee and/or former employee’s trading account(s) and all open positions shall be closed immediately and any funds held within the account shall be confiscated.
Clause Prohibited Trading in Client Agreement and Condition, p.13
Read from the broker's site on Open the reference
Our own capture of zxcm.com, taken on Sep 12, 2026All funds confiscated from staff and partners, forever (clause Prohibited Trading)This 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

Where it sits: section 33 of 98 in the Client Agreement and Condition, 34% of the way through.

Our readingConfiscation of an entire balance, including the client's own deposit, as a penalty for who the account holder is rather than what they traded. Agreements that restrict staff accounts usually close them and return the money.

  • Worse together with Exhibit 6One clause takes the whole balance from a banned person, the other takes historic profits from anyone ZXCM labels abusive, and ZXCM decides both alone.
04

ZXCM's Risk Disclosure Statement promises your losses will never go past your account balance. Its Client Agreement, published three months later, says there is no negative balance protection and you must pay ZXCM whatever the account goes below zero.

In plain words

Negative balance protection is a limit that stops you owing more than you put in. Without it, one fast market move can leave you owing the broker money on top of your deposit.

Why this matters

If a price gaps against you, the gap between these two documents is a debt you owe ZXCM. The Client Agreement is the one you sign, and it is the one that says you can lose more than you put in.

Exhibit 4CriticalHarder than usual2

The Company does not provide negative balance protection therefore you will be liable to pay the Company for any negative balances that result from your trading activity. Therefore, it is possible to lose more than you deposit.
Clause 5. Negative Balance Liability in Client Agreement and Condition, p.6
Read from the broker's site on Open the reference
Our own capture of zxcm.com, taken on Sep 12, 2026The claim, on Risk Disclosure Statement section 4, published on ZXCM's legal page for the same Saint Lucia entityVisit this page on the broker's siteDownload the full size image file
Our own capture of zxcm.com, taken on Sep 12, 2026What the contract says, clause 5. Negative Balance LiabilityVisit this page on the broker's siteDownload the full size image file

Where it sits: section 15 of 98 in the Client Agreement and Condition, near the start.

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

Firms licensed by the FCA, CySEC or ASIC must give retail clients negative balance protection, so a retail account cannot go below zero. ZXCM's Client Agreement removes it and makes you liable for the shortfall.

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

05

ZXCM's AML Policy bans clients from seven countries. The website footer names five. The sign-up form asks you to confirm only three. Syria, Sudan and Myanmar are banned in the policy, missing from both public lists, and selectable in the registration form.

Why this matters

If you live in Syria, Sudan or Myanmar you can tick ZXCM's declaration honestly, register, and deposit. The ban surfaces later, when compliance reviews your withdrawal against a list you were never shown.

Exhibit 5CriticalHarder than usual7

The Company is required to do an “Enhanced Due Diligence” on clients from the others as they are classed as High Risk by the FATF, thus, we cannot accept clients from The United States, North Korea, Iran, Myanmar, Cuba, Sudan and Syria.
Clause 2. Account Opening Procedures - Know Your Customer Policy (KYC) in AML Policy, p.3
Read from the broker's site on Open the reference
Our own capture of zxcm.com, taken on Sep 12, 2026Three different lists of countries ZXCM will not accept (clause 2. Account Opening Procedures - Know Your Customer Policy (KYC))Visit this page on the broker's siteDownload the full size image file

Where it sits: section 9 of 21 in the AML Policy, 43% of the way through.

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

Firms licensed by the FCA or CySEC must make sure client-facing information is fair, clear and not misleading. ZXCM publishes three different country lists across its contract, its footer and its registration form.

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

  • Worse together with Exhibit 14A client accepted from a banned country can also have their deposits cancelled once ZXCM decides the paperwork does not satisfy it.
06

ZXCM can decide on its own that your trading was abusive and take back profits from any point in your history with it. A second clause lets it void all your trades and close the account without warning once it declares a default.

Why this matters

The reach goes back to your first trade, and ZXCM is the only judge of what counts as abuse. One listed trigger is simply that ZXCM considers action necessary for its own protection, which is not a test you can pass.

Exhibit 6CriticalHarder than usual

obtain from your account any historic trading profits or losses that you have resulted through such abuse of the Company’s platform as determined by us at any time during our trading relationship; and/or
Clause Improper or Abusive Trading in Client Agreement and Condition, p.12
Read from the broker's site on Open the reference
Our own capture of zxcm.com, taken on Sep 12, 2026Past profits reclaimed whenever ZXCM calls trading abusive (clause Improper or Abusive Trading)This 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

Where it sits: section 30 of 98 in the Client Agreement and Condition, 31% of the way through.

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

Firms licensed by the FCA or CySEC must act in the client's best interests and cannot rely on terms giving themselves an unchallengeable discretion over client money. ZXCM keeps the decision and sets no time limit on it.

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

Five business days to challenge a trade, and no regulator at the end

ZXCM gives you five business days to object to a confirmation before its record becomes conclusive and binding, counted from when it posted the record rather than when you read it. Its three live complaint policies set three different deadlines, and the Saint Lucia one that covers your account points to no regulator, only a third-party service if one happens to exist.

Time to object2 clauses flagged

You get five business days to object to a trade confirmation or account statement. After that ZXCM's version is treated as correct, conclusive and binding on you, and the clock runs from when the record was made available, not when you read it.

In plain words

A manifest error means an obvious mistake by the broker.

Why this matters

Take a two week holiday and every trade booked while you were away becomes unchallengeable. The five days start when ZXCM posts the confirmation to your account, so the deadline can pass before you ever log in.

Exhibit 7CriticalHarder than usual5 working days

Confirmation of execution and statements of your Account(s), in the absence of manifest error, shall be deemed correct, conclusive and binding upon you if not objected to immediately by email if orders were placed through ZX Capital Markets Ltd.’s Online Trading System or by telephone to the ZX Capital Markets Ltd Trading Desk, within five Business Days of making such confirmations available to you via our website or we notify you of an error in the confirmation within the same period.
Clause Confirmations in Client Agreement and Condition, p.11
Read from the broker's site on Open the reference
Our own capture of zxcm.com, taken on Sep 12, 2026Five business days to object, then the trade is final (clause Confirmations)This 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

Where it sits: section 29 of 98 in the Client Agreement and Condition, 30% of the way through.

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

Firms licensed by the FCA or CySEC must handle complaints fairly and cannot use a term that treats a client's silence as agreement to a disputed transaction. ZXCM treats five business days of silence as acceptance.

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

ZXCM publishes three live complaint policies with three different deadlines: seven business days, thirty business days, and twenty-one stretching to ninety. The Saint Lucia policy that covers your account offers no regulator, only a third-party service if one happens to exist.

Why this matters

You cannot tell which clock applies to you, and the one attached to your own entity ends nowhere. The named regulator with an address and a complaint form belongs to the Seychelles company you did not sign with.

Exhibit 10WarningHarder than usual90 working days

When disputes between the Company and the Complainant cannot be settled by the official procedure, the Complainant may use a third-party dispute resolution provider, should one be available to them.
Clause 10. Settlement of Disputes in Complaint Handling Policy and Procedures, p.6
Read from the broker's site on Open the reference

Buried at section 28 of 30 in the Complaint Handling Policy and Procedures, 93% of the way through.

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

Firms licensed by the FCA or CySEC must give clients access to an independent complaints scheme and a single clear deadline. ZXCM's Saint Lucia policy points to no scheme at all.

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

ZXCM's own documents disagree about your downside and your money

ZXCM's Risk Disclosure Statement says losses can never pass your account balance. Its Client Agreement, published three months later for the same company, says there is no negative balance protection and you owe ZXCM the shortfall. The homepage promise that client funds are segregated appears only in the AML Policy, which closes by saying it is not part of ZXCM's terms and not contractually binding.

Two versions1 clause flagged

ZXCM's homepage says client funds are segregated from company funds. The only document that promises segregated accounts is the AML Policy, which ends by saying it is not part of ZXCM's terms and is not meant to be contractually binding.

Why this matters

The promise you were sold on is in the one document ZXCM says it is not bound by. Your actual contract only says ZXCM will endeavour to hold your money in Saint Lucia, and defines its client money duties by reference to a law it never names.

Exhibit 13WarningHarder than usual

Our AML Policy is a policy only; it is not part of our Terms and Conditions of Business and is not intended to be contractually binding.
Clause 14. Compliance Footnote in AML Policy, p.7
Read from the broker's site on Open the reference
Our own capture of zxcm.com, taken on Sep 12, 2026The claim, on Segregated Accounts panel on the ZXCM homepageVisit this page on the broker's siteDownload the full size image file
Our own capture of zxcm.com, taken on Sep 12, 2026What the contract says, clause 14. Compliance FootnoteVisit this page on the broker's siteDownload the full size image file

Buried at section 21 of 21 in the AML Policy, 100% of the way through.

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

Firms licensed by the FCA or CySEC must hold retail client money in segregated accounts under binding client money rules and say which rules apply. ZXCM's binding agreement names no statute and no regulator.

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

  • Worse together with Exhibit 1No named regulator and no binding segregation rule means nobody outside ZXCM checks where your money sits.

A withdrawal can cost 4.5% for the crime of not trading

Clause 2.10.1 of ZXCM's Client Service Agreement lets it charge up to 4.5% on a withdrawal when you have not made two trades a month, rising by how long the account stayed quiet. Every ZXCM payment page prints None in the fees column. The schedule that sets ZXCM's interest rates and currency mark-ups is referred to throughout the agreement and published nowhere.

Cost disclosure1 clause flagged

ZXCM's Seychelles agreement sends you to a Commissions, Charges and Margin Schedule for interest rates, currency mark-ups, netting costs and minimum margin. That schedule is on none of ZXCM's legal or pricing pages.

Why this matters

You agree to rates you cannot read. ZXCM can also add a mark-up to any currency conversion it makes on your account, and the size of that mark-up lives only in the document that is missing.

Exhibit 12WarningHarder than usual

The Company shall be entitled to add a mark-up to the exchange rates. The prevailing mark-up is defined in the Commissions, Charges & Margin Schedule.
Clause 9.7 in Client Service Agreement, p.30
Read from the broker's site on Archived copyOpen the reference

Where it sits: section 45 of 80 in the Client Service Agreement, 56% of the way through.

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

Firms licensed by the FCA or CySEC must give retail clients a clear statement of costs and charges before they trade. ZXCM's agreement points to a schedule that is not available to read.

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

Twice your used margin has to stay behind

ZXCM only processes a withdrawal if double your used margin remains in the account afterwards, which locks up far more than the positions require. Any unearned bonus comes off the same request. ZXCM then picks the payment method at its absolute discretion, so the route your money arrived by may not be the route back.

Getting paid out1 clause flagged

ZXCM will only process a withdrawal if what stays in the account afterwards is at least twice your used margin. Any unearned bonus is taken off the same request, and ZXCM picks the payment method at its absolute discretion.

Why this matters

With open positions you cannot take out most of your own money, because double the margin has to stay put. ZXCM also chooses how you get paid, so the route your money came in by may not be the route back.

Exhibit 9WarningHarder than usual

In order to process your withdrawal request please ensure that the funds remaining on your account following your withdrawal is at least twice of your used margin. If you have not met the necessary bonus trading requirements at the time you make a withdrawal request the bonus will be debited from your trading account.
Clause Withdrawals in Client Agreement and Condition, p.14
Read from the broker's site on Open the reference

Where it sits: section 35 of 98 in the Client Agreement and Condition, 36% of the way through.

  • Worse together with Exhibit 14Clearing the margin test still leaves the request with a compliance team that can hold it with no deadline.

Three country lists, and an indemnity for ZXCM's own pricing

ZXCM bans seven countries in its AML Policy, names five in its footer and asks about three at sign-up, so a resident of Syria, Sudan or Myanmar can register honestly and find out later. A second clause lets ZXCM widen spreads and change leverage without notice, then has you promise to cover any losses that follow from it doing so.

In plain words

Indemnities are money it says you owe it.

Who gets in1 clause flagged

ZXCM can widen spreads, change your leverage, alter rollover rates and raise margin without notice. The same clause then has you promise to cover any and all losses that follow from ZXCM doing exactly that.

Why this matters

A decision ZXCM makes becomes a bill you agreed to pay. If a spread widening stops you out, the clause points the cost back at you rather than at the firm that moved the price.

Exhibit 15WarningRarely seen

The Company exclusively reserves the right to widen its variable spreads, adjust leverage, change its rollover rates and/or increase the margin requirements without notice under certain market conditions including, but not limited to, when the trading desk is closed, around fundamental announcements, as a result of changes in credit markets and/or at times of extreme market volatility. In such circumstances, the Client agrees to indemnify the Company for any and all losses that may occur due the widening of spreads and the adjustment of leverage.
Clause Trade Adjustments in Client Agreement and Condition, p.11
Read from the broker's site on Open the reference

Where it sits: section 28 of 98 in the Client Agreement and Condition, 29% of the way through.

Our readingAn indemnity running from the client to the broker for the broker's own pricing decision. Indemnities normally cover a client's breach, not a firm's discretionary act.

Deposits cancelled, withdrawals held, and no deadline on either

ZXCM can cancel your deposits once you pass $10,000 or ten separate payments and it cannot verify the method, or simply because it sees a chargeback risk. A withdrawal flagged for suspicious activity goes on hold pending investigation, with no clause saying when that ends. ZXCM also states it has no duty to tell you when it reports your activity.

Paperwork gates1 clause flagged

ZXCM can cancel your deposits if it suspects your documents, sees a chargeback risk, or cannot verify your card once you pass $10,000 or ten separate deposits. A flagged withdrawal goes on hold pending investigation, and no clause says when that ends.

Why this matters

Your money can sit frozen for as long as ZXCM takes to decide. ZXCM also says it has no duty to tell you when it reports your activity, so you may never learn why the account stopped working.

Exhibit 14WarningHarder than usual$10000

when you deposit $10,000 or more or if you make over 10 separate deposits to your trading Accounts and the Company is unable to verify your credit or debit card details or is unable to verify any other payment method used.
Clause Disabling and Cancelling Deposits in Client Agreement and Condition, p.14
Read from the broker's site on Open the reference

Where it sits: section 34 of 98 in the Client Agreement and Condition, 35% of the way through.

ZXCM advertises no dealing desk and contracts to be the market maker

ZXCM's homepage lists No Dealing Desk as a feature. Clause 12.6 of its Client Service Agreement says ZXCM may act as market maker and hold positions contrary to yours. Clause 12.9 adds that the spread it earns will never be shown on a confirmation or revealed to you, so you cannot work out what a trade actually cost.

Who is on the other side1 clause flagged

ZXCM's homepage advertises No Dealing Desk. Its Client Service Agreement says ZXCM may act as market maker, may hold positions opposite to yours, and that the spread it earns will never be shown to you on any confirmation.

In plain words

Remuneration means payments it receives.

Why this matters

Your loss can be ZXCM's gain on the same trade. Because the spread is never itemised, you cannot work out what you paid or compare it against another broker.

Exhibit 11WarningStandard wording

The Customer accepts that the Company in such markets where the Company acts as Market Maker, may hold positions that are contrary to positions of the Customer, resulting in potential conflicts of interest between the Company and the Customer, cf. Clause 15.
Clause 12.6 in Client Service Agreement, p.32
Read from the broker's site on Archived copyOpen the reference

Buried at section 48 of 80 in the Client Service Agreement, 60% of the way through.

A quiet account costs 25 dollars a month

After 90 days with no trade, no position and no deposit, ZXCM classes the account inactive and charges $25 a month against the balance. The charge is on no pricing page. Set beside the $100 minimum deposit ZXCM advertises, it empties a minimum-sized account in four months, after which the account turns dormant and needs fresh identity documents to restart.

Standing still1 clause flagged

Go 90 days without a trade, a position or a deposit and ZXCM classes your account inactive and charges $25 every month. The charge appears nowhere on ZXCM's account comparison or pricing pages.

In plain words

Dormancy means an account left unused.

Why this matters

A forgotten account with $200 in it is empty inside eight months. Once the balance hits zero the account turns dormant, and you have to contact ZXCM and produce fresh identity documents to use it again.

Exhibit 8WarningHarder than usual$25

The Client further acknowledges and confirms that such Inactive Accounts will be subject to a monthly charge of $25, relating to the maintenance/administration of such Inactive Accounts.
Clause Inactive and Dormant Account in Client Agreement and Condition, p.15
Read from the broker's site on Open the reference

Where it sits: section 38 of 98 in the Client Agreement and Condition, 39% of the way through.

What it costsAn account holding $200 that goes quiet is charged $25 a month. After eight months the balance is zero and the account turns dormant.

Our readingDormancy fees are common, but $25 a month is high against the $100 minimum deposit ZXCM advertises. It empties a minimum-sized account in four months.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Day 90ZXCM classes the account as an Inactive Account.Inactive and Dormant Account
Every month afterA $25 charge is taken from the balance.Inactive and Dormant Account
Balance reaches zeroThe account turns Dormant and stops working until you contact ZXCM and re-supply identity documents.Inactive and Dormant Account
90 days after reactivationThe account becomes Dormant again if it stays quiet.Inactive and Dormant Account

Two document sets share one legal page and contradict each other

ZXCM's legal page carries a Seychelles set from April 2025 and a Saint Lucia set from late 2025 onward. The Saint Lucia client gets four documents and no best execution policy, no conflicts of interest policy and no privacy statement of its own. The Complaint Handling Policy prints the Seychelles company registration number where the licence number belongs, and one published privacy policy still carries an unfinished drafting note.

Paper trail1 clause flagged

ZXCM's legal page serves two parallel sets of documents, one for each company. The Saint Lucia set has four documents and no best execution policy, no conflicts of interest policy and no privacy statement of its own.

Why this matters

You cannot tell which policies bind your account. The Complaint Handling Policy even prints ZXCM's Seychelles company registration number where the licence number should be, and one published privacy policy still carries an unfinished drafting note.

Exhibit 16NoticeHarder than usual

ZX Capital Markets Ltd (the “Company”) is a Securities Dealer Licensee, regulated and authorized by the Seychelles Financial Services Authority under the license number 8437654 -1 with its registered address at IMAD Complex, 3rd Floor, Office 12, Il du Port, Mahe, Seychelles.
Clause 1.1 in Complaint Handling Policy, p.4
Read from the broker's site on Open the reference

Where it sits: section 4 of 106 in the Complaint Handling Policy, near the start.

Where the marketing and the contract disagree

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

01

The licence on every page belongs to the Seychelles company, while the agreement you sign is with the Saint Lucia company under Saint Lucia law.

Said in public, in English

ZX Capital Markets Ltd (Seychelles) is regulated by the Financial Services Authority in Seychelles and is holder of Dealer in Securities license SD214.

Homepage footer, repeated on every page of the site

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

In the contract · clause 21. Governing Law and Jurisdiction

This Agreement shall be governed by and construed in accordance with Saint Lucia law.

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

02

The registration form assigns every new client to the company that holds no licence, one line below a page advertising a Seychelles licence.

Said in public, in English

I agree to register with the St Lucia entity

Required checkbox on the ZXCM account registration form

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

In the contract · clause 2. General, Information about us

ZX Capital Markets Ltd with the trade name (‘ZXCM’) is a company registered in Saint Lucia, (hereinafter ‘the company’). The Company is registered under company number 2023-00378 with its registered offices at Ground Floor, The Sotheby Building, Rodney Village, Robney Bay, Gros-Islet, Saint Lucia.

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

03

The payment page promises no withdrawal fees while the agreement allows a commission of up to 4.5% on the same withdrawal.

Said in public, in English

No deposit and withdrawal fees

Headline benefit badge on the deposit and withdrawal methods page, above a fee table reading None for every method

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In the contract · clause 2.10.1

The Company reserves a right to raise commission on withdrawal up to 4.5% in case there is no sufficient trading activity between last deposits and withdraw request which the customers will be given prior notice of.

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

04

Arabic-speaking clients are promised fee-free withdrawals on a page in their own language, while the 4.5% commission exists only in an English PDF.

Said in public, in Arabic

بدون رسوم إيداع وسحب

Word for word in English: Without deposit and withdrawal fees

Benefit badge on the Arabic deposit and withdrawal methods page

In the contract · clause 2.10.1

The Company reserves a right to raise commission on withdrawal up to 4.5% in case there is no sufficient trading activity between last deposits and withdraw request which the customers will be given prior notice of.

05

The homepage promises no commissions and no hidden fees above a contract holding a tiered withdrawal commission and a $25 monthly inactivity charge.

Said in public, in English

Our super low spreads start from 0.2 pips with no commissions and no hidden fees.

Raw Spreads panel on the ZXCM homepage

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In the contract · clause 2.10.1

Activity Percentage 1 month to 3 months 2% 3 months to 6 months 3% More than 6 months 4.5%

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06

One ZXCM document promises losses can never pass your balance and another says you owe ZXCM whatever the account goes below zero.

Said in public, in English

Your losses will never exceed the balance of your account, which is balanced to zero, if the losses are higher than the amount deposited.

Risk Disclosure Statement section 4, published on ZXCM's legal page for the same Saint Lucia entity

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In the contract · clause 5. Negative Balance Liability

The Company does not provide negative balance protection therefore you will be liable to pay the Company for any negative balances that result from your trading activity. Therefore, it is possible to lose more than you deposit.

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

07

The sign-up gate asks about three countries while the AML policy bans seven, so residents of Syria, Sudan and Myanmar can register truthfully.

Said in public, in English

I am not a US, Iran or North Korea resident

The only country declaration on the ZXCM registration form, whose country menu offers Syria, Sudan and Myanmar

In the contract · clause 2. Account Opening Procedures - Know Your Customer Policy (KYC)

The Company is required to do an “Enhanced Due Diligence” on clients from the others as they are classed as High Risk by the FATF, thus, we cannot accept clients from The United States, North Korea, Iran, Myanmar, Cuba, Sudan and Syria.

08

The public list names Iraq, which the AML policy does not ban, and leaves out Myanmar, Sudan and Syria, which it does.

Said in public, in English

Restricted Countries: ZX Capital Markets Ltd does not offer its services to residents of certain jurisdictions such as USA, Cuba, Iraq, Iran and North Korea.

Risk warning block in the homepage footer, shown identically on the Arabic pages in English only

In the contract · clause 2. Account Opening Procedures - Know Your Customer Policy (KYC)

The Company is required to do an “Enhanced Due Diligence” on clients from the others as they are classed as High Risk by the FATF, thus, we cannot accept clients from The United States, North Korea, Iran, Myanmar, Cuba, Sudan and Syria.

09

The homepage advertises no dealing desk while the agreement lets ZXCM act as market maker and hold positions against its own clients.

Said in public, in English

No Dealing Desk

Trading conditions panel on the ZXCM homepage

In the contract · clause 12.6

The Customer accepts that the Company in such markets where the Company acts as Market Maker, may hold positions that are contrary to positions of the Customer, resulting in potential conflicts of interest between the Company and the Customer, cf. Clause 15.

10

The segregation promise the homepage makes appears only in the document ZXCM says is not part of its terms and not binding.

Said in public, in English

Following industry best practices and to ensure conformity with global regulation, client funds are segregated from company own funds and are always held in different accounts or wallets.

Segregated Accounts panel on the ZXCM homepage

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In the contract · clause 14. Compliance Footnote

Our AML Policy is a policy only; it is not part of our Terms and Conditions of Business and is not intended to be contractually binding.

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

The documents this reading is based on

12 files, all published by ZXCM. 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 ZXCM publishes.

How this reading was done

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

This reading was published on .

Documents
12 of 12downloaded from the broker's site of the 16 we found, and 12 read in full
Pages opened
32pages walked to find those documents, footer links included
Older copies
3earlier versions downloaded, 3 identical to the copy we hold by fingerprint
Marketing pages
11public pages set against what the contract says
Languages
AR vs ENthe language it advertises in, against the language it contracts in
Position measured
16clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

ZX Capital Markets Ltd

Two companies share the name ZX Capital Markets Ltd. One is registered in Seychelles under number 8437654-1 and holds Dealer in Securities licence SD214. The other is registered in Saint Lucia under number 2023-00378 and holds no licence named anywhere in its own documents. ZXCM's sign-up form asks you to tick a box reading 'we agree to register with the St Lucia entity', so the unlicensed company is the one a retail client contracts with. Its Client Agreement is governed by Saint Lucia law and sends every dispute to Saint Lucia courts. Both document sets sit on the same legal page, which is how a client ends up reading a licence number that does not belong to their counterparty.

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

ZXCM publishes a real fee and timing table for each payment method, with named processing windows rather than vague promises. Its About page admits plainly that deposits are automatic while withdrawals are checked by hand. The St Lucia agreement states outright that there is no negative balance protection, where many offshore firms stay silent. The Complaint Handling Policy version 2.1 is genuinely well built: it carries a version number, promises acknowledgement in two business days with a reference number, sets out a vulnerable consumer process, and prints the regulator's address, email and form link. The Seychelles agreement is also unusually frank that ZXCM profits from spreads it will never show you.

We read all twelve of ZXCM's current legal documents in full. No earlier version of most of them is available, so this is a first reading with little to measure against. Three earlier copies matched today's files exactly by fingerprint, and we did not read their text separately. We did not go past the public sign-up form into the client portal, so we could not see any fee schedule or bonus terms shown only after registration. The Commissions, Charges and Margin Schedule that the Seychelles agreement relies on for interest rates, currency mark-ups and minimum margin is not published, so we could not read the rates it sets.

How to check any of this yourself

Every quote above links to the ZXCM 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 ZXCM 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 ZXCM 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 12, 2026.

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

Back to the ZXCM profile