Terms & Policies

All the legal statements, policies and guidelines from SGT in one place:

Anti-Money Laundering (AML) Policy

Sterling Gent Trading Ltd (SGT) is committed to the fight against money laundering. As part of our regulatory obligation and our efforts to combat money laundering, we have appointed an officer that is responsible for Anti-Money Laundering and is accountable to senior management. SGT requires all relevant personnel to complete training in Anti-Money Laundering and our internal Compliance Procedures.

The Money Laundering Reporting Officer ("MLRO")

The MLRO’s functions is to receive all reports of suspicious activities from staff.
The MLRO is responsible for overseeing the implementation of the policies and procedures set out in this AML Policy, determining whether and to what extent to report suspicious activities to the BVI Financial Investigation Agency (the “FIA”), responding to requests made by the FIA for information, and resolving any issues or differences of opinion arising out of this AML Policy.

The Financial Investigation Agency

In the BVI, reports on money laundering and terrorist financing activities are made to the Financial Investigation Agency (“FIA”) set up under the Financial Investigation Agency Act, 2003.

Four Key Policies

SGT has in place four primary policies that are designed to assist in the recognition, prevention, and reporting of money-laundering activities. We summarise these as follows:

Policy 1: Know Your Client (“KYC”)
Policy 2: Beneficial Owner Verification (“BOV”)
Policy 3: Suspicious Activities Reporting
Policy 4: Systems, Controls, and Training

The BVI Legislation

Anti-money laundering legislation in the BVI, and indeed worldwide, recognises the use of professional services for money laundering. The AML (Anti-Money Laundering) and CFT (Combating the Finance of Terrorism) laws in various jurisdictions have therefore been extended to apply beyond the traditional, regulated institutions to include independent legal professionals and trust and company service providers.

The anti-money laundering legislation of the BVI is contained principally in:

the Proceeds of Criminal Conduct Act, 1997 (as amended) (the “PCCA”);
the Anti-Money Laundering Regulations, 2008 (the “Regulations”); and
the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 (as amended) (the “Code”).

The Regulations and Code create mandatory requirements:

to know the name of and verify the identity of one’s customers or investors, and to keep proper records of such verification;
to keep proper records of transactions with investors or customers for a minimum period of at least 5 years; and
to have internal controls and reporting procedures, including training of employees to prevent money laundering and the appointment of a MLRO.

In brief the SGT Anti-Money Laundering Statement's key principles are:

Protect SGT from money laundering & terrorist financing.
Maintain a written set of AML policy and procedures, a system of internal controls to ensure ongoing AML compliance by a designated person(s) and to take appropriate action, once suspicious activity is detected, through the reporting of such transactions in line with the guidelines set out by the Financial Services Commission, British Virgin Islands.
Comply with applicable anti-money laundering & terrorist financing laws and regulations as established by the Financial Services Commission, British Virgin Islands.
Report all identified suspicious activities to the extent that SGT can do so under all applicable foreign and domestic laws.
Retaining the entire customer-related documents for a period specified as per the Financial Services Commission, British Virgin Islands.
Co-operate fully with law enforcement and regulatory agencies to the extent that it can do so under all applicable laws.

For further AML inquiries please contact us at compliance@sgt.markets

Cookie Policy

A cookie is a small text file placed on your device that stores information about a user’s use of a website. Tracking technologies, such as cookies and local shared objects (sometimes called “Flash cookies”) may be used by this website. We use cookies for allowing the website to work and enhancing usability, as well as for providing information to us. The different types of cookies we use are outlined below:

"Session based": This is a temporary cookie and, once you close out of the website, any information is no longer needed and is deleted. It is essential for parts of the website to operate and is used to allow the website to carry background information as you navigate between pages, allowing the website to provide you an efficient service.

"Persistent": This remains in the cookie file of your browser even after you log out of the website or close the browser. It enables a website to remember you the next time you visit the website and can remember your site settings preferences. You will be asked for your explicit consent before agreeing to the use of this function.

Given the nature of some cookies however, you may not be able to use all features of the website, or access secure areas, if these are disabled. For more information on cookies and why they are used, please visit: www.allaboutcookies.org

How Do We Use Cookies?

In common with many other website operators, we use cookies on our website. We use them to enrich your experience of using the website by allowing us to tailor what you see to what we have learned about your preferences during your visits to the site. Our cookies are also used to enable us to develop our website to reflect our fans and customers interests by noting who has seen which pages and advertisements, how frequently particular pages are visited and determining the most popular areas of our website. We and carefully selected third parties also use cookies to show you more relevant advertising online.

In general, we use the following types of cookie:

Strictly Necessary Cookies:
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use the shopping cart feature when buying match tickets etc.

Analytical/Performance Cookies:
These allow us to recognise and count the number of visitors and see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users can find what they are looking for easily.

Functionality Cookies:
These are used to improve the functional performance of the website and make it easier for you to use. For example, they are used to remember that you have previously visited the website and asked to remain logged into the website.

Targeting Cookies:
These cookies record your visit to our website and your browsing habits, such as the pages you have visited and the links you have followed. They are used to deliver advertising which is more relevant to your interests and also may be used to limit the number of times that you see an advertisement. They may be placed by us or by advertising networks with our permission. Please note, these cookies do not contain any of your personal information. For details on how to manage cookies and how to opt out of targeted marking see below.

By continuing to use our website without choosing to delete/block cookies, you agree that we can place these types of cookies on your device.

Managing Cookies

You have the ability to change your internet browser settings to accept or reject cookies. To find out how to do this please either refer to the “Help” menu of your specific browser or visit www.allaboutcookies.org - Manage Cookies.

If you do not wish to accept cookies from this website, please either disable them or leave this website. If cookies are disabled, however, it may mean that either you experience reduced functionality or may be prevented from using some, or all, of this site.

Changes to this Cookie Policy

We aim to meet high standards and our policies and procedures are, therefore, constantly under review. From time to time we may change how we use and place cookies. Accordingly, we recommend that you check this page periodically in order to review our current policies and practices.

Execution Policy

Slippage

Because the spot forex market is decentralized, meaning it lacks a single central exchange where all transactions are conducted, each forex broker, may quote slightly different prices. The small differences in prices are also due to the different spreads and commissions each broker charges.

Rejected Orders

Extreme market volatility creates conditions that make it difficult to execute orders at the given price due to an extremely high volume of orders. By the time orders are able to be executed, the bid/ask price at which a counterparty is willing to take a position may have moved.

In cases where the liquidity pool is not large enough to fill a Market or Pending Order, the order will be rejected until the order can be filled.

Trade Execution Delay

A delay in execution can happen for several reasons, such as technical issues with the trader's internet connection to the SGT servers, which may result in hanging orders; the SGT trading platform on a trader's computer may not be maintaining a constant connection with SGT's servers due to a lack of signal strength from a wireless or dialup connection.

A disturbance in the connection path can sometimes interrupt the signal, and disable SGT's trading platforms, which can cause delays in the transmission of data between the trader's SGT trading platform and SGT’s servers.

Greyed-Out Pricing

SGT does not intentionally "gray out" prices; however, this is a condition that occurs when liquidity decreases, and liquidity providers that provide pricing to SGT are not actively making a market for a particular currency pair or instrument. Such a situation can increase spreads which may result in margin calls on a trader's account.

Widened Spreads

SGT prides itself on tight, competitive spreads; however, there may be instances when spreads widen beyond what is typical. During news events spreads may widen substantially in order to compensate for the tremendous amount of volatility in the market. The widened spreads may only last a few seconds or as long as a few minutes.

SGT strongly encourages traders to use caution when trading around news events and economic announcements and to always be aware of their account equity, usable margin and market exposure. Widened spreads can adversely affect all positions in an account.

Weekend Risk

Traders, who fear the potential for weekend risk, may simply close out orders and positions ahead of the weekend. News events can cause significant movement at the open and there is a potential for price gaps to occur. Please note that SGT offers 24/7 crypto CFD pricing allowing the trader to participate in market movements over the weekend.

Liquidity

Please be aware that during the first few hours after the opens especially on a Sunday evening EST time, the market tends to be thinner than usual until the Tokyo and London market sessions begin. These thinner markets may result in wider spreads, as there are fewer market participants.

Margin Calls

Margin trading allows traders to hold a position much larger than their actual account value. SGT offers multiple levels of leverage and as has been stated, trading on margin comes with risk, since high leverage levels may work against you as much as it may work for you. If account equity falls below margin requirements, SGT's trading platforms will trigger an order to close all open positions. When positions have been over-leveraged or trading losses are incurred to the point that insufficient equity exists to maintain current open positions, a margin call will result, and open positions must be closed.

Please bear in mind that when the account's useable margin reaches zero, all open positions are triggered to close. The margin-call process is entirely electronic, and there is no discretion on SGT's part as to the order in which trades are closed.

Although the margin call feature is designed to close positions when account equity falls below the margin requirements, there may be instances when liquidity does not exist at the exact margin call rate. As a result, account equity can fall below margin requirements at the time orders are filled, even to the point where equity account becomes negative. This is especially true during market gaps or volatile periods. SGT will not hold traders responsible for NEGATIVE balances in this scenario, but clients should be aware that all funds on deposit in an account are subject to loss. SGT also recommends that traders use stop orders to limit downside risk instead of using a margin call as a final stop.

SGT strongly recommends that traders always maintain the appropriate amount of margin in their accounts. You may request a change to your margin requirements/leverage levels, which is subject to approval by SGT. Margin requirements may be changed at the discretion of SGT.

Chart Pricing vs. Prices Displayed on the Platform

It is important to make a distinction between indicative prices (displayed on charts) and executable prices (displayed on SGT’s trading platforms in the Market Watch Window). Only executable prices can be traded.

Differences in Pricing Between Brokers

Expert Advisor Trading (EA)

SGT allows trading via Expert Advisors but does not offer support regarding their installation, implementation, and proper functioning. Therefore, any responsibility for proper functioning of an EA lies with the user of the EA. SGT does not accept liability for the misuse of any EA within SGT’s trading systems.

Bonus Offerings

SGT may, from time to time, offer a bonus scheme. Clients should carefully read and understand the terms and conditions for each bonus offered by SGT as these are published.

FX Global Code

KYC Guidelines

Sterling Gent Trading Ltd (SGT) has the responsibility to its regulators for compliance regarding global anti-money laundering (AML) regulations and Know Your Client requirements (KYC). For this reason, traders are required to submit accurate and up-to-date proof of identity and source of funds.

The following documents must be submitted to SGT once an account application has been successfully submitted:

Individual & Joint Accounts

Proof of Identification:
SGT accepts valid passports only (showing photograph, personal details, signature, date and place of birth, date and place of issue and serial number);
Proof of Residence:
A separate document such as a recent utility bill (gas, water, electricity, or fixed-line phone bill), or a bank statement which clearly states the applicant’s address. Both utility bills and bank statements must be dated within the last 3 months.

Business Accounts

For all business accounts (see full list below), the following documents must be submitted to SGT:

A certified* copy of Certificate of Incorporation.
A certified copy of the Memorandum and Articles of Association or Bye Laws
A Certificate of Incumbency listing the directors and officers of the Company
A certified list of all shareholders who own in excess of 10% of the shares of the Company
Verification of the names and addresses of the directors, officers, shareholders and authorised signatories by provision of;
1. a certified Proof of Identification from the account’s signatories: Valid passports are the preferred form of ID, and;
2. a certified copy or original of a separate document such as a recent utility bill (gas, water, electricity, or fixed-line phone bill) or bank statement that verifies the individual signatory’s home address. Both utility bills and bank statements must be dated within the last 3 months.

*The certified documents must be certified by a professional person such as a lawyer, notary or accountant or official entity such as an embassy or government ministry.

**SGT does NOT accept clients from these countries.

SGT will not disclose and or share any of your information with third parties without your consent except in the event that we are required to do so by a regulatory authority under the applicable jurisdiction, by court and/or to enable us to provide you with our services. The latter includes but is not limited to members of the SGT group of companies, IT service providers, payment services providers, banks and liquidity providers. Where we disclose and/or share any of your information we will take all reasonable steps to do so in a secure manner.

Protecting your personal information is important to us. We have, therefore, created this statement in accordance with the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679 the “GDPR”). GDPR strengthens and unifies data protection across the European Union. It also applies to all organisations that hold or process the personal information of EU-based individuals.

The legislation is intended to ensure that all personal information held by organisations (including, for example, an email address) which might allow you, as an individual, to be identified, is accurate and secure and there is no miss-use of personal information by that organisation.

This document sets out how the Sterling Gent Trading Ltd. (“SGT”) collects, uses and safeguards the personal information that you, as an individual, provide to us.

This statement covers all communication with SGT, including users of SGT websites. In this privacy statement:

“you” or “your” refers to you as an individual and not to any legal entity (such as your employer) which you may be representing by viewing our websites or communicating with us “our”, “ours”, “we” or “us” refers to SGT.

Please note, if you provide personal information relating to other individuals (for example contact details in a work context), you must either advise those individuals of the details of this statement or provide them with a link to this statement.

By providing your information to SGT you consent to the collection and use of your personal information in the manner set out below.

The privacy statement covers only SGT, it does not cover the privacy policies of other entities which may be accessible through, or linked to, any SGT website or communication.

We will not notify you separately of any changes or updates to this privacy statement, but instead will post them to this page. Any change or update will be effective immediately upon posting

Should you have any questions on this statement, please email them to: compliance@sgt.markets

Information Collected by SGT

When you visit an SGT website or contact with SGT, and when providing any services to you, SGT may collect personally identifiable information about you from information provided by you.

This can include the following information relating to you: name, address (residential or corporate), geographical location, email address, contact details, corporate contact information, correspondence records.

We may also obtain personal information on you from other public sources.

Purposes of Processing and Legal Basis for Processing

Generally, SGT will use the personal information provided by you to:

Create an account allowing access to detailed information about the funds we manage,
Facilitate the administration of a website account,
Email updates relating to the products and services that SGT and related parties offer,
Respond to queries or provide services to you, and
Maintain or update contact data about you or a third party (for example your employer) within SGT’s systems.
Enable us to act on any agreement with you, your employer or any other relevant third party.
Provide to any third parties that may host, maintain or manage services for SGT, solely to the extent necessary to fulfil their hosting, maintenance or service management functions.

We will never share your personal information with others for marketing purposes, unless you have given us your explicit permission to do so.

Where you have done so, we will only share your information with:

Those service providers that help us manage our marketing activities; or with related parties for the purposes of providing you with related products and services. Accordingly, you understand that we may use your personal information for the purposes as described above, provided that we are acting in a fair, transparent and accountable manner and that we have taken appropriate steps to prevent the activity having any unwarranted impact on you and also noting your right to object to such use, as discussed below.

Should we wish to use your personal information for other purposes (including, if applicable, any purpose that requires your additional consent), we will contact you.

The categories of non-public personal information which SGT shall collect include:

information provided by the customer when opening an account, or to process a transaction, such as name, address, assets, bank information, prior trading experience, etc.;
information used to verify the identity of the customer, including copies of government issued identification materials such as passports, driver’s licenses, and credit reports.
information resulting from transactions between the customer and SGT or an affiliate of SGT, such as withdrawal and deposit forms.
information derived from customer’s navigation and usage of SGT.’s website and online platforms, including account trading statements.

Usage of Personal Information

SGT may use the information collected from you to verify your identity and contact information. SGT may also use this information to establish and setup your trading or demo account, issue an account number and a secure password, maintain your account activity, and contact you with account information.

Should you close your account, SGT will retain your information, but only use it to comply with regulatory requirements and to periodically contact you to offer you the opportunity to reactivate your account or participate in other valuable offers.

Recipients of Data and Transfer of Data

SGT may disclose personal information to:

Entities within the SGT group, service providers of the business it manages, its service providers and their respective affiliates engaged by SGT to process data for the above-mentioned purposes.

To regulatory authorities, courts and bodies as required by law or to service providers for internal investigations and reporting.

The disclosure of personal information to the third parties set out above may involve the transfer of data other jurisdictions outside the European Economic Area (“EEA”) which may include the United States. Any transmission of personal information by SGT or its service providers outside the EEA shall be in accordance with the conditions of the GDPR. These countries may not have the same data protection laws that apply in the EEA, but SGT will authorise its group entities or other service providers to transfer personal information to other countries only where standard contractual clauses or other safeguards permitted under the GDPR have been put in place with parties to whom personal information will be transferred.

SGT and its service providers apply appropriate information security measures designed to protect personal information in its or its service providers’ possession from unauthorised access by third parties or from any form of computer corruption.

Information Disclosed by SGT and To Whom SGT Discloses the Information

SGT may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer.

Except for the limited circumstances described below or as otherwise permitted by law, SGT does not share non-public personal information about our current or former customers with any third parties.

* SGT may share non-public personal information with introducing brokers for translation services. When introducing brokers provide translation services, we endeavour to protect such personal information by requiring those introducing brokers to enter into an agreement with SGT to safeguard the confidentiality of personal information.

* When a client is referred by an introducing broker, SGT generally shares non-public personal information concerning the account opening and maintenance process with the introducing broker who made the referral.

* SGT may engage another business or person to help us identify client and demo user needs and notify clients and demo users of product and service offerings. Use of the information shared is limited to the performance of the task we request and is not used for any other purpose. These third parties are required to enter into an agreement with SGT to safeguard the confidentiality of personal information before they provide such services. Examples of information shared are identifying information such as name, mailing address, e-mail address and telephone number and information on account activity.

* SGT may provide information to non-affiliated third parties, as permitted by law, in providing financial services to you.

* SGT may provide information, as permitted by law, to government or regulatory agencies and to comply with a legal summons, court order, subpoena or a similar legal process, audit or investigation; and

* SGT may also disclose your non-public personal information if you authorise such disclosure.

If you do not wish to have SGT share non-public personal information with non-affiliated third parties pursuant to any of the provisions listed above, please opt out of those provisions by sending an e-mail to compliance@sgt.markets or calling SGT at +44 800 298 7925. Opting out will apply for all financial products or services you obtain through SGT. Please note that you cannot opt out of any provisions if sharing of the information is required by law. Further, please note that an opt-out election must be made for each separate account you hold at SGT or with any SGT affiliates.

Third Party Sites

Our communications may contain links to third party websites. As we do not control the information on these websites, you should review their privacy policies and cookies to learn about how that website may collect and use your personal information. When accessing any third-party sites that may be linked you will leave this website. These third-party sites are not controlled or endorsed by SGT. SGT is not responsible for the contents, operation or security of such sites.

Retention Period

SGT will retain personal information only for as long as required for the purposes set out above. Once the personal information is no longer required, we will take appropriate steps to dispose of any records containing your personal information, to the extent this is operationally feasible and proportionate.

Data Subject Rights

Where SGT holds personal information, the owner of that information has the following rights, in certain circumstances, in relation to their personal information:

Right to access any personal data held
Right to have any inaccurate personal data rectified
Right to restrict the use of personal data
Right to request that personal data is erased
Right to object to the processing of personal data
Right to obtain a copy of any personal data held in electronic form (data portability)

SGT will notify you of any personal data breach affecting you that is likely to result in a high risk to your rights and freedoms.

You also have the right to lodge a complaint with the Office of the Data Protection Commissioner, or your local supervisory authority, if you consider that the processing of your personal information by us infringes the Data Protection Legislation.

If your personal information has changed or requires correcting, please let us know by emailing compliance@sgt.markets so that we can update our records.

Opting Out of Receiving Communications

SGT and its service providers from time to time send communications, such as market holiday schedules, changes in margin requirements, new instruments or products, general SGT updates and event information. All such communications from us include an “unsubscribe” link which can be clicked should you no longer wish to receive these types of communication from us.

Alternatively, you can send an email to compliance@sgt.markets requesting to be removed from some of or all our mailing lists.

Personal Data Requests

Any questions about our use of your personal information should be directed to SGT at compliance@sgt.markets

Confidentiality and Security Procedures

Only those staff members for whom the information is necessary to complete a given transaction shall possess the authority to access the information. SGT, its personnel, and its affiliates shall strictly adhere to security practices and procedures to ensure the confidentiality of its customers’ information.

SGT maintains numerous safeguards that comply with Federal regulations to guard your non-public personal information including the use of encryption technology, firewalls and authentication systems (usernames and passwords).

SGT will continue to protect the privacy of former customers’ non-public personal information in the same manner as when they were customers. Unlike current customers, however, former customers will not receive annual privacy notices.

Security Technology

SGT uses Secure Socket Layer (SSL) encryption technology in order to protect certain information that is submitted. This technology protects you from having your information intercepted by anyone other than SGT while it is being transmitted to us. We work diligently to ensure that our Web sites are secure and that they meet industry standards. We also use other safeguards such as firewalls, authentication systems (e.g., passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data.

Risk Disclosure

This brief statement is not a full and exhaustive list of all the risks and other significant aspects of trading in leveraged investments. Considering these risks, you should undertake such transactions only if you understand the nature of the transactions (and contractual relationships) into which you are entering and the extent of your exposure to risk. You should carefully consider whether trading is appropriate for you based on your experience, objectives, financial resources, and other circumstances.

Full Risk Disclosure and Disclaimer.

1. Effect of 'Leverage' or 'Gearing'

Transactions in OTC accounts carry a high degree of risk. The amount of initial margin for contracts for differences, commodities, foreign exchange, futures or indices is small relative to the value of the OTC contract so that transactions are highly ‘leveraged’ or highly ‘geared’. A relatively small market movement will have a proportionately larger impact on the funds you have deposited or will have to deposit; this may work against you as well as for you. You may sustain a total loss of initial margin funds and any additional funds deposited with the firm to maintain your position. If the market moves against your position or margin levels are increased, you may be called upon to pay substantial additional funds on short notice to maintain your position. If you fail to comply with a request for additional funds within the time prescribed, or to maintain sufficient usable margin in your account, your position may be liquidated at a loss without notice and at the sole discretion of Sterling Gent Trading Ltd (SGT).

2. Risk-reducing Orders or Strategies

The placing of certain orders (e.g., ‘stop-loss’ order, where permitted under local law, or ‘stop- limit’ orders) which are intended to limit losses to certain amounts may not be effective because market conditions may make it impossible to execute such orders. Strategies using combinations of positions, such as ‘spread’ and ‘straddle’ positions may be as risky as taking simple ‘long’ or ‘short’ positions.

3. Terms & Conditions of Contracts

You should understand the terms and conditions of the specific contracts for differences, commodities, foreign exchange, cryptos, futures or indices which you are trading and any associated obligations.

4. Suspension or Restriction of Trading & Pricing Relationships

Market conditions, including, but not limited to, illiquidity, and/or the operation of the rules of certain markets (e.g., suspension of trading in any security due to price limits, government intervention or “circuit breakers”) may increase the risk of loss by making it difficult or impossible to effect transactions or liquidate/offset positions.

5. Deposited Cash & Property

You should familiarise yourself with the protections accorded money or other property you deposit for domestic and foreign transactions, particularly in the event of a firm’s insolvency or bankruptcy. The extent to which you may recover your money or property may be governed by specific legislation or local rules. In some jurisdictions, property which had been specifically identifiable as your own will be pro-rated in the same manner as cash for purposes of distribution in the event of a shortfall.

6. Commission and Charges

Before you begin to trade, you should obtain a clear explanation of all commission, fees, markups, markdowns, rollovers, interest rate differential and other charges for which you will be liable. These charges will affect your net profit (if any) or increase your loss.

7. Transactions in Other Jurisdictions

Transactions in currencies in other jurisdictions, including markets formally linked to a domestic market, may expose you to additional risk. Such markets may be subject to regulation which may offer different or diminished investor protection. Before you trade you should inquire about any rules relevant to your particular transactions. Your local regulatory authority will be unable to compel the enforcement of the rules of regulatory authorities or markets in other jurisdictions where your transactions have been effected. You should understand about the types of redress available in both your home jurisdiction and other relevant jurisdictions before you start to trade.

8. Currency Risks

The profit and loss in transactions in foreign currency-denominated contracts or securities (whether they are traded in your own or another jurisdiction) will be affected by fluctuations in currency rates where there is a need to convert from the currency denomination of the contract to another currency.

9. Trading Facilities

OTC business is not traded on a regulated market and therefore does not require open outcry. Even though quotations or prices are afforded by many computer-based component systems, the quotations and prices may vary due to market liquidity. Many electronic trading facilities are supported by computer-based component systems for the order-routing, execution or matching of trades. As with all facilities and systems, they are vulnerable to disruption or failure. Your ability to recover certain losses may be subject to limits on liability imposed by the system provider, the market, the bank and/or financial institution and such limits may vary.

10. Electronic Trading

Trading on an electronic trading system may differ not only from trading in the interbank or other regulated markets but also from trading on other electronic trading systems. If you undertake transactions on an electronic trading system, you will be exposed to risks associated with the system including the failure of hardware and software. The result of any system failure may be that your order is either not executed according to your instructions or is not executed at all.

Disclaimers:

Internet Failures: Since SGT does not control signal power, its reception or routing via the Internet, configuration of your equipment or reliability of its connection, we cannot be responsible for communication failures, distortions, or delays when you trade on-line (via the Internet).
Market Risks & Online Trading: Trading contracts for differences, currencies, commodities, cryptos, futures, and indices involves substantial risks that may not be suitable for everyone. Trading online, no matter how convenient or efficient, does not necessarily reduce risks associated with securities trading and may increase the risks in the event of communication breakdowns.
Password Protection: The Trader is obligated to keep passwords secret and ensure that third parties do not obtain access to the trading facilities. The Trader will be liable to SGT for trades executed by means of the Trader’s password, even if such use may be wrongful.
Quoting Errors: Should quoting errors occur due to a dealer’s mistype of a quote or an erroneous price quote from a pricing source, SGT will not be liable for the resulting errors in account balances. SGT reserves the right to make the necessary corrections or adjustments on the account involved. Any dispute arising from such quoting errors will be resolved on the basis of a fair market value of the contract or security at the time such an error occurred.

11. Off-exchange Transactions

In OTC markets, firms are not restricted to effect off-exchange transactions. The firm with which you deal may be acting as your counterparty to the transaction. It may be difficult or impossible to liquidate an existing position, to assess the value, to determine a fair price or to assess the exposure to risk. For these reasons, these transactions may involve increased risks. Off- exchange transactions may be less regulated or subject to a separate regulatory regime. Before you undertake such transactions, you should familiarize yourself with applicable rules and attendant risks.

Notice for clients with annual income or net worth less than $25,000:

If a customer’s annual income or net worth is less than $25,000, the customer is advised to read and understand the following Risk Statements: The potential for loss in trading Forex and CFDs can be substantial. You should therefore carefully consider whether such trading is suitable for you in light of your personal financial circumstances and financial resources. The high degree of leverage that is obtainable in Forex trading and CFDs trading on account of minimal margin requirements can work against you as well as for you. The use of leverage can lead to large losses as well as gains. Please consider the financial risks involved in Forex trading with regard to your personal financial circumstances and financial resources, before proceeding to open an account with SGT.

12. Risk Warning

CFDs, FX, futures, crypto, commodities and other leveraged products carry a high level of risk to your capital, with the possibility of losing significantly more than your initial investment. They are not suitable for everyone. Ensure you fully understand the risks and seek independent advice if necessary.

Please contact our Compliance Department with any questions regarding the terms and conditions under which you may open an account and trade or invest with SGT.

The services and products offered by SGT are not being offered within the United States of America and are not being offered to U.S. citizens, as defined under U.S. law. As such, should you reside in or be a citizen of a country in which SGT does not conduct business, any email message received is not intended to serve as a solicitation or inducement on behalf of any of the aforementioned entities. Furthermore, SGT does not accept traders, clients or customers from Ontario, Canada, and is not registered to sell securities in the province of Ontario, Canada. SGT has not been registered or qualified under the securities laws of the United States or any other jurisdiction or with any other supervisor or regulatory authority, outside of the British Virgin Islands.

SGT services are not intended for distribution to, or use by, any person, corporation, trust or partnership in any country or jurisdiction where such distribution or use would be contrary to local law or regulation. It is the responsibility of the trader, client, or customer to ascertain the terms of and comply with any local law or regulation to which they are subject.

Investments of any kind can carry a risk of losing money and may not be suitable for everyone. Ensure you fully understand the risk of investing into products and programs, and seek independent advice if necessary on these products and programs.

Restricted Countries

By accessing or using this website (the “Site”) of Sterling Gent Trading Ltd and its affiliates (collectively, "SGT"), you hereby accept and agree to comply with these Terms and Conditions of Use. You acknowledge your understanding that these Terms and Conditions of Use constitute a binding agreement between you and SGT (sometimes referred to as “we” or “us”) that governs your access and use of the Site, which includes any images, text, illustrations, designs, icons, photographs, programs, music clips, downloads, systems and methods of trading, video clips, graphics, user interfaces, visual interfaces, information, data, tools, products, written materials, services and other content (together, "Content"), including but not limited to the design, structure, selection, coordination, expression and arrangement of the Content available on or through the Site.

Please read these terms and conditions of use carefully before using the site. Each time you use the site, your use indicates your full acceptance of and agreement to abide by these terms and conditions in current form. If you do not accept the terms and conditions stated herein, do not use the site. If you do not agree to these terms and conditions of use, you agree that your sole and exclusive remedy is to discontinue using the site.

Your compliance with these terms and conditions of use and all other rules, procedures, policies, terms and conditions that govern all or any portion of the site is a condition to your right to access the site. Your breach of any provision of these terms and conditions of use or other rules, procedures, policies, terms and conditions that govern all or any portion of the site will automatically, without the requirement of notice or other action, revoke and terminate your right to access the site and you will be fully liable for conversion, misappropriation, trespass to chattels and all other claims and causes, regardless of the identity of claimant or injured party, arising from or relating to your continued use of the site after such breach.

1. Limited Right to Use

SGT grants you a limited right to use the Site. Your right to use the Site is subject to your agreement to abide by these Terms and Conditions of Use in their entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of the Site. At any time and for any reason SGT may revoke your right to use all or any portion of the Site.

2. Updates to the Site

SGT reserves the right to change or modify the terms and conditions contained in these Terms, including but not limited to any policy or guideline of the Site, at any time and at its sole discretion. We will provide notice of these changes by posting the revised Terms to the Site and changing the 'Last Revised' date at the top of the Terms, or by emailing Users at their provided email addresses, or by any other means as determined by SGT. Method of notification will be left to SGT's sole discretion. Using a particular form of notice in some instances does not obligate us to use the same form in other instances. Any changes or modifications will be effective immediately upon posting the revisions to the Site or at the instant that SGT transmits the information to the Users (e.g. via email). These changes will apply at that instant to all then current and subsequent uses of the Site. You waive any right you may have to receive specific notice of such changes or modifications.

Your continued use of this Site acts as acceptance of such changes or modifications. If you do not agree to the Terms in effect when you access or use the Site, you must stop using the Site.

3. Eligibility

By accessing or using the Site, you represent and warrant that you are at least 18 years old and have not previously been suspended or removed from the Site. You also represent and warrant that you are not a resident of a Restricted Country, State or Territory as defined here. The list of Restricted locales is subject to change at any time. In the event a locale becomes Restricted, SGT will provide Users residing in that area with notice via email, a notification on our Site, or other means as we deem necessary, regarding their access to the Services.

You represent and warrant that you are not:

(a) located in, under the control of, or a national or resident of any country to which the British Virgin Islands has embargoed goods or services,

(b) identified as a “Specially Designated National,” or

(c) placed on the Commerce Department's Denied Persons List. You further represent and warrant that you will not use the Site if the laws of your country prohibit you from doing so in accordance with these Terms.

Finally, you represent and warrant that you will not be using this site for any illegal activity, including but not limited to illegal gambling, money laundering, fraud, blackmail, extortion, ransoming data or the financing of terrorism, or other violent activities.

Notwithstanding the foregoing, SGT may not make the Services, in whole or in part, available in every market, either in its sole discretion or due to legal or regulatory requirements, depending on the User’s location.

4. Privacy Policy

Your privacy is important to us. We only share your information with third parties as outlined in our Privacy Policy or as required to do so by law enforcement, court order, or in compliance with identity verification or legal reporting obligations in SGT’s sole judgment.

5. Cookies

We may collect certain aggregate and non-personal information when you visit the Site as laid out in our Cookie Policy. We may collect this information through "cookie" technology. Cookies are bits of text that can be placed on your computer's hard drive when you visit certain web sites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. The "help" portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of the Site features.

6. Confidentiality of The Transmission of Information Over the Internet

The transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks may not always be secure, although SGT utilizes PHP encryption, and is subject to possible loss, interception, or alteration while in transit. Accordingly, SGT does not assume any liability, without limitation, for any loss or damage you may experience or costs you may incur as a result of any transmissions over the Internet or other publicly accessible networks, including but not limited to transmissions involving the Platform or e-mail with SGT containing your personal information. While SGT will take commercially reasonable efforts to safeguard the privacy of the information you provide to SGT and will treat such information in accordance with SGT's Privacy Policy, in no event will the information you provide to SGT be deemed to be confidential, create any fiduciary obligations for SGT, or result in any liability for SGT in the event that such information is negligently released by SGT or accessed by third parties without SGT's consent.

7. Ownership Of Materials On Site

You may download or copy Content only to the extent such download is expressly permitted in writing on the Site. No right, title or interest in any downloaded materials or software is transferred to you as a result of any such downloading or copying. You may not reproduce (except as noted above), publish, transmit, distribute, display, modify, create derivative works from, sell or participate in any sale of or exploit in any way, in whole or in part, any of the Content, the Site or any related software.

Nothing on the Site shall be interpreted as granting any license or right to use any image, trademark, trade dress, logo or service mark on the Site. Anything transmitted to the Site by you becomes SGT’s property and may be used by us for any lawful purpose. SGT reserves all rights with respect to copyright and trademark ownership of all material on the Site, and will enforce such rights to the full extent of the law.

Unless otherwise noted, all Contents are copyrights, trademarks, trade dress and/or other intellectual property owned, controlled or licensed by SGT or by third parties who have licensed their materials to SGT and are protected by U.S. and international copyright laws. The compilation of all Contents on the Site is the exclusive property of SGT and is also protected by U.S. and international copyright laws.

8. Copyright Infringement

The Digital Millennium Copyright Act of 1998, found at 17 U.S.C. § 512 (“DMCA”), provides recourse for owners of copyrighted materials who believe that their rights under United States copyright law have been infringed upon on the Internet.

 Under the DMCA, the bona fide owner of copyrighted materials who has a good faith belief that their copyright has been infringed may contact not only the person or entity infringing on their copyright, but may also contact the designated agent of an Internet Service Provider (“ISP”) to report the alleged infringements of protected works, when such alleged infringements appear on pages contained within the system of the Internet Service Provider.

9. Third-Party Content

References on this Site to any names, marks, products or services of third parties, or hypertext links to third party sites or information or Content provided by third parties, are provided solely as a convenience to you and do not in any way constitute or imply our endorsement, sponsorship or recommendation of the third party, its information, materials or services. We are not responsible for the practices or policies of such third parties, nor the Content of any third-party sites, and do not make any representations regarding third party materials or services, or the Content or accuracy of any material on such third-party sites. If you decide to link to any such third-party sites, you do so entirely at your own risk.

10. Blogs & Social Networks

Certain areas within the Site may allow you to participate in blog discussions and other forms of social networking. These blogs and social networks are accessible to other users, and any information posted in such areas can be read, collected, shared, or otherwise used by other users who access the Site. You are solely responsible for any information you choose to submit in these forums.

11. Copyright of Feedback Materials

You acknowledge and agree that any materials, including but not limited to questions, comments, feedback, suggestions, ideas, plans, notes, drawings, original or creative materials or other information or commentary you provide on our platform or one of our social media accounts, regarding SGT or the Services (collectively, 'Feedback') that are provided by you, whether by email, posting to the Site or otherwise, are non-confidential and will become the sole property of SGT. SGT will own exclusive rights, including all intellectual property rights, and will be entitled to the unrestricted use and dissemination of such Feedback for any purpose, commercial or otherwise, without acknowledgment or compensation to you.

12. User Conduct & Obligations

In connection with your use of the Services and in addition to the list of prohibited activities in Section 1 above, you will not:

(a) Violate or assist any party in violating any law, statute, ordinance, regulation or any rule of any self-regulatory or similar organization of which you are or are required to be a member through your use of the Services;

(b) Provide false, inaccurate, incomplete or misleading information;

(d) Distribute unsolicited or unauthorized advertising or promotional material, any junk mail, spam, or chain letters;

(e) Use a web crawler or similar technique to access our Services or to extract data,

(f) Reverse engineer or disassemble any aspect of the Site or Services in an effort to access any source code, underlying ideas and concepts, and algorithms;

(g) Take any action that imposes an unreasonable or disproportionately large load on our infrastructure, or detrimentally interfere with, intercept, or expropriate any system, data, or information;

(h) Transmit or upload any material to the Site that contains viruses, Trojan horses, worms, or any other harmful or deleterious programs;

(i) Otherwise attempt to gain unauthorized access to the Site, other SGT Accounts, computer systems or networks connected to the Site, through password mining or any other means;

(j) Or Transfer any rights granted to you under these Terms.

13. Site Security

You may not violate or attempt to violate the security of the Site. Tampering with any portion of the Site, providing untruthful or inaccurate information, misrepresenting your identity, or conducting fraudulent activities on the Site, whether or not through the use of agents, are prohibited and constitute a breach of these Terms and Conditions of Use.

You are prohibited from violating or attempting to violate the security of the Site, including, without limitation,

(a) accessing data not intended for you or logging onto a server or an account which you are not authorized to access;

(b) disabling, removing, defeating, or avoiding any security device or system, including, without limitation, any password and login functionality used to authenticate users;

(c) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization;

(d) attempting to interfere with service to any user, host or network, including, without limitation, via means of submitting a virus to the Site, overloading, "flooding," "spamming," "mailbombing" or "crashing;"

(e) sending unsolicited email, including promotions and/or advertising of products or services;

(f) forging any TCP/IP packet header or any part of the header information in any email or posting;

(g) using or attempting to use any engine, software, tool, agent or other device or mechanism (including, without limitation, browsers, spiders, robots, avatars or intelligent agents) to navigate or search the Site other than the search engine and search agents available on the Site and other than generally available third-party web browsers;

(h) reverse engineering, decompiling or disassembling the underlying software;

(i) removing any notices, warnings, labels, annotations or instructions from any portion of the Site or any related material, including, without limitation, any patent, trademark, copyright, or other proprietary notices or license provisions; or

(j) otherwise invading the privacy of, obtaining the identity of, or obtaining any personal information about any user of the Site.

Any violations of system or network security, including attempts to intentionally access a computer without authorization or exceed your authorized access level, may result in civil and criminal charges, including but not limited to charges under applicable British Virgin Islands legislation. SGT may investigate occurrences that might involve such violations and may involve, and cooperate with, law enforcement authorities in prosecuting users who are involved in such violations. We may, without prior notice or warning of any kind, restrict or terminate the access of any and all users to the Site if we reasonably conclude that such restriction or termination is necessary to prevent, or prevent the further spread, of a virus, security breach or system malfunction.

14. No Offers or Reliance

The information on this website is provided for informational purposes only. No Content or other material on the Site shall be used or considered as an offer to sell or a solicitation of any offer to buy the securities or services of SGT or any other issuer. Offers can only be made where lawful under, and in compliance with, applicable law.

SGT makes no representations that transactions, products or services discussed on the Site are available or appropriate for sale or use in all jurisdictions or by all investors. Those who access the Site do so at their own initiative and are responsible for compliance with local laws or regulations.

While SGT uses reasonable efforts to obtain information from reliable sources, SGT makes no representations or warranties as to the accuracy, reliability or completeness of any information or document at the Site obtained outside of SGT. Certain information on the Site may contain forward-looking statements, which reflect our views with respect to, among other things, our operations and financial performance. Such forward-looking statements are subject to various risks and uncertainties and speak only as of the date on which they are made. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from this indicated in these statements. You can identify these forward-looking statements by the use of words such as “outlook,” “indicator,” "believe," "expect," “potential,” “continue,” “may,” “should,” “seek,” “approximately,” “predict,” "anticipate," "optimistic," "intend," “plan,” “estimate,” "aim," "will" or the negative version of these words or similar expressions. SGT undertakes no obligation to update publicly or revise any information on the Site, whether as a result of new information, future developments or otherwise. Opinions and any other Contents at the Site are subject to change without notice.

SGT is not utilizing the Site to provide investment or other advice, and no information or material at the Site is to be deemed a recommendation to buy or sell any securities or is to be relied upon for the purpose of making or communicating investment or other decisions. In addition, no information, Content or other materials contained on the Site should be construed or relied upon as investment, legal, accounting, tax or other professional advice or in connection with any offer or sale of securities. Any transactions listed on the Site are included as representative transactions and are not necessarily reflective of overall performance.

SGT does not advise on the tax consequences of any investment.

15. No Transferability

While the Account and the Services provided to a User are not transferable under any circumstance and shall be used only by the User, SGT shall have the right to transfer, assign, or sell all the rights, benefits, or obligations to any person and these Terms shall continue to be in force and effect for the benefit of the successors and assigns of SGT or its lenders, if any.

16. Indemnification

You agree to indemnify, defend and hold SGT, its affiliates and service providers, and each of their respective officers, directors, agents, joint venturers, employees, and representatives, harmless from any claim or demand (including attorneys’ fees and costs and any fines, fees or penalties imposed by any regulatory authority) arising out of or related to (i) your breach of these Terms, (ii) your use of Services, or (iii) your violation of any law, rule, or regulation, or the rights of any third party.

17. Disclaimer of Warranties

By using the site, you expressly agree that such use is at your sole risk. The site and related services are provided on an "as is", "as available" and “with all faults” basis. Neither sgt nor any of its respective officers, directors, employees, agents, third-party content providers, designers, contractors, distributors, merchants, sponsors, licensors or the like (collectively, "associates") warrant that use of the site or related services will be uninterrupted or error-free. Neither sgt nor its associates warrant the accuracy, integrity, completeness, availability or timeliness of the content provided in the site or the materials or services offered in the site now or in the future. Sgt and its associates specifically disclaim all warranties, whether expressed or implied, including but not limited to warranties of title, merchantability, fitness for a particular purpose or non-infringement of the site, information on the site or the results obtained from use of the site or related services.

Under no circumstances will sgt or its associates be liable to you or anyone else for any direct, consequential, incidental, special, exemplary, punitive or other indirect damages, including but not limited to lost profits, trading losses, unauthorized access, systems failure, communications line failure, internet failure or damages that result from use or loss of use of the site, content, inconvenience or delay. This is true even if sgt has been advised of the possibility of such damages or losses.

Any content downloaded or otherwise obtained through the site is done at your own discretion and risk and you are solely responsible for any damage to your computer or other electronic system or loss of data that results from the download of any such content. The foregoing limitation of liability will apply in any action, whether in contract, tort or any other claim, even if an authorized representative of sgt has been advised of or should have knowledge of the possibility of such damages.

Additionally, you acknowledge that sgt does not act or serve as your broker, intermediary, agent, or advisor with respect to any transaction you make or propose to make using the services and owes you no fiduciary duty.

18. Warning Regarding Web Fraud & Phishing

Our name, brands and reputation may be misused by imposters and frauds publishing fake web sites and engaging in "phishing" scams seeking personal or confidential information.

When communicating with SGT through digital media, please:

(a) Confirm you are visiting a SGT authorized web site.

(b) Do not share your password and login ID with anyone, including anyone from SGT. Certain SGT web sites are private, available only to clients through secure log-in procedures. Apart from allowing you to use your password and log-in to enter an authorized web site, SGT will never ask you for your password or log in information. (If you forget your password or login, we will issue you new ones.)

(c) Do not communicate or deal with personnel who are not affiliated with an authorized office. All authorized office locations are listed on our contact page. No other office locations are authorized offices of SGT.

(d) Do not send e-mails to anyone with an address other than authorized SGT e-mail addresses. SGT only uses “@SGT.com” for e-mail addresses. SGT does not permit our employees and authorized representatives to send or receive work related e-mails from personal accounts or any other address.

If you have any questions about the above, please contact SGT using our Contact Us page.

19. Representations & Warranties

You represent and warrant that:

(i) you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to these Terms and Conditions of Use;

(ii) you have not and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of these Terms and Conditions of Use; and

(iii) you will not delete any Content.

20. Termination of Use

These Terms and Conditions of Use are effective unless and until terminated by either you or SGT. You may terminate these Terms and Conditions of Use at any time, provided that you discontinue any further use of the Site. We also may terminate these Terms and Conditions of Use, in our sole discretion, at any time and may do so immediately without notice, and accordingly deny you access to the Site. Upon any termination of these Terms and Conditions of Use by either you or us, you must promptly destroy all materials downloaded or otherwise obtained from the Site, as well as all copies of such materials, whether made under these Terms and Conditions of Use or otherwise.

21. Applicable Law & Venue

If a legal or equitable claim is subject to arbitration, you agree that British Virgin Islands arbitration law applies. If a legal or equitable claim is not subject to arbitration, you agree that federal law and the laws of the British Virgin Islands and conflict of law provisions, apply. You agree that any legal or equitable claim arising out of or relating to your use of the Services or these Terms that is not subject to arbitration will be filed only in the state courts of the British Virgin Islands. You irrevocably and unconditionally consent and submit to the exclusive jurisdiction of such courts over any suit, action, or proceeding arising out of these Terms.

22. Arbitration

By using the Site, you agree that SGT, at its sole discretion, may require you to submit any disputes arising from the use of the Site, related services or these Terms and Conditions of Use concerning or, including disputes arising from or concerning their interpretation, violation, nullity, invalidity, non-performance or termination, as well as disputes about filling gaps in this contract or its adaptation to newly arisen circumstances, to final and binding arbitration under the International Rules of Arbitration, by one or more arbitrators appointed in accordance with the said rules. Notwithstanding these rules, however, such proceeding shall be governed by the laws of the state as set forth in the previous section.

23. Effect on Other Agreements

Nothing contained in these Terms and Conditions of Use is intended to modify or amend any other written agreement you may have with SGT (including without limitation any customer agreement, participation agreement or account agreement) (collectively, “Other Agreements”), if any, that may currently be in effect. In the event of any inconsistency between these Terms and Conditions of Use and any Other Agreement, the Other Agreement will govern. Some pages within the Site contain supplemental terms and conditions and additional disclosure and disclaimers, which are in addition to these Terms and Conditions of Use. In the event of a conflict, such supplemental terms and conditions and additional disclosures and disclaimers will govern for those sections or pages.

24. Severability Waiver

If any provision of these Terms is deemed unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from these Terms and will not affect the validity and enforceability of any remaining provisions. Any delay or failure by SGT to enforce any of its rights shall not constitute a continuing waiver of such rights.

25. Integration

The failure of us to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision. These Terms and any policies or operating rules posted by us constitutes the entire agreement and understanding between you and us and govern your use of the Services, superseding any prior or contemporaneous agreements, communications and proposals, whether oral or written, between you and us (including, but not limited to, any prior versions of these Terms). Any ambiguities in the interpretation of these Terms shall not be construed against the drafting party.

26. Governing Language & Translations

You agree that these Terms, SGT's Privacy Policy, and other notices posted through the Services have been drafted in English. Although translations in other languages of any of the foregoing documents may be available, such translations may not be up to date or complete. Accordingly, you agree that in the event of any conflict between the English language version of the foregoing documents and any other translations thereto, the English language version of such documents shall govern.

27. Questions & Contact Information

If you have questions or comments about this Terms of Use or the Site, please contact us using the information below:

Sterling Gent Trading Ltd
Craigmuir Chambers,
Road Town, Tortola, British Virgin Islands
British Virgin Islands

Email: info@sgt.markets

Please check the website before contacting support. When contacting SGT, please provide all relevant information to your enquiry so that we can assist you as swiftly as possible. Although we make no representations or provide no warranties about the speed of response, we will get back to you as soon as possible.