Terms and Conditions 

Client Agreement of Vatee Pty Limited

Last Updated: February 2026

This Client Agreement (the “Agreement”) is issued by Vatee Pty Limited (Company Registration No. 40097), with its registered office at C/- SFAI Barrett & Partners Vanuatu, 1/Floor, B&P House, Kumul Highway, Port Vila, Vanuatu.

This Agreement sets out the legally binding terms and conditions governing your relationship with Vatee Pty Limited (“we”, “us”, “our”) in connection with your dealings in financial products offered by us, namely Margin Foreign Exchange Contracts (Margin FX Contracts) and Contracts for Difference (CFDs). It applies to all services, transactions, and interactions you may have with us through your trading account.

By submitting your Application Form electronically via our Website, you acknowledge and agree that:
a) you have read and understood this Client Agreement and all related documentation provided by us;
b) you authorise us to open a trading account in your name;
c) all transactions and services provided under this Agreement are subject to applicable laws and regulations;
d) you agree to be legally bound by the terms and conditions set forth herein.

Once an account is opened, you are deemed to have accepted and be bound by the terms of this Agreement in all dealings with us. All transactions entered into under this Agreement are legally valid, binding, and enforceable.

We reserve the right to amend, revise, or update this Agreement at any time. The most recent version will be published on our Website and/or made available through our Trading Platform. This Agreement may not be modified by oral statements or informal communication unless confirmed by us in writing.

You are advised to read this Agreement carefully and seek independent legal or financial advice if necessary. If this Agreement is provided to you in any language other than English, the translation is for information purposes only. In the event of any discrepancy or inconsistency, the English version shall prevail.

1. Scope of Agreement

This Agreement outlines the comprehensive framework under which we provide our financial services and conduct transactions with you. It governs all contractual, operational, and regulatory aspects of your relationship with Vatee Pty Limited. The key areas covered by this Agreement include:
a) Our Services and Client Eligibility
b) Account Establishment and Client Responsibilities
c) Order Placement, Pricing, and Execution Rules
d) Margin Requirements and Monitoring Obligations
e) Fees, Charges, and Third-Party Costs
f) Risk Disclosures and Limitation of Liability
g) Use of Client Money and Banking Conditions
h) Notice and Communication Procedures
i) Termination and Default Events
j) Complaints and Dispute Resolution Mechanism
k) Agreement Amendments and Applicable Policies

You acknowledge that these provisions collectively form the legal basis for all activity conducted through your account and remain in effect for the duration of your relationship with us, subject to applicable laws and any updates made pursuant to the terms of this Agreement.

2. Services Provided and Client Eligibility

2.1 Nature of Our Services

We offer services in over-the-counter (OTC) derivatives, including Margin FX Contracts and CFDs. These financial products are not traded on any exchange and are not cleared or guaranteed by a central counterparty. Our services include:
a) providing access to our Trading Platform for the execution of Contracts;
b) pricing, quoting, and confirming your trades;
c) maintaining your account and records; and
d) providing trade execution and risk management infrastructure.

We do not provide personal advice or discretionary trading. Any information provided by us is general in nature and does not consider your personal objectives, financial situation, or needs. You are solely responsible for assessing the suitability of our services.

2.2 No Personal Advice

You acknowledge that:
a) we do not provide personal advice or act as your fiduciary;
b) any statement made by our staff or materials published by us is general information only;
c) you must consider your own objectives and financial situation before entering into any Contract; and
d) you should seek independent financial advice if necessary.

2.3 Eligibility Criteria

To be eligible to open an account with us and use our services, you must:
a) be at least 18 years of age;
b) have the legal capacity to enter into a binding contract;
c) not be a resident of a jurisdiction in which our services are restricted or prohibited; and
d) provide complete and accurate information in your application.

We may refuse your application at our sole discretion and are not required to provide reasons.

2.4 Client Classification

We may classify you in accordance with applicable laws, regulations, or internal policies. You acknowledge that:
a) classification may affect your regulatory protections and disclosure entitlements;
b) we may reclassify you upon notice or request; and
c) you must inform us of any change in your status or eligibility.

2.5 Anti-Money Laundering (AML) Obligations

We are committed to complying with the Vanuatu Anti-Money Laundering and Counter-Terrorism Financing Act No. 13 of 2014 and related regulations. You agree to:
a) provide all identification and verification documents upon request;
b) allow us to verify your identity electronically or otherwise;
c) not initiate or participate in any transaction that may involve proceeds of crime; and
d) promptly update us if any information you have provided changes.

We may delay, block, or refuse to process any transaction if we suspect it may breach AML laws or our internal policies. We are not liable for any loss caused by such action.

3. Account Opening and Operation

3.1 Application Process

To open an account, you must complete our online Application Form and provide all required information and documentation. We reserve the right to accept or reject any application at our sole discretion.

We will notify you when your account has been approved and is ready for use. You must not attempt to place orders or access trading services before receiving confirmation of account activation.

3.2 Accurate and Up-to-Date Information

You agree to ensure that all information provided to us is complete, accurate, and current at all times. You must promptly notify us of any changes to your contact details, financial circumstances, or other material information.

We are not responsible for any loss arising from your failure to update your information or notify us of changes.

3.3 Account Security

You are responsible for maintaining the confidentiality and security of your account credentials, including your username, password, and any authentication codes.

You agree that:
a) you will not share your credentials with any third party;
b) you will take reasonable steps to prevent unauthorised access to your account;
c) you will notify us immediately if you suspect any breach of security or misuse of your account; and
d) we may rely on any instructions received through your account unless and until we are notified otherwise.

We are not liable for any loss resulting from unauthorised use of your account unless caused by our gross negligence or wilful misconduct.

3.4 Joint Accounts

If your account is held jointly with another person:
a) each account holder is jointly and severally liable for all obligations and liabilities under this Agreement;
b) any one account holder may act on behalf of all account holders, including placing orders and requesting withdrawals;
c) we may act on instructions from any individual account holder unless otherwise agreed in writing; and
d) in the event of death of one account holder, the surviving holder(s) shall provide appropriate documentation to us, and we may treat the surviving holder(s) as having full authority over the account.

4. Orders and Execution

4.1 Placing Orders

You may place orders through our Trading Platform or as otherwise permitted by us. Orders may be submitted in electronic or written form, and we may acknowledge them in the same manner. Orders may take the form of:
a) Market Orders;
b) Limit Orders;
c) Stop Orders;
d) Take Profit or Stop Loss Orders; or
e) other types as made available on our Trading Platform.

We reserve the right to reject any order or delay execution at our sole discretion, including for reasons related to liquidity, pricing, technical issues, or regulatory compliance.

4.2 Order Execution and Confirmation

Orders will be executed in accordance with our execution policy, as published on our Website or made available upon request. You acknowledge and agree that:
a) execution times may vary depending on market conditions and system performance;
b) slippage may occur, and the final executed price may differ from the quoted price;
c) we do not guarantee the execution of any order at a specific price or time; and
d) once an order is executed, it is final and binding.

We will provide you with confirmation of each executed order through the Trading Platform or by email. It is your responsibility to review confirmations and notify us promptly of any discrepancies.

4.3 Order Restrictions

We may impose restrictions on orders, including but not limited to:
a) minimum or maximum trade sizes;
b) leverage limits;
c) margin requirements;
d) restricted trading hours; and
e) limits on specific instruments or account types.

Such restrictions will be made available on our Website or notified to you through the Trading Platform.

4.4 Order Cancellation or Modification

You may request to cancel or modify an order that has not yet been executed. We will use reasonable efforts to comply with your request but do not guarantee that it can be actioned.

We reserve the right to cancel or adjust any executed order in the event of manifest error, pricing issue, system failure, regulatory intervention, or other exceptional circumstances.

5. Margins and Client Obligations

5.1 Initial and Ongoing Margin Requirements

You are required to maintain sufficient funds in your account to meet margin requirements for all open positions. Margin requirements are calculated by us and may vary depending on:
a) the instrument being traded;
b) the size of the position;
c) market volatility;
d) applicable regulatory requirements; and
e) our internal risk management policies.

You must ensure that the balance of your account is sufficient to meet initial and ongoing margin requirements before placing or maintaining any position.

5.2 Leverage and Margin Adjustment 

The Company may, at its sole discretion, adjust the maximum leverage applicable to a Client’s account at any time, including in response to account equity, margin utilisation, exposure levels, market conditions or internal risk management requirements.

Any leverage thresholds or examples published by the Company are indicative only and do not constitute a fixed or guaranteed leverage entitlement.

a) Indicative Leverage Based on Account Equity

Account Equity         Indicative Maximum Leverage

30,000 or above         1:400

50,000 or above         1:200

100,000 or above       1:100

200,000 or above       1:50

300,000 or above       1:25

500,000 or above       1:20

b) Indicative Leverage Based on Used Margin

Used Margin              Indicative Maximum Leverage

20,000 – 100,000        1:100

100,001 or above       1:50

Leverage adjustments may be applied automatically or manually. Where leverage is reduced, any subsequent adjustment is subject to the absence of open positions, prevailing risk conditions and the Company’s assessment at the relevant time. The Company does not guarantee that leverage will be restored to any prior or default level.

The Client acknowledges that leverage adjustments may increase margin requirements and may result in margin calls, forced liquidation or other risk control actions being applied without prior notice. The Company shall not be liable for any losses arising from such actions.

The Client remains solely responsible for monitoring account equity, margin levels and exposure at all times.

5.3 Margin Shortfalls and Close-Out

If the equity in your account falls below the required margin level, you must promptly deposit additional funds or reduce your exposure. We may, without notice, take any of the following actions:
a) close out all or part of your open positions;
b) convert currencies or apply account balances toward margin obligations;
c) refuse to accept new orders or requests; and
d) suspend or restrict your access to the Trading Platform.

You remain liable for any shortfall in your account following such actions. We are not obligated to notify you before taking these measures and do not provide margin call warnings.

5.4 Monitoring Obligations

You are solely responsible for monitoring your account, margin usage, and open positions. You acknowledge that:
a) margin levels may fluctuate rapidly due to market conditions;
b) you must actively monitor your account to avoid forced liquidation;
c) reliance on automated notifications or platform alerts is at your own risk; and
d) we may take risk management action without your prior consent.

5.5 Negative Balance Protection

We provide negative balance protection on a discretionary basis. Where available, this means that your account balance will not fall below zero due to trading losses.

However, you acknowledge that:
a) negative balance protection may not apply in all cases or to all account types;
b) protection may be voided in the case of abusive trading practices or breaches of this Agreement; and
c) you remain responsible for losses due to unauthorised access or fraud.

6. Fees and Charges

6.1 Types of Fees

You agree to pay all applicable fees, charges, and costs associated with your account and trading activity. These may include:
a) spreads or commissions on each trade;
b) overnight financing or swap charges;
c) withdrawal or transfer fees;
d) inactivity or account maintenance fees; and
e) third-party service or data fees.

All fees are published on our Website or notified to you in advance. You are responsible for reviewing applicable charges before entering into any transaction.

6.2 Fee Changes

We may change our fees and charges from time to time. Any changes will take effect on the earlier of:
a) the date specified in the notice provided to you; or
b) the date you enter into a new Contract after the change.

Continued use of our services after such changes constitutes acceptance of the new fee terms.

6.3 Taxes and Other Costs

You are responsible for all applicable taxes, levies, and duties arising from your trading activity or use of our services. You acknowledge that:
a) we do not provide tax advice;
b) you must consult your own tax adviser; and
c) we may withhold amounts from your account if required by law.

Additional costs may apply that are not paid via or imposed by us. You must consider all such costs when evaluating our services.

7. Client Money and Funding

7.1 Treatment of Client Money

We will handle your funds in accordance with applicable client money laws and regulations in Vanuatu. Client money will be held in a segregated bank account, separate from our own funds.

You acknowledge and agree that:
a) client money may be pooled with funds of other clients in the same account;
b) interest earned (if any) on client money will be retained by us unless otherwise agreed;
c) client money may be used to meet your obligations to us in connection with your trading activity; and
d) client money may be held outside Vanuatu, including in jurisdictions that may not afford the same protections.

We are not responsible for the solvency or performance of any bank or custodian holding client money.

7.2 Funding Your Account

You may fund your account using any method approved by us, including bank transfer, credit/debit card, or payment service provider. You are responsible for all transfer fees and costs.

Funds will be credited to your account once cleared and identified. We are not liable for delays caused by third-party payment systems or incorrect payment references.

7.3 Non-Genuine Funding and Payment Activity

To protect the integrity of our payment infrastructure and prevent abusive or non-commercial use of our services, Vatee reserves the right to assess whether account funding and withdrawal activity is proportionate to genuine trading usage.

As a general assessment benchmark, trading activity equivalent to approximately 1 standard lot of XAUUSD trading volume per USD 1,000 deposited (or equivalent notional exposure in other financial products) may be considered indicative of normal platform usage. All assessments are conducted reasonably and on a case-by-case basis.

Where deposits and withdrawals are conducted with limited or non-genuine trading activity, we may, at our reasonable discretion, apply administrative, processing, blockchain network, or payment handling charges, including fees of up to 3% of the relevant deposit and/or withdrawal amount where operational or third-party costs are considered disproportionate to the nature of the account activity.

7.4 Withdrawals

You may request to withdraw available funds from your account at any time, subject to:
a) completing identity verification and providing any required documentation;
b) sufficient funds being available after accounting for open positions and margin requirements;
c) compliance with applicable laws and our internal policies; and
d) using a withdrawal method in your own name and accepted by us.

We reserve the right to delay or refuse a withdrawal if we suspect fraud, financial crime, or breach of this Agreement.

8. Risk Disclosure and Limitation of Liability

8.1 Risk Warning

Trading in Margin FX and CFDs involves significant risk of loss and is not suitable for all investors. You acknowledge that:
a) you may lose more than your initial investment;
b) past performance is not indicative of future results;
c) leverage amplifies both potential gains and losses; and
d) market volatility, liquidity, and system interruptions may adversely affect outcomes.

You are responsible for understanding the risks of each product and should not trade unless you fully understand the nature and extent of your exposure.

8.2 No Guarantee of Outcomes

We do not guarantee the performance of any product, service, or trading outcome. You acknowledge that:
a) all trading decisions are made by you at your own risk;
b) we do not provide investment, legal, or tax advice;
c) any illustrations, examples, or statements made by us do not constitute a recommendation; and
d) you should consult independent professional advisers as needed.

8.3 Limitation of Liability

To the maximum extent permitted by law, we are not liable for:
a) any loss or damage arising from your use of or inability to use our services;
b) delays, errors, or interruptions in transmission, execution, or platform access;
c) any act or omission of a third party, including liquidity providers or technology vendors; or
d) indirect, incidental, special, or consequential losses, including loss of profits, opportunity, or goodwill.

Our total aggregate liability to you under this Agreement is limited to the amount of fees you have paid us in the preceding six (6) months.

9. Communication and Notices

9.1 Communication Methods

We may communicate with you using any of the following methods:
a) electronic mail (email);
b) secure message via the Trading Platform;
c) posting information on our Website;
d) telephone calls or text messages (SMS); or
e) postal mail, where applicable.

You agree that electronic communication has the same legal effect as if provided in writing and signed.

9.2 When Notices Are Deemed Received

Unless otherwise agreed, notices are deemed to be received:
a) immediately upon transmission if sent via email or secure platform message;
b) at the time of publication if posted on our Website;
c) at the time of the call or message if sent by phone or SMS; and
d) three (3) Business Days after dispatch if sent by post.

You must ensure that your contact details remain up to date at all times. We are not liable for any loss resulting from communication sent to outdated or incorrect contact information provided by you.

10. Termination and Default

10.1 Termination by Either Party

Either party may terminate this Agreement at any time by providing written notice to the other. Termination will not affect:
a) any outstanding obligations or liabilities incurred prior to termination;
b) any open Contracts, which will continue to be governed by this Agreement until closed or otherwise resolved; and
c) our rights to retain, set off, or realise any client money or property as permitted under this Agreement.

You must promptly close all open positions and withdraw any available funds following termination. We may, in our discretion, close positions and return remaining funds after deducting any amounts owed to us.

10.2 Default Events

We may take any action we deem appropriate, including suspending or closing your account, if you are in default under this Agreement. Default includes but is not limited to the following events:
a) failure to make any payment or maintain margin as required;
b) breach of any term of this Agreement;
c) provision of false or misleading information to us;
d) becoming bankrupt, insolvent, or subject to any legal incapacity;
e) regulatory or legal restrictions imposed on you or your trading activity; or
f) misuse of our platform or engagement in abusive trading practices.

10.3 Prohibited and Abusive Trading

The Client shall not, directly or indirectly, engage in any Prohibited or Abusive Trading, including, without limitation:

a) placing, modifying, or cancelling orders with the intent to create a false or misleading appearance of market activity, including spoofing, layering, or other forms of market manipulation;

b) entering trades based on knowledge of pending orders, execution priority, system latency, or other non-public information in order to gain an unfair advantage;

c) opening, maintaining, or closing positions in a manner intended to exploit predictable market reactions to events, announcements, or price gaps, including by hedging opposing positions or exploiting stop-loss levels or margin mechanics;

d) engaging in trades with oneself or in collusion with others to create artificial volume, price movement, or misleading market activity;

e) using automated systems, algorithms, or bots to manipulate order books, execution priority, spreads, or liquidity;

f) trading in violation of any applicable laws, regulations, exchange rules, or other regulatory requirements;

g) engaging in any conduct that the Company determines, in its sole discretion, to be fraudulent, deceptive, manipulative, abusive, or likely to harm the Platform, the Market, or other Users.

h) engaging in any trading activity that the Company determines, in its sole discretion to be disproportionate to the Client’s account equity, margin utilisation or reasonably inferred risk capacity, including, without limitation, the placement of disproportionately large, concentrated or directional positions during periods of market illiquidity, heightened volatility, market close, rollovers or similar conditions.

The Company shall have the sole discretion to determine whether any activity constitutes Prohibited or Abusive Trading. The Company’s determination shall be final, conclusive, and binding on the Client.

The Client acknowledges and agrees that engagement in Prohibited or Abusive Trading constitutes a material breach of this Agreement and a Default Event under Section 10.2.

The Company may take any action it deems necessary in respect of Prohibited or Abusive Trading, including, without limitation, cancelling or reversing trades, liquidating positions, withholding profits, restricting, suspending, or closing the Client’s account, and reporting any suspected violations to regulatory authorities.

Nothing in this Section shall be construed as limiting the Company’s rights under this Agreement or at law to take action against any conduct it reasonably considers harmful, abusive, or otherwise improper.

10.4 Our Rights on Default

If a Default Event occurs, including but not limited to a breach of Section 10.3 (Prohibited and Abusive Trading), we may, without prior notice:

a) suspend or terminate your access to the Trading Platform;

b) close out all or part of your open positions;

c) cancel unexecuted orders;

d) convert currencies or apply account balances to offset liabilities; and

e) take any other reasonable action we consider to be necessary or reasonable to protect its interests, the integrity of the Platform, the Market, or other users, including reporting suspected violations to regulatory or enforcement authorities.

The Client may remain liable for any resulting losses, costs, or expenses incurred by us, including, without limitation, losses arising from the close out of positions, liquidation, or any actions taken under this Section.

Any determination by us that a Default Event has occurred, including a determination of whether the Client has engaged in Prohibited or Abusive Trading under Section 10.3, shall be final, conclusive, and binding on the Client.

11. Dispute Resolution

11.1 Internal Dispute Handling

If you have a complaint or dispute regarding our services, you should contact us as soon as possible. We will handle your complaint in accordance with our Complaint Handling Policy, which is available on our Website or upon request.

You agree to:
a) provide complete and accurate details of your complaint;
b) cooperate with our internal investigation process; and
c) allow us a reasonable time to review and respond.

We will acknowledge receipt of your complaint promptly and aim to provide a final response within twenty-eight (28) days.

11.2 External Resolution

If you are dissatisfied with our response or the handling of your complaint, you may refer the matter to an external dispute resolution body or authority with jurisdiction over such matters.

We may also take steps to refer the dispute to independent mediation or arbitration as appropriate.

11.3 Governing Law and Jurisdiction

This Agreement is governed by the laws of the Republic of Vanuatu. Any dispute arising out of or in connection with this Agreement that cannot be resolved through internal or external complaint processes shall be:
a) subject to the exclusive jurisdiction of the courts of Vanuatu; or
b) resolved by arbitration under applicable arbitration rules, if mutually agreed.

Nothing in this clause limits our right to initiate proceedings in any other jurisdiction where you may be located or hold assets.

12. General Terms

12.1 Entire Agreement

This Agreement, together with all policies and documents incorporated by reference, constitutes the entire agreement between you and us with respect to its subject matter.

You acknowledge that:
a) you have not relied on any representation or warranty not expressly set out in this Agreement;
b) any previous terms or communications are superseded by this Agreement; and
c) if any provision of this Agreement is found to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

12.2 Assignment and Transfer

You may not assign, transfer, or novate any of your rights or obligations under this Agreement without our prior written consent.

We may assign or transfer any or all of our rights or obligations under this Agreement to an affiliate, related entity, or third-party service provider, subject to applicable law and regulatory requirements.

12.3 Force Majeure

We are not liable for any delay or failure to perform our obligations under this Agreement due to circumstances beyond our reasonable control, including but not limited to:
a) natural disasters, pandemics, or extreme weather events;
b) war, terrorism, or civil unrest;
c) power outages or failure of telecommunications systems;
d) market disruption or trading suspension; or
e) acts of government or regulatory authorities.

We will notify you of any force majeure event affecting our services as soon as reasonably practicable.

12.4 Language and Interpretation

This Agreement is made in English. If a version is provided in any other language, it is for reference only. In the event of any discrepancy, the English version prevails.

Unless the context requires otherwise:
a) references to the singular include the plural and vice versa;
b) headings are for convenience only and do not affect interpretation;
c) references to a statute or regulation include any amendment or re-enactment; and
d) references to “including” mean “including without limitation”.

13. Amendment and Supplementary Policies

13.1 Amendments to This Agreement

We reserve the right to amend, modify, or update the terms of this Agreement at any time. Any such amendments will take effect on the earlier of:
a) ten (10) Business Days after the updated Agreement is posted on our Website; or
b) the date on which you enter into any new Contract with us following the amendment.

You are deemed to have accepted any such amendment by continuing to use our services or maintain open positions after the amendment takes effect.

If you do not agree to a proposed amendment, you may terminate this Agreement prior to the effective date of the change. Termination will not affect:
a) any obligations or liabilities accrued before termination; or
b) any open Contracts, which will remain subject to the pre-existing terms unless otherwise agreed.

13.2 No Verbal Modifications

No oral statement, informal communication, or unauthorised document shall be deemed to amend or override the terms of this Agreement unless explicitly accepted by Vatee in writing.

13.3 Supplementary Policies

This Agreement incorporates by reference the following documents and policies, each of which forms an integral part of your contractual relationship with us:
a) Privacy Policy
b) Risk Disclosure Statement
c) AML/CTF Policy
d) Complaint Handling Policy
e) KYC and Onboarding Overview
f) Restricted Jurisdictions Policy

By opening an account and using our services, you acknowledge that you have read and agreed to this Client Agreement and our Privacy Policy.
You further acknowledge that additional policies referenced herein are legally binding and available for your review on our official Website.

The most recent version of each policy is accessible at any time on our Website. Copies may also be provided upon request prior to registration. For assistance or policy access, please refer to the contact section on our Website.

You will be asked to confirm acceptance of this Client Agreement during the account registration process. Your confirmation will constitute binding acceptance of the Agreement and acknowledgement of the availability of all referenced policies.