:::The sources are all primary, but SpotOption Exchange lists Banc de Binary as an "associate".. So Banc de Binary isn't just licensing the software; they're reselling SpotOption Exchange. In the legal agreements from SpotOption, we find "The Company sets the prices to be used in binary options trading." and "The Company shall be the sole execution venue for the execution of its clients’ orders.". So the counter-party is SpotOption Exchange itself. There is no "exchange" here; other traders are not counter-parties. Technically, this is a bucket shop.