RISK DISCLOSURE
INTRODUCTION
Trading Point of Financial Instruments Ltd, operating under the trading name XM.com, is a Cypriot
Investment Firm ("CIF") registered with the Registrar of Companies in Cyprus under number HE 251334,
and regulated by the Cyprus Securities and Exchange Commission ("CySEC") under license number
120/10 (hereinafter “XM”, the “Company”, “we”, “us” and “our“, as appropriate).
The Company is operating under the Cypriot Law L. 87(1)/2017 titled “Investment Services and Activities
and Regulated Markets Law of 2017” which transposed the European Directive 2014/65/EU of theEuropean Parliament and of the Council of 15 May 2014 on markets in financial instruments and amending
Directive 2002/92/EC and Directive 2011/61/EU, as the same may be in force from time to time and modified
or amended from time to time (hereinafter “MiFID II”). This Notice, or more specifically this Risk Disclosure,is provided to you in accordance with the requirements of the above legislation because you consider theuse or you already use the services of the Company to enter into transactions in financial instruments
provided by the Company (hereinafter “supported financial instruments”, “financial instruments” or“products”).
This Notice cannot and does not disclose or explain all of the risks and other significant aspects associatedwith our services and Company’s financial instruments. Its purpose is to explain, in general terms, thenature of the risks particular to entering into transactions (i.e. trade) in the Financial Instruments provided
by the Company and to help you to take investment decisions on an informed basis. For a detailed
explanation on how our services operate, you should read the following documents, which together withthis Notice, form our agreement with you:
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Terms and Conditions of Business/Client Agreement;
Order Execution Policy;
Summary of Conflicts of Interest Policy;
Client Categorisation Policy; andPrivacy Policy.

You should NOT commence trading with us until you have read and understood the documents referred toabove.
GENERAL CHARACTERISTICS OF COMPANY’S PRODUCTS
We offer trading services in Contracts For Differences (“CFDs”). CFDs fall under the asset class ofderivative financial instruments (hereinafter “derivatives”). A derivative is a financial instrument whose priceis dependent upon or derived from the price fluctuations of another underlying financial instrument.
What is a Contract for Difference?
A Contract for Difference (CFD) is an over-the-counter (“OTC”) derivative which enables investors to obtain
exposure and participate in the returns (which could end up being positive or negative) from pricemovements in an underlying financial instrument, without the need to physically acquire that underlying
financial instrument.
Who is your Counterparty?
Like all derivatives, a CFD is a contract under which two parties agree to exchange the difference in value
between the opening value and the closing value of the contract. For the purposes of Client orders in
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financial instruments provided by the Company, the Company is always the counterparty (or ‘principal’) to
all of your trades. Therefore, the Company is the sole execution venue for the execution of the Client’s
orders. Should you decide to open a position in a financial instrument with the Company, then that open
position may only be closed with the Company.
How is your profit or loss on a CFD trade calculated?
CFDs allow you to make a profit or loss from the price fluctuations in the underlying financial instrument
and the amount of any profit or loss on a CFD trade will be the total of the difference between the opening
value of the CFD (Quantity x our price) and the closing value of the CFD (Quantity x our price) less any
commissions and/or any other fees you incur and are required to pay to us in respect of the CFD.
Our trading service carries a high level of risk and is not suitable for everyone. You should not trade with
us unless you understand the nature of the transaction you are entering into and the extent of yourpotential loss from a trade. You trade entirely at your own risk.
Our trading service is ‘execution-only’. This means that we carry out your trading instructions. We do
NOT provide you with any investment advice.
FUNCTIONING AND PERFORMANCE OF COMPANY’S PRODUCTS IN DIFFERENT MARKETCONDITIONS
CFD products entail the use of “gearing” or “leverage” and are considered speculative products and, assuch, carry significantly greater risks than non-leveraged products. Leverage enables you to obtain a large
exposure to a financial instrument while only tying up a relatively small amount of your capital. However,your profit or loss is based on the full position (exposure) and, as such, the amount you gain or lose mightseem very high in relation to the sum you have invested.
The performance of such products depends on different market conditions which can have positive or
negative effects on the performance of a product. Past performance is not an indication of future
performance. The value of investments can go down as well as up. Therefore, when trading in CFDs, themarket can move in your favour for a profit or against you for a loss.
For a better understanding as to how the market can have a positive or negative impact on your trades, anumber of examples is included in the Appendix of this document.
Trading in CFDs is not suitable for all investors. Thus, you should not invest in CFDs unless you
adequately understand the characteristics, and in particular the associated risks, of these products andyou are comfortable with these risks when trading on such products. You should seek independent
professional advice, if necessary, in order to ensure that investing in these products is suitable for yourobjectives, needs and financial circumstances and resources.
RISKS ASSOCIATED WITH TRADING IN COMPANY’S PRODUCTS
In considering whether to engage in trading in CFDs, you should be aware of the following:
A. General Risks associated with the Financial Instruments offered by the Company
1. The Company does not and cannot guarantee the initial capital of the Clients’ portfolio or its value at
any time or any money invested in any financial instrument.
2. Transactions undertaken through the dealing services of the Company may be of a speculative nature.
Large losses may occur in a short period of time, equaling the total of funds deposited with theCompany.

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3. You may be required to deposit additional funds into your account at short notice in order to support
your open trades. A failure to deposit additional funds when required to do so may result in your open
trades being closed out (‘stopped out’) at a loss and your pending orders cancelled by us without notice
to you.
4. Under certain market conditions, it may be difficult or impossible to execute your order.
5. You must understand that the price of the financial instruments being traded is determined byfluctuations in markets outside our control. In setting our prices, spreads and the sizes in which wedeal, we take into account the market or markets for the relevant underlying instruments.
6. We do not guarantee that an order you place to limit the loss on a trade (‘stop loss’) will be filled at theprice that you specify. In a fast-moving market, your order may be liable to ‘gap through’, with the resultthat your trade is closed at an increased loss as compared with the level of the order that you placed.
In the event that a ‘gap through’ occurs there can be a markedly different price in the financial instrument
being traded with no opportunity to close your trade in-between. Therefore, an order you place to limit
the loss on a trade should not be treated as a guarantee to limit your loss on that trade to a specificamount.
7. The Client’s attention is expressly drawn to CFDs on currencies traded irregularly or infrequently that it
cannot be certain that a price will be quoted at all times or that it may be difficult to effect transactions
at a price which may be quoted owing to the absence of a counterparty.
8. Some financial instruments are quoted and settled in currencies other than the base currency of youraccount. Trading in these instruments carries additional risk as the currency exchange rate at the time
you close a trade and when your balance is converted to your base currency at the close of businesson the same day may have fluctuated against you. Therefore, if you trade in an instrument that is notquoted in the base currency of your account, currency exchange fluctuations will have an impact upon
your profits and losses.
9. Any funds you deposit with us or is credited to your Account will be held in one or more segregatedclient bank accounts. The client bank accounts will be pooled accounts holding funds of other clientsof ours and will not hold any of our own money. You shall have an ownership interest in your share of
the balance in the relevant client bank account. However, in the event that a bank at which the clientbank account is held has become insolvent or has otherwise failed and is unable to return the fullamount of funds held in the client bank account, you may not receive all the funds to which you havean ownership interest.
10. In the event of insolvency of the Company, your positions may be closed out against your wishes.
11. Changes in, or the introduction of new, rules, regulations and laws or the way in which they are applied
or interpreted may impact your trading with us. You may be exposed to the risks arising under therules, laws and regulations of jurisdictions other than the jurisdiction in which you are located and/orwith which you are familiar.
12. Trading online, no matter how convenient or efficient, does not necessarily reduce risks associated withtrading. In addition, by trading online, you face risks of slow or no internet connectivity and hardware
or software failures.
13. It is your responsibility to monitor your account at all times. It is important that you monitor yourpositions closely due to the speed at which profits or losses can be incurred. If you have open trades
you should always be in a position to access and manage your account. You may do this on-line, 24
hours a day, 7 days a week.
B. Specific Risks associated with transactions in Financial Instruments of the Company
You should unreservedly acknowledge and accept that, regardless of any information which may be offeredby the Company, the value of the Supported Financial Instruments may fluctuate downwards or upwards
and it is even probable that the investment may become of no value.
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Address: 12, Richard & Verengaria Street, Araouzos Castle Court, 3042, P.O.Box 50626, 3608 Limassol, Cyprus

You should also unreservedly acknowledge and accept that you run a great risk of incurring losses anddamages, up to all your invested capital, as a result of the dealing in Financial Instruments and accepts anddeclares that you are willing to undertake this risk.
The main specific risks associated with transactions in Financial Instruments of the Company are thefollowing:
1.

Leverage

As CFD products entail the use of leverage, you may deposit a relatively small proportion of the overall
contract value to open a trade. This can work for and against you as a relatively small movement in theprice of the underlying financial instrument being traded can have a disproportionate effect on your trade.
This may result in you achieving a good profit if the price of the underlying financial instrument moves inyour favour, but, equally, may result in you incurring significant losses as an equally small adverse market
movement may quickly result in the loss of your entire invested capital. Your losses will never exceed thebalance of your account as the Company offers a “negative balance protection”.
The Company offers to its Retail Clients fixed leverage ratios which vary from 2:1 to 30:1 according to thevolatility of the underlying financial instrument, as follows:
CFDs on the following financial instruments

New margin rates (leverage levels)from 1st August 2018

Major FX – Currency pairs composed of any two (2) of thefollowing: USD, EUR, JPY, GBP, CAD and CHF

3.33% (30:1 leverage)

Other FX – All other currency pairs

5% (20:1 leverage)Gold

5% (20:1 leverage)

Major indices – FRA40, GER30, JP225, UK100, US100, US30,
US500, AUS200Cash, FRA40Cash, GER30Cash, JP225Cash,
UK100Cash, UK100Cash, US100Cash, US30Cash and
US500Cash
Minor and Thematic indices – All other indices (HK50Cash,
IT40Cash, NETH25Cash, SPAIN35Cash, SWI20Cash, SWI20,
USDX, SA40Cash, ChinaHCash, Sing30Cash, CA60Cash,
US2000Cash, China50Cash, ElectricVehicles, FAANGs_10,
Blockchaim&NFT, ChinaInternet and AI_INDX)

5% (20:1 leverage)

10% (10:1 leverage)

Commodities (other than gold)

10% (10:1 leverage)

Shares and other reference values

20% (5:1 leverage)

Crypto_10 Thematic Index

50% (2:1 leverage)

For example, if a retail investor wants to open a position on EUR/USD worth of USD 30,000 and for which
the fixed leverage ratio offered is 30:1, then the investor would only need to use USD 1,000 (i.e. USD
30,000 / 30) of his/her funds to do so.
2. Volatility of price and limitation on the available market
The products provided by the Company are derivative financial instruments, where their price is derived
from the price of the underlying financial instruments in which the financial instruments refer to. Derivative
financial instruments or markets can be highly volatile. The prices of derivative financial instruments andthe underlying instruments may fluctuate rapidly and over wide ranges and may reflect unforeseeable
events or changes in market conditions, none of which can be controlled by the Client or the Company.
Under certain market conditions, it can be impossible to execute any type of Clients order at the declared
price. Therefore, even an open trade with a ‘stop loss’ order cannot always guarantee the limit of loss.
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Address: 12, Richard & Verengaria Street, Araouzos Castle Court, 3042, P.O.Box 50626, 3608 Limassol, Cyprus

The prices of derivative financial instruments are influenced by, amongst others, changing supply anddemand relationships, governmental, agricultural, commercial and trade programs and policies, national
and international political and economic events and/or the behavioural characteristics in a capital market.
Transactions in the products provided by the Company are not undertaken on a Trading Venue (RegulatedMarket, Multilateral Trading Facility or Organised Trading Facility), rather they are executed by theCompany, through its Electronic Trading Platform and/or Mobile Application, which is not a Trading Venue,
and as such you may be exposed to greater risks than those of a Trading Venue. The terms and conditions
and trading rules are established solely by the Company. You must close an open position of any given
financial instrument during the opening hours of the Company’s Trading Platform.
3. Impediments on closing an open trade
There may be circumstances where market conditions may significantly change in a very short period oftime, so that if you wish to sell an instrument or close a position, you may not be able to do so under thesame terms as when you purchased or opened it. This is the case when there is low liquidity in a financial
instrument and/or where you have a large position and, therefore, it is not possible to close your open
trades immediately. During that time, the value of your open trades could fall, possibly by a significant sum,and you will be liable for the full amount of the losses that arise.
4. Margin requirements
You are required to deposit a margin with the Company in order to open a trade. The margin requirement
will depend on the underlying instrument of the derivative Financial Instrument, the level of your leverageand the value of position to be established. When the margin level required to maintain the open position(s)in your trading account falls below the minimum margin requirement, as specified by the Company, wemay, but shall have no obligation whatsoever, issue a ‘margin call’ and in this case you will have to either
increase the ‘equity’ in your trading account by depositing additional funds and/or close your positions. If
you do not perform any of the aforementioned and the trading account reaches or falls below the ‘stop out
level’, as this is specified by the Company, the automatic ‘stop out mechanism’ will be initiated and will startclosing the open positions at the current market prices, in descending order on the basis of level of loss ofeach trade. The Company guarantees that there will be no negative balance in your account when tradingin financial instruments provided by the Company due to the negative balance protection offered by theCompany.
In order to protect our Clients and the Company, XM may have to take measures including increasing theminimum margin requirements for all positions. When taking such actions, the Company endeavours to
inform clients ahead of time, however under abnormal market conditions the Company may have toimplement these actions at short or without notice.
Having said the above it is of crucial importance that clients always monitor their positions with theCompany. Clients should ensure that their trading accounts are sufficiently funded to avoid any
disturbances from possible margin calls and /or stop-outs in their trading activity.
5. Additional obligations
Before you commence trading with us, you should ensure that you are aware of our charging system. If
any charges are not expressed in money terms, but for example as a spread, you may request and obtaina clear written explanation, including appropriate examples, to establish what such charges are likely tomean in specific money terms.
The value of open positions in certain financial instruments provided by the Company is subject to ‘financing
fees’ (for example ‘swap rates’). The price of long positions in financial instruments is reduced by a daily
financing fee throughout their life. Conversely, the price of short positions in financial instruments isincreased by a daily financing fee throughout their life. Financing fees are based on prevailing market
interest rates, which may vary over time.

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Address: 12, Richard & Verengaria Street, Araouzos Castle Court, 3042, P.O.Box 50626, 3608 Limassol, Cyprus

Details of our charging system (such as spreads, commissions and financing fees) may be found on the
Company’s website under the link: https://www.xm.com/spreads.
You should be aware that your trades in financial instruments may be or become subject to tax and/or any
other duty, for example, because of changes in legislation or in your personal circumstances. The Company
does not warrant that no tax and/or any other stamp duty will be payable. You are responsible for any taxes
and/or any other duties which may accrue in respect of your trades.
6. Corporate Events and Actions
In the case where an instrument becomes subject to corporate event, as set out in the relevant sections
within the Company’s Terms and Conditions, the Company will carry out the appropriate actions to adjustclients’ trading account for the effect of the event on their position, preserving the economic equivalent of
the rights and obligations attached to the clients’ Transaction and/or Contract with the Company, on the exdate of the event.
Further to the above, it is noted that the Company endeavors to communicate upcoming events and actions
through its official website. In this respect, clients shall always monitor the Company’s website in order tobe duly informed of any possible upcoming corporate events.

ONGOING REVIEW AND AMENDMENT OF RISK DISCLOSURE
The Company reserves the right to review and/or amend its Risk Disclosure, at its sole discretion, whenever
it deems fit or appropriate.
OTHER INFORMATION
1. The Risk Disclosure is not part of our Client Agreement/Terms and Conditions of Business and are notintended to be contractually binding or impose or seek to impose any obligations on us which we would
not otherwise have, but for the Cyprus Investment Services and Activities and Regulated Markets Lawof 2017 (Law 87(I)/2017).
2. We are members of the Investor Compensation Fund (“ICF”). You may be entitled to compensationfrom the ICF if we cannot meet our obligations. The maximum amount of compensation paid to a client,
who will be deemed as eligible for compensation is EUR 20.000 or 90% of the covered investor’s claim,
whichever is lower. The said coverage applies to the total amount of claims by a client against an ICF
member, irrespective of the number of accounts, the currency and the place of provision of the service.
Further information about compensation arrangements is available at the website of the Cyprus
Securities and Exchange Commission: https://www.cysec.gov.cy/en-GB/complaints/tae/
3. If there is anything in the Risk Disclosure you do not understand, please contact our ComplianceDepartment: compliance@xm.com.
EFFECTIVE DATEThe effective date is 3 January 2018.

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Address: 12, Richard & Verengaria Street, Araouzos Castle Court, 3042, P.O.Box 50626, 3608 Limassol, Cyprus

APPENDIX
EXAMPLES
The below examples illustrate how the market can move in your favor or against a Client when trading in
CFDs. Please note that the examples provided herein below are only provided for illustrative purposes anddo not necessarily reflect current or future market or product movements, the values that the Company will
apply to a trade, nor how such trades impact your personal circumstances. Also, the figures used in theexamples do not necessarily reflect your personal circumstances and do not restrict in any manner the way
in which the Company may exercise its powers or discretions. These examples do not constitute generalor personal advice to any person reading this document:
1. CFD on a Currency Pair (Forex)
Example 1 – Buy Order (profitable trade)
Currency Pair: EUR/USD
Base currency: USD
Contract size: 1 Standard Lot (100,000 units)
Current Bid/Ask price: 1.28380/1.28390
Selected Leverage: 30:1 (or 3.33% margin)
Commission/Fees: No
You believe that signals in the market are indicating that the EUR will go up against the USD (“$”). You
decide to enter into a CFD on EUR/USD and place a ‘buy order’.
Therefore, you open one standard lot (100,000 units of EUR/USD), buying the EUR at the offered leverageof 30:1 (or 3.33% margin) and wait for the exchange rate of EUR/USD to climb. When you buy one lot(100,000 units) of EUR/USD at a price of 1.28390, you are effectively buying 100,000 EUR, which is worth$128,390 (100,000 units of EUR x 1.28390). As the margin requirement is 3.33%, then approximately
US$4,275 (US$128,390 x 3.33%) would be set aside in your account to open up the trade. You now‘control’ 100,000 EUR with just US$4,275.
Your predictions come true and you decide to close your trade. The Euro strengthens to 1.28420/1.28430.
Now, to realise the profits, you close your order, i.e sell one lot (100,000 units) of EUR/USD at the current
rate of 1.28420 and you receive $128,420 for that trade (100,000 units x 1.28420).
Result of your closed trade
You bought one lot (100,000 units) of EUR/USD at a price of 1.28390, paying $128,390. Then, you soldone lot (100,000 units) of EUR/USD at a price of 1.28420, receiving $128,420. That is a positive differenceof $30 ($128,420 – $128,390 = +$30).
Total profit = $30 on a deposit of US$4,275.
Example 2 – Buy Order (loss-making trade)
Currency Pair: EUR/USD
Base currency: USD
Contract size: 1 Standard Lot (100,000 units)
Current Bid/Ask price: 1.28380/1.28390
Selected Leverage: 30:1 (or 3.33% margin)
Commission/Fees: No
You believe that signals in the market are indicating that the EUR will go up against the USD (“$”). You
decide to enter into a CFD on EUR/USD and place a ‘buy order’.
Therefore, you open one standard lot (100,000 units EUR/USD), buying EUR at 3.33% margin and wait for
the exchange rate of EUR/USD to climb. When you buy one lot (100,000 units) of EUR/USD at a price of
1.28390, you are effectively buying 100,000 EUR, which is worth $128.,390 (100,000 units of EUR x

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Address: 12, Richard & Verengaria Street, Araouzos Castle Court, 3042, P.O.Box 50626, 3608 Limassol, Cyprus

1.28390). If the margin requirement was 3.33%, then approximately US$4,275 would be set aside in youraccount to open up the trade (US$128,390 x 3.33%). You now ‘control’ 100,000 EUR with just US$4,275.
Your predictions do not come true and the Euro weakens to 1.28360/1.28370. Now, you decide to close
your order to avoid further losses, you close your trade, i.e. sell one lot (100,000 units) of EUR/USD at thecurrent rate of 1.28360, and you receive $128,360 for that trade (100,000 units x 1.28360).
Result of your closed trade
You bought one lot (100,000 units) of EUR/USD at a price of 1.28390, paying $128,390. Then, you soldone lot (100,000 units) of EUR/USD at a price of 1.28360, receiving $128,360. That is a negative differenceof $30 ($128,360 – $128,390 = -$30).
Total loss = -$30 on a deposit of US$4,275.
2. CFD on Gold
Example 1 – Sell Order (profitable trade)
Precious Metal: Gold
Base currency: USD
Contract size: 1 Standard Lot (100 ounces of Gold)
Current Bid/Ask price: 1248.20/1248.60
Selected Leverage: 20:1 (margin of 5%)
Commission/Fees: No
Imagine the current Bid/Ask price for Gold is: 1248.20/1248.60, meaning that you can enter into a Gold
CFD to buy (‘go long’) at 1248.60 or sell (‘go short’) at 1248.20. Suppose that you believe that the value ofGold will fall and, as such, you decide to enter into a CFD on Gold and place a ‘sell order’, i.e. to sell (‘goshort’) Gold.
Therefore, with a 5% margin, the amount of US$6,241 (100 ounces x 1248.20 x 5%) would be set aside inyour account for selling (going short) 100 ounces (one lot) of Gold. As you expected, the value of Golddrops to 1245.80/1246.20. Now, to realize the profits, you close the order and buy 100 ounces (one lot) of
Gold at the current price of 1246.20.
Result of your closed trade
You went short one lot (100 ounces) of Gold at 1248.20 for $124,820. Then, you closed your trade, i.e.
bought one lot (100 ounces) of Gold at 1246.20 for $124,620. That is a positive difference of $200 ($124,820- $124,620 = $200).
Total profit = $200 on a deposit of US$6,241.
Example 2 – Sell Order (loss-making trade)
Precious Metal: Gold
Base currency: USD
Contract size: 100 ounces
Current Bid/Ask price: 1248.20/1248.60
Selected Leverage: 20:1 (margin of 5%)
Commission/Fees: No
Imagine the current Bid/Ask price for Gold is: 1248.20/1248.60, meaning that you can can enter into a Gold
CFD to buy (‘go long’) at 1248.60 or sell (‘go short’) at 1248.20. Suppose that you believe that the value ofGold will fall and, as such, you decide to enter into a CFD on Gold and place a ‘sell order’, i.e. to to sell (‘goshort’) Gold.
Therefore, with a 5% margin, the amount of US$6,241 (100 ounces x 1248.20 x 5%) would be set aside inyour account for selling (going short) 100 ounces (one lot) of Gold. Your predictions do not come true andTel: +357 25 02 99 00 | Fax: +357 25 82 03 44 | Email: info@xm.com | Web: www.xm.com
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the value of Gold rises to 1249.80/1250.20. Now, to minimise your losses, you close the order and buy 100
ounces (one lot) of Gold at the current price of 1250.20.
Result of your closed trade
You went short one lot (100 ounces) of Gold at 1248.20 for $124,820. Then, you closed your trade, i.e.
bought one lot (100 ounces) of Gold at 1250.20 for $125,020. That is a negative difference of $200($124,820 - $125,020 = -$200).
Total loss = -$200 on a deposit of US$6,241.
Risk Warning:

CFDs are complex instruments and come with a high risk of losing money rapidly due to leverage.
Click here for the percentage (%) of retail investor accounts lose money when trading CFDs
with this provider.
You should consider whether you can afford to take the high risk of losing your money.

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Address: 12, Richard & Verengaria Street, Araouzos Castle Court, 3042, P.O.Box 50626, 3608 Limassol, Cyprus