Risk Disclosure

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RISK

DISCLOSURE
RISK DISCLOSURE 2
AN All New Investments LTD

Introduction

A.N. All New Investments Ltd operating under the trading name LegacyFX.eu, is a Cypriot Investment Firm
("CIF") registered with the Registrar of Companies in Cyprus under number HE 348194, and regulated by the
Cyprus Securities and Exchange Commission ("CySEC") under license number 344/17 (hereinafter “LegacyFX”,
“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 the European
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 the use
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 the risks and other significant aspects associated with
our services and Company’s financial instruments. Its purpose is to explain, in general terms, the nature 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 with this Notice, form our
agreement with you:

▪ Terms and Conditions of Business/Client Agreement;


▪ Order Execution Policy;
▪ Summary of Conflicts of Interest Policy;
▪ Client Categorization Policy; and
▪ Privacy Policy

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678
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AN All New Investments LTD

You should NOT commence trading with us until you have read and understood the documents referred to
above.

General characteristics of company’s products

We offer trading services in Contracts for Differences (“CFDs”). CFDs fall under the asset class of derivative
financial instruments (hereinafter “derivatives”). A derivative is a financial instrument whose price is 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 price movements
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 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.

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678
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AN All New Investments LTD

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 and the extent of your potential 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 market conditions

CFD products entail the use of “gearing” or “leverage” and are considered speculative products and, as such,
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 might seem 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. Therefore, when trading in CFDs, the market can move in
your favor 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,
several examples are included in the Appendix of this document.

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678
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AN All New Investments LTD

Trading in CFDs is not suitable for all investors. Thus, you should not invest in CFDs unless
you adequately understand the characteristics, and the associated risks, of these products
and you 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 your objectives, needs and financial circumstances and resources.

Risk 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 the Company.

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 you.

4. Under certain market conditions, it may be difficult or impossible to execute your


order.

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678
RISK DISCLOSURE 6
AN All New Investments LTD

5. You must understand that the price of the financial instruments being traded is
determined by fluctuations in markets outside our control.

6. We do not guarantee that an order you place to limit the loss on a trade (‘stop loss’)
will be filled at the price that you specify. In a fast-moving market, your order may
be liable to ‘gap through’, with the result that your trade is closed at an increased
loss as compared with the level of the order that you placed. If 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 specific amount.

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 always be quoted 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 your account. 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 business on the same day may have
fluctuated against you. Therefore, if you trade in an instrument that is not quoted 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 segregated client bank accounts. The client bank accounts will be pooled
accounts holding funds of other clients of ours and will not hold any of our own
money. You shall have an ownership interest in your share of the balance in the

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AN All New Investments LTD

relevant client bank account. However, in the event that a bank at which the client
bank account is held has become insolvent or has otherwise failed and is unable to
return the full amount of funds held in the client bank account, you may not receive
all the funds to which you have an 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 the rules, laws and regulations of jurisdictions
other than the jurisdiction in which you are located and/or with which you are
familiar.

12. Trading online, no matter how convenient or efficient, does not necessarily reduce
risks associated with trading. In addition, by trading online, you face risks of slow or
no internet connectivity and hardware or software failures.

13. It is always your responsibility to monitor your account. It is important that you
monitor your positions closely due to the speed at which profits, or losses can be
incurred. If you have open trades, you should always be able to access and manage
your account. You may do this on-line, 24 hours a day, 7 days a week.

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RISK DISCLOSURE 8
AN All New Investments LTD

B. Specific Risks associated with transactions in Financial Instruments of the

Company

The Client should unreservedly acknowledge and accept that, regardless of any information which may
be offered by 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.

The Client should also unreservedly acknowledge and accept that he runs a great risk of incurring losses
and damages, up to all his/her invested capital, as a result of the dealing in Financial Instruments and
accepts and declares that he is willing to undertake this risk.

The main specific risks associated with transactions in Financial Instruments of the Company are the
following:

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 the price 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 in your favor, 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 the balance of your account as the
Company offers a “negative balance protection”.

For example, if an investor trades with leverage 1:100 and wants to open a position on EUR/USD
worth of USD 100,000, the investor would only need to use USD 1,000 (i.e. USD 100,000 / 100) of
his/her funds to do so.

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678
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AN All New Investments LTD

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 and the 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.

The prices of derivative financial instruments are influenced by, amongst others, changing supply
and demand relationships, governmental, agricultural, commercial and trade programs and policies,
national and international political and economic events and/or the behavioral characteristics in a
capital market.

Transactions in the products provided by the Company are not undertaken on a Trading Venue
(Regulated Market, Multilateral Trading Facility or Organized Trading Facility), rather they are
executed by the Company, through its Electronic Trading Platform, 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 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.

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678
RISK DISCLOSURE 10
AN All New Investments LTD

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 chosen leverage and 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, we may, 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 start closing the open
positions at the current market prices, in descending order on the basis of level of loss of each trade.
The Company guarantees that there will be no negative balance in your account when trading in
financial instruments provided by the Company due to the negative balance protection offered by
the Company.

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
obtain a clear written explanation, including appropriate examples, to establish what such charges
are likely to mean 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 is increased by a daily financing fee throughout their life. Financing fees are
based on prevailing market interest rates, which may vary over time.

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678
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AN All New Investments LTD

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.legacyfx.eu/trading-conditions

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.

C. Risks associated with CFDs on Cryptocurrencies

1. You should acknowledge and understand that Cryptocurrencies are a type of


decentralized digital currency or asset, which is not issued by any Central Bank or any
other issuer, in which encryption techniques are used to facilitate the generation of units
of the currency or asset and verify the transfer of units. Trading in Cryptocurrencies
and/or in CFDs on Cryptocurrencies is not appropriate for all investors and, thus, you
should not trade in such products unless you understand and accept the specific
characteristics and risks related to these products.

2. Trading in Cryptocurrencies and/or in CFDs on Cryptocurrencies falls outside the scope


of the regulated investment services and products offered by the Company, as such
products are not covered by the regulatory framework of MiFID II. Cryptocurrencies are
traded on nonregulated decentralized digital exchanges. You should acknowledge and
accept that, by trading in such products, a significantly higher risk of loss of the invested
capital may occur within a very short period as a result of sudden adverse price
movements of the cryptocurrencies. This is since the price formation and price
movements of the Cryptocurrencies depend solely on the internal rules of the digital
exchange, which may be subject to any point in time and without prior notice. This leads

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678
RISK DISCLOSURE 12
AN All New Investments LTD

to a very high intra-day volatility in the prices of the Cryptocurrencies, which may be
substantially higher relative to other financial instruments provided by the Company.

3. The market and pricing data on Cryptocurrencies are derived from the digital
decentralized exchanges that the Cryptocurrencies are traded on. Since the price-
formation rules on Cryptocurrencies provided by such exchanges are not subject to any
regulatory supervision, they may be subject to changes in the relevant digital
exchange’s discretion at any time. Likewise, such digital exchanges may introduce
trading suspensions or take other actions that may result in the suspension or cessation
of trading or the price and market data feed becoming unavailable to us. The above
factors could result in material adverse effect on your open positions, including the loss
of all your invested capital. Where a temporary or permanent disruption to or cessation
of trading occurs on any digital exchange from which we derive our price feeds for the
relevant Cryptocurrency, your positions in such Cryptocurrency will be priced at the last
available price for the relevant Cryptocurrency and you may be unable to close or
liquidate your position or withdraw any funds related to such position until the trading
on the relevant digital exchange resumes (if at all). You accept that where trading
resumes again at either the relevant initial digital exchange or on any successor
exchange thereof, there may be significant price differential ('price gapping’) which may
impact the value of your CFD positions in the relevant Cryptocurrencies and result in
significant profits or losses. Where trading does not resume, all your invested capital
could potentially be lost.

You hereby acknowledge and accept that you have been informed by the Company and
understand the associated risks when taking investment decisions in respect of trading in
CFDs on Cryptocurrencies.

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678
RISK DISCLOSURE 13
AN All New Investments LTD

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 not
intended 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 Law of 2017
(Law 87(I)/2017).

2. We are members of the Investor Compensation Fund (“ICF”). You may be entitled to compensation from 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. 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 Compliance
Department [email protected]

Effective date

The effective date is 3 January 2018.

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RISK DISCLOSURE 14
AN All New Investments LTD

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 and
do 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 the
examples 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 general or
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: 1:200 (or 0.5% 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 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 your selected
leverage of 1:200 (or 0.5% 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 0.5%, then

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RISK DISCLOSURE 15
AN All New Investments LTD

approximately US$642 (US$128,390 x 0.5%) would be set aside in your account to open the trade. You
now ‘control’ 100,000 EUR with just US$642.

Your predictions come true and you decide to close your trade. The Euro strengthens to 1.28420/1.28430.
Now, to realize 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 sold
one lot (100,000 units) of EUR/USD at a price of 1.28420, receiving $128,420. That is a positive difference
of $30 ($128,420 – $128,390 = +$30).

Total profit = $30 on a deposit of $642.

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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: 1:200 (or 0.5% 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 a CFD on EUR/USD and place a ‘buy order’.

Therefore, you open one standard lot (100,000 units EUR/USD), buying EUR at 0.5% 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). If the margin requirement was 0.5%, then approximately US$642 would be set aside in your
account to open the trade ($128,390 x 0.5%). You now control 100,000 EUR with just US$642.

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
the current 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 sold
one lot (100,000 units) of EUR/USD at a price of 1.28360, receiving $128,360. That is a negative difference
of $30 ($128,360 – $128,390 = -$30).

Total loss = -$30 on a deposit of $642.

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RISK DISCLOSURE 17
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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: 1:200 (margin of 0.5%)
▪ Commission/Fees: No

Imagine the current Bid/Ask price for Gold is: 1248.20/1248.60, meaning that you can enter a Gold CFD
to buy (‘go long’) at 1248.60 or sell (‘go short’) at 1248.20. Suppose that you believe that the value of
Gold will fall and, as such, you decide to enter a CFD on Gold and place a ‘sell order’, i.e. to sell (‘go
short’) Gold.

Therefore, with a 0.5% margin, the amount of US$624.10 (100 ounces x 1248.20 x 0.5%) would be set
aside in your account for selling (going short) 100 ounces (one lot) of Gold. As you expected, the value
of Gold drops 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 $624.10.

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RISK DISCLOSURE 18
AN All New Investments LTD

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: 1:200 (margin of 0.5%)
▪ Commission/Fees: No

Imagine the current Bid/Ask price for Gold is: 1248.20/1248.60, meaning that you can enter a Gold CFD
to buy (‘go long’) at 1248.60 or sell (‘go short’) at 1248.20. Suppose that you believe that the value of
Gold will fall and, as such, you decide to enter a CFD on Gold and place a ‘sell order’, i.e. to sell (‘go
short’) Gold.

Therefore, with a 0.5% margin, the amount of US$624.10 (100 ounces x 1248.20 x 0.5%) would be set
aside in your account for selling (going short) 100 ounces (one lot) of Gold.

Your predictions do not come true and the value of Gold rises to 1249.80/1250.20. Now, to minimize
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 $624.10.

Q Tower, 5th floor, Ioanni Kondylaki 47, 6042, Larnaca, Cyprus [email protected] tel: + 357-25- 030678

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