Customer Agreement
- Introduction
1.1 Universal Trade Group (hereinafter referred to as the “Company”), which is registered at Richmond Hill Road, Kingstown, VC0100, St. Vincent and the Grenadines, provides access to this website and other ancillary services (hereinafter referred to as the “Services”) on the terms of this public offer (hereinafter referred to as the “Agreement”) to any natural or legal person (except for stateless persons; persons under 18 years of age; and citizens and legal entities of countries where the Company does not provide these services) (hereinafter referred to as the “Client”). Translated with DeepL.com (free version)
1.2 The following governing documents shall form an integral part of this Agreement:
a) Risk Declaration (Notification);
b) Regulations on non-trading operations;
c) Privacy Policy;
d) Refund Policy;
e) AML and KYC Policy;
f) All other applicable documents posted on the Company's Website and related materials.
1.3 This Agreement and all of the governing documents listed above shall hereinafter be collectively referred to as the “Terms of Business”.
1.4 The Terms of Business should be read carefully by the Client, as they define all the terms and conditions under which the Client makes trading and non-trading transactions. By using this Website By accepting the terms and conditions of this Agreement, the Client accepts the Terms of Business listed above.
1.5 Unconditional acceptance (acceptance) of the terms of this Agreement and all its integral parts is the advance payment made by the Client in accordance with this Agreement.
1.6 From the moment the Client makes an advance payment, each transaction made by the Client in Client Account or on the relevant trading platform(s) becomes subject to the Terms of Business.
1.7 The Client and the Securities Broker act as principals in respect of any transaction in Client Account or on the relevant trading platform, and the Securities Broker does not act as an agent on behalf of the Client. This means that the Client is fully and directly responsible for the fulfillment of any of his obligations in respect of any transactions made in Client Account or on the relevant trading platform. If the Client acts on someone else's behalf, whether that person is identified or not, the Company does not accept them as a Client and shall not be liable to them, unless specifically agreed and agreed.
1.8 Terms and Definitions.
The following terms and definitions are used in this Agreement and the other Regulatory Documents:
1.8.1. “Payment” - the making of funds by means of payment by the Client to the Company in payment of future expenses.
1.8.2. “Base Currency” - the first currency in the designation of the currency pair, which the Client can buy or sell for the quote currency.
1.8.3. “Balance” - the aggregate financial result of all full completed transactions and operations of deposit/withdrawal of funds from the trading account.
1.8.4. “Bank Card” means a plastic identification means, by means of which the holder of the bank card is provided with an opportunity to carry out payment transactions for goods, services, as well as to receive cash.
1.8.5. “Currency Pair” - an object of a trade operation based on the change in the value of one currency against another currency.
1.8.6 “Website” means the Company's website located at https://universal-trd.group or any other website that the Company recognizes as official and may maintain from time to time for access by Customers.
1.8.7. “Client's External Account” - the Client's bank and/or digital account.
1.8.8. “Long position” - purchase of an instrument with the expectation of a rate increase. For currency pairs - purchase of the base currency for the quote currency.
1.8.9. “Identification Data” - for individuals: passport data specified in the Customer Registration Questionnaire; for legal entities: data of registration and foundation documents.
1.8.10. “Instrument” means a currency pair, cryptocurrency pair, spot metals, CFDs and other financial.
1.8.11. “Client Account” - any account opened by the Client with the Company.
1.8.12. “Short position” - sale of an instrument with the expectation of the rate decrease. Applied to currency pairs: sale of the base currency for the quote currency.
1.8.13. “Rate” - the value of the base currency unit expressed in the quote currency.
1.8.14. “Personal Cabinet” - the Client's cabinet on the Website provided by the Company to the Client on the basis of the Client Agreement concluded between the Client and the Company, which is the Client's individual space on the Website, access to which is protected and is opened after entering a unique login and password.
1.8.15. “Margin trading” - trading operations with the use of leverage, when the Client has the opportunity to make transactions for amounts significantly exceeding the amount of funds on the trading account.
1.8.16. “Inactive Trading Account” - a trading account of the Client on which no positions have been opened, no pending orders have been placed and no non-trading operations have been performed for 3 (three) consecutive calendar months.
1.8.17. “Client's Transactions” - Client's orders and requests to the Company regarding his trading and non-trading operations in Personal Account and trading platforms.
1.8.18. “Open Position” - the result of the first part of a fully completed transaction. As a result of opening a position, the Client's obligations arise:
a) Produce an opposite transaction of the same volume;
b) maintain funds not lower than the required margin level (the level may vary depending on the type of account, up-to-date information can be found on the Company's Website)
1.18.19. ‘Written Notice’ - an electronic document (including e-mail, internal mail of the Client Terminal, etc.), an announcement in the section ‘Company News’ on the Website. A written notice shall be deemed to have been received by the Client:
- a) one hour after sending it to the Client's e-mail address; b) one hour after posting the advertisement on the Website.
1.18.20. ‘Instruction’ - an instruction of the Company's Client to open/close a position, place, delete or change the level of a pending order.
1.18.21. ‘Withdrawal Order’ - an order submitted through the Client's Personal Cabinet from the Company's Website, the purpose of which is to debit funds from the Client's account and withdraw them to the Client's external account.
1.8.22. ‘Server’ - all programmes and technical means, which are used for processing Clients‘ instructions, execution of Clients’ orders and for providing trading information in real time (the content of the information is determined by the Company), taking into account mutual obligations between the Client and the Company according to the relevant Regulations.
1.8.23. ‘Spread’ - the difference between Ask and Bid quotes expressed in points.
1.8.24. ‘Trading Platform’ - all programmes and technical means that provide real-time quotes, allow placing/modifying/executing orders and calculating all mutual obligations between the Client and the Company. In simplified form, for the purposes of these Regulations, the trading platform consists of a server and a client terminal.
1.8.25. ‘Client's Authorised Person’:
a) a natural person over 18 years of age, who is a citizen and/or tax resident of any country, except for countries where the Company does not provide the specified service, authorised on behalf of the Client to make or receive a non-cash (bank and/or digital) transfer in order to credit a payment to the Client's account or debit funds from the Client's account;
b) a legal entity or a person of other legal form, established under the laws of any country, except for countries where the Company does not provide the specified service, authorised on behalf of the Client to make or receive a non-cash (bank and/or digital) transfer in order to credit a payment to the Client's account.
1.8.26. ‘Emergency situation’ - non-compliance of the Company's conditions with the conditions of the counterparty, current market situation, capabilities of the Company's software or hardware, other situations that cannot be foreseen.
- Services
2.1 If the Client fulfils all obligations under this Agreement and other Company's Regulations, the Company will provide the Client with the opportunity to perform transactions provided for by the features of the Personal Account and the Terms of Business.
2.2 The Securities Broker executes only the execution The Securities Broker provides the Client with a technological platform and in relation to the Client's transactions the Securities Broker executes only the execution, without providing fiduciary management or any recommendations. The Securities Broker may execute the Client's order or request even though such operation may be disadvantageous for the Client. The Company is not obliged, except as set out in this Agreement and the Terms of Business, to monitor and notify the Client of the status of his trading operation; to send requests for additional margin; or to forcibly close any open position of the Client. Unless otherwise specifically agreed, the Company shall not be obliged to attempt to execute the Client's order at quotes more favourable than those offered to the Client through the trading platform.
2.3 The Client is not entitled to request investment / trading recommendations from the Securities Broker, as well as other information that can motivate the Client to perform trading operations.
2.4 The Client acknowledges that the Company at its sole discretion may provide information, recommendations and advice to the Client, but in this case it will not take any responsibility for the consequences and profitability of such recommendations and advice for the Client.
The Client acknowledges that in the absence of fraud, wilful default or gross negligence, the Company shall not be liable for any losses, costs, expenses and damages of the Client resulting from inaccurate information provided to the Client, including but not limited to the Client's trading information. While the Company reserves the right to cancel or close out any position of the Client under certain conditions described in this Agreement or the Terms of Business, all transactions made by the Client as a result of such inaccurate information or error shall nevertheless remain valid and binding on both the Client and the Company.
2.5 The Company shall not make or perform physical delivery of currency upon execution of any trading operation. Profits or losses on trading operations are accrued/written off from the balance of the Client's trading account immediately after the position is closed.
2.6 The Company, its partners or any of its affiliates may have a material benefit, legal relationship or arrangement in relation to any transaction in Personal Cabinet or on the trading platform;
a material benefit, legal relationship or arrangement that conflicts with the interests of the Client. As an example, the Company may:
a) act as principal in respect of any instrument and on its own account by selling or buying the instrument from the Client;
b) offer another Client of the Company as a counterparty to the trade operation;
c) to buy or sell an instrument that the Company offers to the Client;
d) advise and provide other services to its partners or other Clients of the Company on instruments or underlying assets in which they are interested despite the fact that this conflicts with the Client's interests.
The Client agrees and authorizes the Company to act with respect to and for the Client as the Company deems appropriate, regardless of any possible conflict of interest or the existence of any material interest in relation to any transaction in Personal Account or on the trading platform, without prior notice to the Client. The existence of a conflict of interest or material benefit in relation to any operation in Personal Account or in the trading platform shall not affect the service of the Client by the Company's employees.
2.7 The Company may from time to time act on behalf of the Client with those with whom the Company or any of its affiliates has an agreement to obtain goods or services. The Company warrants that such agreements are entered into wherever possible in the best interests of the Client, e.g. such agreements allow access to information or some other service that would otherwise be unavailable.
2.8 The Company endeavours to provide advanced services to Clients, and the Client in turn undertakes that he/she will use the Services fairly and honestly. The Company maintains a policy of detecting and detecting fraud, or other manipulation, including but not limited to latent arbitrage, unfair scalping and other similar operations. The Company reserves the right to unilaterally suspend the Client's account and recalculate all open and closed positions to reflect market conditions. In this case, the Company reserves the right to deposit / withdraw funds from the Client's account.
- Client's requests and orders
3.1 The Securities Broker shall process the Client's requests and orders in accordance with the relevant Terms of Business.
3.2 The Securities Broker shall have the right to reject a Client's request or instruction if any requirement of the Terms of Business has not been fulfilled at the time the Securities Broker completes processing of such request or instruction. However, the Securities Broker may, at its discretion, accept and fulfil such a request or instruction from the Client notwithstanding non-compliance with the provisions of the Terms of Business.
If the Company has complied with the Client's request or instruction and later finds that any provision of the Terms of Business has been breached, the Company shall be entitled to act in accordance with the relevant document of the Terms of Business.
- Netting
4.1 When carrying out transactions between the Client and the Company, conversion shall be made at the current exchange rates established in accordance with the Terms of Business.
4.2 If the total amount of the Client's indebtedness to the Company under the Terms of Business is equal to the total amount of the Company's indebtedness to the Client, there shall be mutual repayment of these obligations.
4.3 If the accrued amount due to either party under the Terms of Business exceeds the accrued amount due to the other party, the party with the higher accrued amount shall pay the excess to the other party and thereupon all payment obligations will automatically be satisfied and carried out.
4.4 The Client shall be obliged to pay all amounts due, including commission and other costs established by the Securities Broker.
4.5 The Client may not assign his rights, assign his obligations or carry out any other act of transfer of rights or obligations under the Terms of Business without prior written notice to the Company. If this condition is breached, any such assignment, assignment or transfer will be void.
- Payments
5.1 The Customer may transfer funds to the Customer Account at any time.
5.2 Account crediting and debiting operations are regulated by the Terms of Business for non-trading operations.
5.3 If the Client has to pay to the Company an amount exceeding the funds of his account, such amount shall be paid by him within 2 (two) working days from the moment the Client has this obligation.
5.4 The Client agrees and acknowledges that (without prejudice to the Company's other rights to close the Client's open positions and to exercise other remedies for the Client's default under the Terms of Business) if the Client has a monetary obligation to the Company under this Agreement or the Terms of Business and sufficient funds have not been credited to the Client's accounts, the Company shall be entitled to deem the Client in default of payment and the Company shall be entitled to exercise its rights under this Agreement and/or the Terms of Business.
5.5 The Client is fully responsible for the accuracy of payments made. If the Company's bank details have changed, the Client is fully responsible for any payments made using outdated bank details from the moment the new information is published in Personal Account.
5.6 Acceptance of funds from the Company's clients by means of payment with cards of international payment systems on the Website may also be carried out by the Company's official partners, information about which can be found in the Terms of Business for non-trading operations and in Personal Account.
- Client's cash and interest.
6.1 Client's funds shall be kept in the Company's accounts, including segregated accounts opened in the name of the Company, for keeping the Client's funds separate from the Company's funds.
6.2 The Client acknowledges and agrees that the Securities Broker will not pay the Client interest on the funds placed on the Client's accounts. The Securities Broker is entitled to pay interest on the Client's funds in cases and amounts determined by the Securities Broker.
6.3 Use of bonus funds The Company may credit bonuses to the Client's trading account.
The amount of the bonus depends on the amount of the Client's deposit or on the terms of the Company's personal offer to the Client, within the framework of which the bonus funds are credited to the Client.
Bonus funds credited to the Client's trading account are not a financial obligation of the Company to the Client.
Funds on the Client's trading account become available for withdrawal only after the Client has made the mandatory trading turnover on his/her account.
The amount of the mandatory trading turnover is equal to the bonus amount multiplied by its leverage. The bonus leverage is equal to 35, and for bonuses, the amount of which is 50% or more of the total trading deposit of the Client, the leverage is equal to 40.
Bonus offers may be limited in duration.
Transactions with the result ‘without income’ (if the strike price of the asset is equal to the expiry price) are not counted when calculating the mandatory trading turnover that the Client has made.
Cancellation or cancellation of the bonus is possible only if there have been no trading operations on the account since the bonus funds were credited.
Upon expiry of the bonus offer, the bonus accrued under it may be written off from the Client's trading account.
The bonus is reset if the Client's trading account balance becomes lower than the minimum allowable transaction size.
- Complaints and disputes
7.1 All complaints and disputes shall be dealt with in accordance with the relevant Terms of Business.
- Communications
8.1 The rules of communication between the Client and the Company are defined in the Terms of Business.
8.2 The Client is obliged to give trading instructions only via the Client Terminal. For certain types of accounts, there may be a backup possibility to submit instructions and orders by telephone.
8.3 The Client is obliged to submit requests for crediting and debiting funds only via Personal Account in accordance with the Terms of Business for non-trading operations.
8.4 By accepting the terms of this Agreement, the Client also agrees to receive e-mails from the Company to his personal e-mail address and SMS messages, and the cell phone number registered in Personal Account.
- Significance of deadlines for fulfilment of obligations
9.1 The time periods for the Client and the Company to fulfil their obligations shall be a material term for all Terms of Business.
- Events of default
10.1 Each of the following events shall constitute an Event of Default:
a) Customer's failure to pay any obligation under the Terms of Business;
b) the Client's failure to fulfil any obligation towards the Company;
c) the initiation by a third party of legal proceedings in respect of the Client's bankruptcy or liquidation (if the Client is a legal entity); or the appointment of a bailiff or receiver in respect of the Client or the Client's assets (if the Client is a legal entity); or (if the Client is a legal entity or an individual) if the Client enters into a debt settlement agreement with its creditors; or any other similar or analogous proceedings to the foregoing initiated against the Client;
d) provision by the Client of guarantees or representations in accordance with clause 11 of this Agreement that are not true;
e) the Client's inability to pay its debt at maturity;
f) death of the Client or declaring the Client incapacitated;
j) any other circumstances where the Company reasonably believes that it is necessary or desirable to take action in accordance with Clause 10.2 of this Agreement.
10.2 In the event of default, the Company may, at its discretion, take the following actions at any time, without prior written notice to the Client:
a) close all or any of the Client's open positions at the current quote;
b) debit from the Client's accounts the amounts that the Client owes to the Securities Broker;
c) close any Client's account opened with the Company;
d) refuse to open new accounts for the Customer.
- Representations and warranties
11.1 The Client represents and warrants to the Company that:
a) All information provided under this Agreement, the Terms of Business and the information provided by the Client in the Registration Questionnaire in the Client's Personal Area is true, accurate and complete in all respects;
b) understands and accepts that he/she is treated as a Professional Client in accordance with the definitions of MIFID I and MIFID II. As a result, the Company will treat the Client as a Professional Member and the Client expressly waives any rights or defences arising from the relinquishment of retail status with the Company;
c) expressly recognizes that the Company is not regulated in any jurisdiction other than Cyprus. As a consequence, the Client acknowledges that the Company cannot offer him/her the same level of protection as other regulated entities;
d) is duly authorised to enter into this Agreement, issue instructions and requests and perform its obligations under the Terms of Business;
e) The client acts as a principal;
f) if the Client is a natural person, it is the Client who has filled in the Client Registration Form, and if the Client is a legal person, the person who filled in the Client Registration Form on behalf of the Client had all authorisations to do so;
j) all actions taken pursuant to the Terms of Business do not violate any statute, ordinance, law, statutory rules and regulations applicable to the Client or in the jurisdiction of which the Client is a resident, or any other agreement to the terms of which the Client is bound or which affects any assets of the Client;
g) all trading systems used by the Client are not aimed at exploiting possible vulnerability of the Company's software;
h) is NOT a resident of the USA, Canada Japan, Australia and New Zealand or any other country in which the Company does not provide services. and recognises that the Company does not act as a tax agent in any jurisdiction and therefore any income, gains or losses arising from the Client's trading activities are reported by the Client to the relevant tax authorities (if any) independently.
11.2 The Company has the right to recognise any Client's position as invalid or to close one or more of the Client's positions at the current price at any time, at its discretion, in case the Client violates clause 11.1 of this Agreement. 11.1 of this Agreement.
- Governing law and jurisdiction
12.1 This Agreement shall be governed by the laws of Cyprus.
12.2 The Customer shall unconditionally:
a) agrees that the courts of Cyprus shall have exclusive jurisdiction to determine any proceedings in respect of this Agreement
b) is subject to the jurisdiction of the courts of Cyprus;
c) waives any challenge to the proceedings in any such court;
d) agrees never to make any claim that such venue is inconvenient or unenforceable against Client.
12.3 The Client irrevocably and to the fullest extent permitted by the laws of Cyprus waives, both in respect of himself and in respect of his income and assets, irrespective of their use or intended use, immunity on the grounds of sovereignty or any other similar grounds from (a) suit, (b) jurisdiction of a court, (c) injunction, writ of execution in kind or recovery of property, (d) attachment of assets before or after judgment, and (e) execution or enforcement of a judgment.
The Client irrevocably and to the fullest extent permitted by Cyprus law agrees that it will not claim such immunity in any action. The Client consents to the satisfaction of court claims and orders, including, but not limited to, with respect to any assets of the Client.
12.4 In case of disagreement, the English version of this Agreement and the Terms of Business shall prevail over the versions of this Agreement and the Terms of Business in other languages.
12.5 The Securities Broker shall communicate with the Client in English, Russian or other languages by mutual agreement, however, agreements concluded between the Securities Broker and the Client in English shall prevail over agreements concluded in other languages.
- Limitation of liability
13.1 The Client undertakes to indemnify the Company against any liabilities, costs, claims, damages that may arise either directly or indirectly due to the Client's failure to fulfill its obligations under the Terms of Business.
13.2 The Company shall not be liable to the Client for any damages, losses, lost profits, missed opportunities (due to possible market movements), costs or damages under the terms of this Agreement, unless otherwise agreed with the relevant Terms of Business.
13.3. The Client may not transfer passwords from the trading platform and Personal Account to third parties, and undertakes to ensure their safety and confidentiality. All actions performed in relation to the fulfillment of the Terms of Business and/or with the use of login and password are considered to be performed by this Client. The Company is not responsible for unauthorized use of registration data by third parties.
13.4 The Client acknowledges and agrees that margin trading is highly speculative as set out in the Risk Disclosure (Notice) on the Company's Website. If the Client does not understand the Risk Disclosure; the Company recommends that the Client seek independent advice or contact his/her introducer. The Client acknowledges and agrees that margin trading may have significant risks, including, but not limited to, legal and financial risks to the extent of causing unlimited losses without any guarantee of preservation of capital invested or generating profits. The Client acknowledges and agrees that margin or non-traded products are suitable only for professional individuals who may incur financial losses by risking their initial deposits and who have the financial security to incur substantial losses without affecting their standard of living.
- Force majeure circumstances (force majeure)
14.1 The Company, having sufficient grounds for this, has the right to state the occurrence of force majeure (force majeure). The Company will duly take appropriate steps to inform the Client about the occurrence of force majeure. Force majeure circumstances include (but are limited to):
a) any act, event or occurrence (including, but not limited to: any strike, riot or civil commotion, acts of terrorism, war, natural disaster, accident, fire, flood, storm, power, communications, software and/or electronic equipment failure, civil unrest) which in the reasonable opinion of the Company has caused destabilization of the market or one or more instruments;
b) the suspension, liquidation or closure of any market; or the imposition of restrictions or special or non-standard trading conditions on any market; or in respect of any such event.
14.2 If the Company determines that a Force Majeure Event has occurred, the Company shall be entitled (without prejudice to the Company's other rights under the Terms of Business) without prior written notice and at any time to take any of the following steps:
(a) Increase margin requirements;
b) close any or all of the Client's open positions at such price as the Company reasonably considers fair;
c) suspend or modify the application of one or all provisions of the Terms of Business as long as the existence of a force majeure circumstance makes it impossible for the Company to comply with those provisions;
d) to take or, alternatively, not to take any action in relation to the Company, the Client and other clients if the Company reasonably considers it appropriate in the circumstances.
14.3 The Company shall not be liable for non-fulfillment (improper fulfillment) of obligations if the fulfillment was prevented by force majeure circumstances.
- Miscellaneous
15.1 In case the Company receives a revocation of payment for a transaction, the Company reserves the right to freeze the current balance of the Client for the amount of the revoked payment until the end of the proceedings on this matter.
15.2 In the absence of trading activity on the Client's account for more than 30 (thirty days), from the moment of closing the last active position, the Company has the right to charge a fee for the maintenance of such trading account in the amount of 50 dollars per month.
15.3 In case of absence of trading activity on the Client's account for more than 3 (three) months or absence of funds on the Client's account for more than 1 (one) month, the Company has the right to recognize such account as inactive, close it and transfer it to the archive.
15.4 The Securities Broker is entitled to suspend the Client's service at any time, having sufficient grounds for it (prior notification of the Client about it is not obligatory).
15.5 If situations arise that are not described in the Terms of Business, the Company will act in accordance with accepted market practice based on the principles of honesty and fairness.
15.6 The Company's exercise of any right, in whole or in part, or its non-exercise (whether under this Agreement or applicable law), shall not be a reason to deny the Company's further exercise of any such or other rights under the relevant Regulations or law.
15.7. The Securities Broker may decide to fully or partially release the Client from liability to the Securities Broker for the Client's breaches of the provisions of the Terms of Business during the period of its validity or make another compromise decision. In this case, all violations shall be taken into consideration, regardless of the age of their occurrence, and the Company shall be entitled to file claims against the Client at any time. The aforementioned circumstances shall not prevent the Company from exercising its other rights under the Terms of Business.
15.8 The rights of the Company under the Terms and Conditions of Business are in addition to the rights established by the Laws of Cyprus.
15.9 The Company has the right to transfer rights and obligations in whole or in part to a third party, subject to due notice to the Client and the successor's agreement to the terms of this Agreement and the applicable governing document.
15.10 If any provision of the Terms of Business (or any part of any provision) is held by a court of competent jurisdiction to be unenforceable, such provision will be treated as a separate part of the Agreement or the Terms of Business and the enforceability of the remainder of this Agreement will not be affected.
- Amendments and termination
16.1 The Client acknowledges that the Company has the right to make amendments and changes:
a) to the provisions of this Agreement or any Terms of Business at any time by notifying Customer of the change;
b) to the values of spreads, swaps and dividends specified in the contract specification without prior notice to the Client;
c) to other trading conditions with written notice to the Client at least 1 (one) calendar day in advance.
Amendments shall take effect from the date specified in the notice. In the event of force majeure events in the markets, the Client recognizes the right of the Company to amend and modify the Terms of Business immediately, without prior notice.
16.2 The Client agrees that no prior notice to the Client is required when the Company introduces new products and services.
16.3 The Client may suspend or terminate this Agreement upon written notice to the Company.
16.4 The Company may suspend or terminate this Agreement immediately by notifying the Client of its intention.
16.5 The Company reserves the right to refuse to provide the Client with the Personal Account service without giving any reasons.
16.6 Termination of the Agreement does not cancel the obligations on the part of the Company and on the part of the Client, which have already arisen under this Agreement or the relevant Regulatory document, including in relation to open positions or operations on withdrawal/receipt of funds to the Client's account.
16.7 Upon termination of this Agreement, Client's indebtedness to the Company shall be immediately due and payable, including but not limited to:
a) Arrears of any fees and commissions;
Customer's indebtedness to the Company shall be immediately due and payable, including but not limited to:
b) arrears of any payments and commissions;
c) any costs associated with the termination of this Agreement;
d) any other losses and expenses in connection with closing a position or in connection with any other obligations of the Company arising on the initiative or through the fault of the Client.