Legal
The full agreement governing your use of Ellington Ltd's website, platform, and services. Please read it carefully before you open an account or trade.
In brief
These Terms set out the rules for using our Services: how you become a client, how trading and your money are handled, the fees and risks involved, and the rights and responsibilities of both sides. They are written to be informative, not promotional. Because the products we offer are leveraged and high-risk, the risk warning below and the risk disclosure in Part F are the most important parts to read.
Part A · About this agreement
These Terms and Conditions (the "Terms") form a binding agreement between you ("you", "the Client") and Ellington Ltd ("Ellington Ltd", "we", "us", or "our"), and govern your access to and use of our website at ellingtonltd.com, our trading platform, and any related services (together, the "Services").
By registering for an account, or by accessing or using the Services, you confirm that you have read, understood, and agree to be bound by these Terms, together with our Privacy Policy, Risk Warning, order execution terms set out in Section 15, conflicts of interest disclosure set out in Section 13, and any other policies we make available, each of which forms part of this agreement. If you do not agree with these Terms, please do not use the Services.
These Terms are provided in English. Where we provide a translation, the English version prevails in the event of any inconsistency, except where local law requires otherwise.
In these Terms, the following words have the following meanings:
Headings are for convenience only. References to legislation include any amendment or replacement of it. "Including" means "including without limitation".
The provider of the Services is Ellington Ltd, a registered International Business Company (IBC) with the St. Vincent and the Grenadines Financial Services Authority (SVGFSA) under IBC registration number 12785, and a registered Virtual Asset Service Provider (VASP) under the Virtual Assets Business Act 2022 (VABA), registration number VABA-2026-0042, with a correspondence address at 275 Slater St. #900, Ottawa, ON K1P 5H9, Canada.
You should understand the nature and limits of our registrations. Our registration as an International Business Company is a corporate registration and does not, by itself, constitute a licence to provide regulated investment, securities, forex, CFD, or brokerage services. Our VASP registration under the Virtual Assets Business Act applies only to virtual-asset business activities that fall within the scope of that law, such as the exchange, transfer, custody, or administration of virtual assets, where applicable. It should not be understood as approval or supervision of all products available on the platform.
Forex, CFDs, and other leveraged trading services are not licensed as Forex/Broker services by the St. Vincent and the Grenadines Financial Services Authority. Clients should understand that these services may not carry the protections associated with a fully regulated investment firm, such as investor-compensation protection, deposit-guarantee protection, or access to a financial ombudsman, unless we expressly state otherwise.
Where a service requires authorisation in a client’s country of residence or in another jurisdiction where the service is offered, we will only provide that service where we are permitted to do so. Where a particular service is offered through a different entity or under a different authorisation, we will tell you.
Part B · Becoming a client
To use the Services you must be at least 18 years old (or the age of majority where you live, if higher), have full legal capacity to enter into a binding agreement, and not be a resident of a country where the Services would be unlawful or where we do not offer them (Cambodia, Cuba, Ghana, Iran, India, Israel, Mongolia, Nigeria, North Korea, Panama, Pakistan, the Philippines, St. Vincent and the Grenadines, Syria, Yemen, and the United States).
The availability of our website in your country does not mean that using the Services is lawful where you live. It is your responsibility to ensure you may lawfully use the Services and to comply with the laws that apply to you, including any rules on taxation, anti-money-laundering, and the trading of leveraged or virtual-asset products.
We may assess your knowledge, experience, financial position, country of residence, and the products you request in order to decide whether we can provide Services to you, whether limits or restrictions should apply, and whether additional warnings or checks are required. This assessment is for onboarding, compliance, risk-management, and client-protection purposes. Unless we expressly tell you otherwise in writing, it does not mean that you have been categorised under any specific statutory client-classification regime, such as retail client, professional client, or eligible counterparty.
We will not treat you as having fewer protections, or as being suitable for higher-risk products, simply because you request it. Where any formal client categorisation is required by applicable law, we will apply the relevant legal criteria and explain the consequences to you before relying on that categorisation.
When you register, you must provide accurate, complete, and current information and keep it up to date. Because we are subject to anti-money-laundering (AML) and "know-your-customer" (KYC) obligations, we will verify your identity before you can fully use the Services, and we may ask for documents such as proof of identity, proof of address, and information about your source of funds and wealth. We may also carry out sanctions and politically-exposed-person screening, and ongoing monitoring as required by law.
We may decline an application, or limit, suspend, or close an Account, where we cannot verify your identity, where verification raises concerns we are legally required to act on, or where continuing would breach applicable law. Except where the law prevents us, we will tell you when we take such a step.
You are responsible for keeping your login details confidential and for transactions carried out through your credentials. Please notify us promptly if you suspect unauthorised access, and we will work with you to investigate.
Where required, we may ask about your knowledge and experience to assess whether a product is appropriate for you, and we may warn you if it does not appear to be. A warning does not prevent you from trading, but you should take it seriously. We may be unable to assess appropriateness if you do not give us enough information, or if you withhold or misstate it.
You confirm that you understand the nature of the products, that they are leveraged and high-risk, and that you have had the opportunity to use a demo environment or educational material before trading.
If an Account is held jointly or by a company, partnership, or other entity, each holder or authorised signatory is bound by these Terms, and instructions from any one of them may bind all, except where we agree otherwise in writing. For company accounts, we may require evidence of authority and of beneficial ownership. We may require all holders or signatories to approve a withdrawal where this is reasonable to protect against fraud.
Part C · The services
We provide an online platform through which you can trade leveraged products, including CFDs on forex, stocks, indices, commodities, and cryptocurrencies, and (where offered) spot virtual-asset services. CFDs let you take positions on price movements without owning the underlying asset; they involve leverage and a high degree of risk (see Part F).
We may add, change, or withdraw Instruments, markets, or features, and set or vary the conditions that apply to each (such as trading hours, minimum sizes, and available leverage). Where a change materially affects open positions, we will act reasonably and give notice where practicable.
Where we offer cryptocurrency trading or custody, additional risks apply that you should understand:
The legal and regulatory treatment of crypto assets is still developing and varies by country; it can change quickly and may affect the use, transfer, value, or availability of a given asset. As a result, we may need to suspend, limit, or stop supporting a particular crypto asset or service, including to comply with the law. Where we reasonably can, we will give notice and allow you to close or withdraw affected positions or assets.
Where we hold virtual assets for you, we will do so in line with applicable law and our custody arrangements (see Section 22).
We provide execution-only services. We do not manage your money, give personal investment, legal, or tax advice, or recommend particular trades or strategies. Any educational material, market commentary, research, signals, or tools we make available are general information only, may not be accurate or current, and must not be relied on as advice or as the sole basis for a decision. All trading decisions are yours.
You should understand how we may earn money and where our interests and yours can differ. Depending on the Instrument, we may act as counterparty to your trades rather than passing them to an external market. In that model, your loss may be our gain, which creates an inherent conflict of interest. We may also choose whether or not to hedge your positions.
We maintain arrangements designed to identify and manage conflicts so that they do not unfairly damage your interests, as set out in this Section 13. We disclose this conflict openly so that you can take it into account.
Part D · Trading
We provide prices for the Instruments we offer. Our prices are derived from market data but may differ from prices in the underlying market, and the spread (the difference between the buy and sell price) is a cost to you. Prices can move quickly, and a price shown is indicative until your order is executed. We will publish current spreads, financing rates, and contract specifications, and will give reasonable notice of changes except in fast-moving or illiquid markets, where changes may take effect immediately.
You can place orders through the platform, including market orders, limit orders, and stop orders. We will seek to execute your orders in line with this Section 15, taking reasonable steps to obtain a fair result for you.
In summary: a market order is executed at the best price currently available, which may differ from the price last shown; a limit order executes only at your specified price or better; and a stop order becomes a market order once your trigger price is reached. You can usually set how long an order remains active and amend or cancel a pending order before it executes. You are responsible for the orders you place and for monitoring their status, and you should make sure you understand how each order type behaves before using it.
Because markets move continuously, the price at which an order is executed may differ from the price shown when you placed it (slippage), and prices can "gap" through your stop level, especially around news or at market open. Stop orders are therefore not guaranteed to execute at the exact stop price unless we expressly offer a guaranteed stop. We may decline or delay an order where there is insufficient margin, where a market is closed or disrupted, or where execution would breach these Terms or applicable law, and we will not be responsible for losses caused by matters outside our reasonable control.
Leveraged positions require you to keep a minimum amount of funds in your Account as margin. You are responsible for monitoring your Account and maintaining sufficient margin at all times.
If your available margin falls below the required level, we may make a margin call (a request for more funds) and, if the position is not brought back within margin, we may close some or all of your open positions to limit further losses. To protect clients, we may operate an automatic close-out at a defined margin level. We will publish the applicable leverage and margin levels and may adjust them in response to market conditions or your circumstances; where we do, we will give notice as soon as reasonably practicable.
As a simple illustration of how leverage works: at leverage of 1:30, opening a position with a notional value of 3,000 units of currency would require about 100 units of your own funds as initial margin. If the market moved against that position, your losses would be calculated on the full 3,000-unit value, not on the 100 units you committed — which is why losses can be large relative to your deposit, and why maintaining margin matters. The exact margin, leverage, and close-out levels for each Instrument are shown on the platform.
Positions held open overnight may attract a financing charge or credit (a "swap" or "rollover"), reflecting the cost of the leverage. These rates are published and may change. Over time, financing costs can be significant, particularly on positions held for long periods.
For CFDs on shares or indices, corporate actions affecting the underlying — such as dividends, splits, rights issues, or mergers — may lead us to make a corresponding adjustment to your position so that, as far as practicable, you are left in a broadly equivalent economic position. We will make such adjustments reasonably and in good faith.
Occasionally a price may be clearly wrong — for example, because of a data-feed fault or an obvious typing error (a "manifest error"). Where a trade is executed on a manifestly erroneous price, we may, acting reasonably and in good faith, cancel it or correct it to the price that would fairly have applied, and adjust your Account accordingly. We will not use this provision to cancel trades simply because they were profitable for you; it applies only to genuine, evident pricing errors, and we will tell you and explain when we rely on it.
To protect the integrity of the market and other clients, you must not engage in abusive or unlawful trading, including market manipulation (such as spoofing, layering, wash trading, ramping, quote stuffing, or pump-and-dump schemes), trading on the basis of inside information, or knowingly exploiting a system error, latency, or a price you know to be wrong.
If we have reasonable grounds to believe you have engaged in such conduct, we may investigate, void only those specific trades affected by the abuse, suspend the Account, and report the matter where the law requires. We will not treat ordinary, legitimate trading — including profitable trading or the normal use of permitted strategies — as abusive, and any action we take will be proportionate and explained.
Part E · Your money
You may fund your Account using the payment methods we make available. To meet AML requirements, deposits should be made from a payment source held in your own name, and we may ask you to confirm the origin of funds. We do not accept deposits from unrelated third parties.
Your Account may be held in one of our base currencies — US Dollars, Euros, or British Pounds. If you deposit in another currency, it will be converted at the exchange rate applying at the time of conversion, and currency-conversion costs may apply.
You have the right to withdraw your available funds — your deposits and any profits from your own trading — at any time, subject only to the lawful checks described below. There is no minimum trading volume, turnover, or similar condition that you must meet in order to withdraw your own money.
Your money and any virtual assets we hold for you remain yours; they are not ours to use as our own. Client funds and assets are held in accordance with our internal client-money and custody procedures. Depending on the payment method, product, and asset type, funds may be held with banks, payment service providers, liquidity providers, custodians, wallet providers, or other third-party service providers. We maintain records designed to identify client balances and to distinguish client funds and assets from our own operating funds.
Client funds and assets may be exposed to risks relating to the banks, payment service providers, custodians, liquidity providers, wallet providers, or other third parties we use. Unless we expressly state otherwise in writing, your Account is not covered by any deposit-guarantee scheme, investor-compensation scheme, or similar statutory protection.
For virtual assets, custody may involve wallets controlled by us or by a third-party custodian, and assets may be held in pooled or omnibus wallets. This may create additional risks, including operational risk, cyber-security risk, private-key risk, blockchain-network risk, and insolvency risk affecting a custodian or other service provider.
The fees that apply to your Account — which may include spreads, commissions, overnight financing or swap charges, currency-conversion costs, and payment-processing fees — are set out in the fee information shown on the platform, in your Account, on the relevant trade ticket, payment screen, or other applicable cost disclosure before you place a trade or make a transaction, which forms part of these Terms. We will give you reasonable notice of any change to our fees before it takes effect, except where a change reflects a market or third-party cost outside our control.
Third parties, such as your bank, card provider, or an intermediary bank, may also charge fees for transfers; these are outside our control and are your responsibility.
In plain terms, the main costs of trading with us are likely to be: the spread built into our prices; any commission charged per trade; overnight financing on positions held open from one day to the next; currency conversion where you trade or fund in a currency other than your account currency; and payment fees on some deposit or withdrawal methods. Costs reduce your returns, and frequent trading or long-held positions can make them add up significantly. We aim to set out all applicable costs clearly before you trade.
You are responsible for determining, reporting, and paying any taxes that apply to your trading and to any profits you make, and for understanding how the laws of your country treat these products. We do not provide tax advice. Where we are legally required to withhold or report tax-related information, we will do so.
Part F · Risk
Trading leveraged products is highly speculative and may not be suitable for everyone. This section summarises the key risks; please also read our Risk Warning.
Leveraged trading can also carry behavioural risks: the speed of gains and losses can encourage over-trading or chasing losses, and trading on borrowed money can amplify the financial and emotional impact of a losing run. These products are generally more suitable for people who understand them well, can monitor their positions, and can absorb losses. They are not a substitute for saving or longer-term investing, and they are not appropriate for money you may need.
You should not trade with money you cannot afford to lose. If you are unsure whether these products are right for you, seek independent advice.
Part G · Platform and conduct
We grant you a limited, non-exclusive, non-transferable right to access the platform for your own use under these Terms. We aim to keep the Services available and accurate, but we cannot guarantee they will be uninterrupted or error-free. The Services may be unavailable for maintenance, upgrades, or reasons beyond our control, and market data may be delayed or contain errors. You are responsible for your own equipment, software, and internet connection, and for keeping access to your Account secure.
All content on the website and platform — including text, graphics, logos, designs, data, and software — is owned by Ellington Ltd or its licensors and is protected by intellectual-property laws. You may use it only as needed to use the Services for your own personal, non-commercial purposes. You may not copy, modify, distribute, resell, frame, deep-link, or create derivative works from our content without our prior written permission. Trademarks shown remain the property of their owners.
You agree to use the Services lawfully and not to:
If you breach this section, we may suspend or close your Account under Section 33, which may involve closing open positions.
We may communicate with you electronically, and you agree to receive notices, statements, and other documents by email or through the platform. We may record and keep records of telephone calls, messages, and other communications with you for security, training, quality, and regulatory purposes, and such records may be used as evidence in the event of a dispute.
We handle your personal information in accordance with our Privacy Policy, which explains what data we collect, why, how we protect it, who we share it with, and the rights you have. By using the Services, you acknowledge that we will process your personal information as described there.
Part H · Legal terms
Nothing in these Terms excludes or limits our liability where it would be unlawful to do so — including liability for fraud or fraudulent misrepresentation, for death or personal injury caused by our negligence, or for any liability that cannot lawfully be excluded. If you are a consumer, these Terms do not affect your mandatory statutory rights.
Subject to the paragraph above, and to the extent permitted by law:
These limits do not apply to our obligation to return your available Client funds to you in accordance with these Terms.
You agree to indemnify us against reasonable losses and costs we actually incur arising directly from your breach of these Terms or your unlawful use of the Services. This indemnity does not extend to losses caused by our own negligence, breach, or wrongdoing.
An "event of default" includes your failure to maintain required margin, your material breach of these Terms, your insolvency or bankruptcy, or our being required to act by law or a regulator. If an event of default occurs, we may, acting reasonably and proportionately, take steps to protect ourselves and other clients — such as closing or suspending open positions, restricting your Account, or setting off amounts you owe against funds we hold for you. We will give notice and an explanation where practicable and lawful, and we will exercise these rights only to the extent reasonably necessary.
You may close your Account at any time, and withdraw your available funds, subject to the checks in Section 21 and the settlement of any amounts you genuinely owe us.
We may suspend or close your Account where you have materially breached these Terms, where we are legally or regulatorily required to, or where we reasonably believe it is necessary to prevent fraud or to protect our other clients or systems. Except where the law prevents us, or where giving notice would defeat a fraud-prevention purpose, we will give you reasonable notice and an explanation. On closure, you remain entitled to withdraw your available Client funds, subject to lawful checks. We do not impose dormancy or inactivity fees, and closing your Account does not cause you to forfeit your own funds.
If you do not use your Account for a long period, we may treat it as inactive — for example, by restricting trading until you confirm your details. We will not charge any dormancy or inactivity fee, and your funds remain yours and available to withdraw at any time, subject only to the lawful checks in Section 21. To reactivate an inactive Account, we may ask you to re-verify your identity in line with our AML obligations.
If you are unhappy with any aspect of the Services, please contact us first using the details in Section 38 so we can try to put things right. We will acknowledge your complaint, investigate it fairly, and aim to respond within a reasonable time, in line with the complaints process described in this Section 34.
If we cannot resolve your complaint directly, you may have the right to raise the matter with a competent regulator, supervisory authority, dispute-resolution body, or court, depending on the product, the activity, your country of residence, and the law that applies. Where a matter falls within the remit of the St. Vincent and the Grenadines Financial Services Authority, you may be able to submit a complaint through its complaint process. Nothing in these Terms removes your right to bring a claim before a court of competent jurisdiction.
We may update these Terms from time to time to reflect changes in our Services, technology, or legal and regulatory requirements. Where a change is material, we will give you reasonable advance notice — for example by email or through the platform — before it takes effect. We will always show the date these Terms were last updated at the top of this page, and we will keep a link to the current Terms available on the site.
If you do not agree to a change, you may close your Account and withdraw your available funds before the change takes effect. Continuing to use the Services after a change takes effect means you accept the updated Terms. Changes will not be applied retroactively to the disadvantage of positions you have already closed.
These Terms, and any dispute arising out of or in connection with them, are governed by the laws of Saint Vincent and the Grenadines. This does not deprive you, if you are a consumer, of the protection of any mandatory rules of the law of the country where you live, nor of your right to bring or defend proceedings there where applicable law so provides.
We are not liable for any failure or delay in performing our obligations caused by events beyond our reasonable control, such as natural disasters, civil unrest, market suspensions, or failures of communications, systems, or blockchain networks. During such an event we may take reasonable steps to protect clients, including adjusting trading times or margin requirements or closing positions where necessary.
If any provision is found invalid or unenforceable, it will be modified or removed to the minimum extent necessary, and the remaining provisions will continue in full force.
You may not transfer your rights or obligations without our consent. We may transfer ours to a successor (for example, in a reorganisation), provided your rights under these Terms are not reduced.
If we do not enforce a right on one occasion, that does not prevent us from enforcing it later.
These Terms are between you and us; no one else has rights to enforce them, except that our affiliates may rely on the limitations of liability that protect us.
Provisions that by their nature should survive termination — including those on liability, indemnity, governing law, and amounts owed — continue to apply after your Account is closed.
These Terms, together with the policies referred to in them, make up the entire agreement between you and us regarding the Services and replace any earlier understanding.
If you have questions about these Terms, or wish to make a complaint, please contact us:
Client support / enquiries: support@ellington-ltd.com
Complaints: support@ellington-ltd.com
Post: 275 Slater St. #900, Ottawa, ON K1P 5H9, Canada
These Terms are provided for transparency about the rules that govern the Services. They reflect commonly applicable standards as of June 2026 and should be adapted to, and reviewed against, the laws of the jurisdictions in which the Services are actually offered.