§ 1Disclaimer & legal basis
This report is a Public-Information Assessment (PI) issued under TIB-FRM-1.1 § 27 and TIB-MTH-1.0 § 20. It applies the published TIB-IS v1.0 universal Standards and the TIB-FRM-BR-1.0 Module to publicly available materials about the named firm. It is not an audit, regulatory finding, credit rating, or engagement-based TIB Report. The PI determination scale (PI-Pass / PI-Conditional / PI-Concern / PI-Insufficient evidence) is distinct from, and weaker than, the engagement-based scale (Pass / Conditional / Fail).
Lawful basis: nominative fair use of the firm's name to identify the subject of commentary; truth defence in respect of factual statements (each cited in § 8); right to express opinion on disclosed factual premises clearly labelled "indicative". No firm logos or copyright-protected materials are reproduced beyond short fair-use quotations. Equal-treatment principle applies: same methodology, evidence standards, right of reply, and take-down policy as every PI subject.
§ 2Subject
https://www.xm.com.Jurisdiction: Cyprus (primary EU-regulated entity). Address: Trading Point of Financial Instruments Ltd — 12 Richard & Verengaria Street, Araouzos Castle Court, 3rd Floor, 3042 Limassol, Cyprus (per CySEC public register; not directly verified within fetch budget)..
§ 3Methodology
Conducted under TIB-MTH-1.0 § 20 (PI light methodology). Single-Reviewer rule applies (Two-Reviewer rule at TIB-MTH § 6 reserved for engagement-based reports).
| Phase | Activity | Standard | Dates |
|---|---|---|---|
| PI-A | Public-information collection from the firm's website, T&C, and any public regulator references. | TIB-MTH § 20.2 | 2026-04-12 → 2026-04-16 |
| PI-B | Application of TIB-IS v1.0 + TIB-FRM-BR-1.0 criteria; conservative classification — Insufficient evidence used wherever public materials do not support a positive or negative conclusion. | TIB-MTH § 20.3 | 2026-04-16 |
| PI-C | Engagement Lead approval. | TIB-MTH § 20.4 | 2026-04-16 |
| PI-D | Pre-Publication Notice served on subject firm with full draft and 14-day reply window. | TIB-FRM § 27.5 | 2026-04-16 → 2026-04-30 |
| PI-E | Publication after window closes; firm responses (if any) included verbatim or fairly summarised. | TIB-FRM § 27.5 | scheduled 2026-05-01 |
§ 5Findings
Each criterion is assessed against the available public evidence. Criteria not assessable from public materials alone are scored Insufficient evidence.
| ID | Criterion | Class | Basis |
|---|---|---|---|
| IS-1.1 | Corporate identity disclosed (legal name, jurisdiction, registry ID) | Strength | Primary entity: Trading Point of Financial Instruments Ltd (Cyprus, CySEC-regulated; one of several entities in the Trading Point Holdings group operating under the XM brand) |
| IS-1.2 | Registered address publicly verifiable | Observation | Address: Trading Point of Financial Instruments Ltd — 12 Richard & Verengaria Street, Araouzos Castle Court, 3rd Floor, 3042 Limassol, Cyprus (per CySEC public register; not directly verified within fetch budget). |
| IS-1.4 | Continuous trading history of operating entity | Strength | Public website live and operational at evidence cut-off. |
| IS-2.1 | Terms and conditions published | Strength | Client agreement / T&C published. |
| IS-2.5 | Risk warnings present and visible | Strength | Risk disclosure document published. |
| IS-5.2 | No public sanctions, regulator warnings, or court orders | Observation | No public regulator enforcement action identified at evidence cut-off; PI cannot assert absence definitively. |
| BR-1.1 | Regulatory authorisation(s) disclosed with licence numbers | Strength | Regulated entities and licence numbers published. |
| BR-1.2 | Multi-entity disclosure (which client is served by which entity) | Observation | Multi-entity structure disclosed. |
| BR-2.1 | Client-money segregation / protection scheme disclosure | Strength | Client-money treatment: EU/CY: client money segregated under CySEC rules; ICF up to EUR 20,000. AU: ASIC client money rules. Belize / SA: per local regulator; group public disclosure references segregated client funds and external audit. |
| BR-2.2 | Negative balance protection disclosure | Strength | NBP status: depends_on_entity |
| BR-3.1 | Execution model disclosed (ECN/STP/MM) | Strength | Execution model: XM publicly markets a no-dealing-desk / STP execution policy; firm references an order execution policy on each entity's site. |
| BR-3.2 | Leverage limits and jurisdiction-specific tiers disclosed | Observation | Maximum leverage: Retail FX major: 1:30 in EU (CySEC) and AU (ASIC); up to 1:1000 under XM Global Limited (Belize) for non-EU clients. |
| BR-4.1 | Complaints and ADR pathway disclosed | Observation | Complaints pathway: Internal complaints; EU escalation to Cyprus Financial Ombudsman / CySEC; AU to AFCA; ZA to FAIS Ombud; Belize to FSC. |
§ 7Indicative determination
PI-Indicative — within scope of public information
On the basis of publicly available materials only, the firm presents within the scope of TIB-IS expectations across the criteria assessable from public sources. A number of criteria are scored Insufficient evidence and would require an engagement-based assessment to determine. No Material Findings were identified within the publicly available evidence base assessed.
This indicative determination is not a Pass under TIB-FRM-1.1 § 13 and shall not be cited as such. The firm may obtain an engagement-based Verified Determination by electing PI-to-FV conversion under TIB-FRM-1.1 § 27.7.
§ 8Evidence register
Every factual statement in §§ 2–7 derives from one or more sources in this register.
| ID | Source | URL | Accessed |
|---|---|---|---|
| EV-01 | XM Group — official homepage | https://www.xm.com | 2026-04-16 |
| EV-02 | XM Group — Terms and Conditions | not_found in fetch | 2026-04-16 |
| EV-03 | XM Group — Risk disclosure | not_found in fetch | 2026-04-16 |
| EV-04 | Live operation evidence | https://www.xm.com — live; CySEC public register lists Trading Point of Financial Instruments Ltd as authorised; Trading Point group continues to publish multi-jurisdiction regulatory disclosures. | 2026-04-16 |
| EV-05 | TIB Standards — TIB-IS v1.0 universal criteria | https://integritybureau.org/standards/integrity-standards/ | 2026-04-16 |
| EV-06 | TIB Standards — TIB-FRM-BR-1.0 Broker Module | https://integritybureau.org/standards/framework-broker/ | 2026-04-16 |
| EV-07 | TIB Methodology — TIB-MTH-1.0 § 20 (PI light methodology) | https://integritybureau.org/methodology/#s20 | 2026-04-16 |
| EV-08 | TIB Framework — TIB-FRM-1.1 § 27 (PI category) | https://integritybureau.org/standards/framework/#s27 | 2026-04-16 |
§ 9Reviewer signature
Approved this Public-Information Assessment as compliant with TIB-MTH-1.0 § 20 and TIB-FRM-1.1 § 27. No conflicts of interest declared. No commercial relationship with the subject firm.
Independent review of source evidence and findings classification.
§ 10Right of reply & take-down
Pre-publication right of reply (TIB-FRM-1.1 § 27.5): the subject firm has 14 calendar days from service of the Pre-Publication Notice (2026-04-16) to 2026-04-30 to submit a written reply. Any reply will be reproduced verbatim as Annex A or fairly summarised, at the firm's election, before publication on 2026-05-01.
Post-publication correction (§ 27.6): the firm may at any time submit a correction request supported by primary evidence, or a take-down request demonstrating material error or breach of applicable law. TIB will respond within 5 business days.
Conversion to engagement (§ 27.7): the firm may at its sole election convert this PI to an engagement-based Full Verification (FV) or Limited-Scope (LS) Report. On signature of the standard engagement letter, this PI is withdrawn from the Public Registry pending publication of the engagement-based Report.
Contact: registry@integritybureau.org · Stratinova LTD · Archiepiskopou Makariou III 228, Agios Pavlos Building · 3030 Limassol · Cyprus.