For Platform Reviewers (Apple App Store, Google Play Store, Huawei AppGallery):
This page provides documentary evidence of the regulatory basis under which the KCM Trade application is distributed, the jurisdictions where the app is available, and the jurisdictions where it is explicitly restricted. It directly addresses the following platform review requirements:
- Apple App Store Review Guideline 3.2.2(viii): Apps facilitating CFD or FOREX trading “must be properly licensed in all jurisdictions where the service is available.”
- Google Play Financial Services Policy: Apps containing financial products and services “must comply with state and local regulations for any region or country that your app targets.” Binary options are explicitly prohibited.
- Huawei AppGallery Financial App Review Requirements: Apps providing financial trading services must demonstrate regulatory authorisation in the jurisdictions where the service is offered.
The Company satisfies all of the above requirements through its FSC Mauritius Global Business Licence and Investment Dealer Licence, supported by independent legal opinions, and through geo-restriction of all jurisdictions where those licences do not apply.
1. Licensing Entity
| Detail | Information |
|---|---|
| Legal Entity | Kohle Capital Markets Limited |
| Brand | KCM Trade |
| Jurisdiction of Incorporation | Republic of Mauritius |
| Regulator | Financial Services Commission of Mauritius (FSC Mauritius) |
| Licence No. | C117022600 |
| Global Business Licence | Code FS-4.1 — issued under Section 72(6) of the Financial Services Act 2007 — effective 1 March 2018 |
| Investment Dealer Licence | Code SEC-2.1B (Full Service Dealer, Excluding Underwriting) — issued under Section 29 of the Securities Act 2005 — effective 1 March 2018 |
| Registered Address (Companies Act) | The Cyberati Lounge, C/o Credentia International Management Ltd, Ground Floor, The Catalyst, Silicon Avenue, 40 Cybercity, 72201 Ebène, Republic of Mauritius |
| Principal Place of Business | Second Floor, The Cyberati Lounge 4.0, The Catalyst, Silicon Avenue, 40 Cybercity, 72201 Ebène, Republic of Mauritius |
Licence documents: Available on the Regulatory Documents page.
2. Compliance with Apple Guideline 3.2.2(viii) — Licensing in All Available Jurisdictions
Apple App Store Review Guideline 3.2.2(viii) states:
“Apps that facilitate binary options trading are not permitted on the App Store. Apps that facilitate trading in contracts for difference (“CFDs”) or other derivatives (e.g. FOREX) must be properly licensed in all jurisdictions where the service is available.”
The following is the Company’s direct response to each element of this requirement.
2.1 Nature of the App — CFD and FOREX; No Binary Options
The KCM Trade application facilitates trading in contracts for difference (CFDs) and foreign exchange (FOREX) instruments only. The application does not facilitate binary options trading of any kind. Binary options are not offered, marketed, or available on the platform in any jurisdiction.
2.2 Primary Licences — FSC Mauritius
Kohle Capital Markets Limited holds two licences issued by the Financial Services Commission of Mauritius (FSC Mauritius):
| Licence | Code | Authority | Effective |
|---|---|---|---|
| Global Business Licence (GBL) | FS-4.1 | Section 72(6), Financial Services Act 2007 | 1 March 2018 |
| Investment Dealer Licence (Full Service Dealer, Excluding Underwriting) | SEC-2.1B | Section 29, Securities Act 2005 | 1 March 2018 |
The GBL is the instrument that authorises the Company to conduct regulated financial services business with clients globally from Mauritius. This is the purpose for which the Mauritius Global Business regime was established under the Financial Services Act 2007 — it enables Mauritius-domiciled entities to serve an international client base under FSC supervision without requiring a separate licence in each client jurisdiction.
The Investment Dealer Licence (Code SEC-2.1B) specifically authorises the Company to deal in securities and derivatives — including CFDs and FOREX contracts — on behalf of clients as a full-service dealer.
The FSC Mauritius is a member of the International Organization of Securities Commissions (IOSCO) and operates under a recognised regulatory framework aligned with international standards.
2.3 “Properly Licensed in All Jurisdictions Where the Service Is Available”
The Company satisfies the “all jurisdictions” requirement through a two-part framework:
Part A — Jurisdictions where the app IS available:
In every jurisdiction where the KCM Trade application is available for download and use, the Company operates under its FSC Mauritius GBL and Investment Dealer Licence. The GBL regime is specifically designed to authorise global financial services operations from Mauritius. In jurisdictions where the Company has additionally obtained independent legal opinions (see §2.4), those opinions provide express confirmation that no separate local licence is required.
Part B — Jurisdictions where the app is NOT available (geo-restricted):
The jurisdictions listed in Section 3 (Restricted Jurisdictions) are precisely those where the Company does not hold, or cannot rely on, a licence that is sufficient for local regulatory purposes (e.g. US — no CFTC/NFA registration; Canada — no provincial securities licence; Japan — no FIEA registration). The app is:
- Not listed on the App Store, Google Play, or Huawei AppGallery in those jurisdictions (storefront-level exclusion); and
- Server-side blocked — account registration and login are prevented for users whose IP geolocation, device locale, or declared country of residence corresponds to a restricted jurisdiction.
This ensures that the app is only available in jurisdictions where the Company is properly licensed, and is not available in jurisdictions where it is not. The requirement of Guideline 3.2.2(viii) is therefore satisfied.
2.4 Independent Legal Opinions
To further evidence the Company’s regulatory position in specific markets, independent legal opinions have been obtained from qualified local counsel:
| Jurisdiction | Legal Counsel | Date | Conclusion |
|---|---|---|---|
| Hong Kong | So, Lung & Associates (Ref. LP-26185) | 5 March 2024 | No licence required under HK Securities and Futures Ordinance (SFO) Section 115 in the absence of active marketing directed at HK persons |
| Global / Mauritius GBL Scope | GlobaLex Chambers (Mauritius) | 25 April 2024 | The GBL authorises global client onboarding from Mauritius; no additional local licence is required in non-restricted jurisdictions |
| Thailand | Siamrungroj Law Office Co., Ltd. | 2 March 2026 | No Thai CFD licence required under current Thai law; making the app available via the App Store does not constitute a licensing trigger |
All opinion documents are available on the Regulatory Documents page.
2.5 Summary
| Requirement | Platform | How It Is Met |
|---|---|---|
| App facilitates CFDs/FOREX (not binary options) | Apple, Google Play, Huawei | Confirmed — CFD/FOREX only; binary options not offered |
| Properly licensed / comply with local regulations | Apple 3.2.2(viii) | FSC Mauritius GBL (FS-4.1) + Investment Dealer Licence (SEC-2.1B) |
| Comply with state and local regulations for each target region | Google Play Financial Services | GBL authorises global operations; jurisdictions requiring separate licences are geo-restricted; independent legal opinions obtained for key markets |
| Demonstrate regulatory authorisation in service jurisdictions | Huawei AppGallery | Same GBL and Investment Dealer Licence; same geo-restriction framework |
| In all jurisdictions where available | Apple, Google Play, Huawei | Jurisdictions requiring separate licences not held are excluded from all storefronts and server-side blocked |
| Evidence of licensing | All platforms | Licence documents publicly available; FSC register verifiable online at fscmauritius.org |
| Evidence of restrictions | All platforms | Storefront exclusion + server-side access controls for all restricted jurisdictions |
3. Restricted Jurisdictions (Exceptions to Global Availability)
Notwithstanding the global availability described in Section 2, the KCM Trade application is not available and is geo-restricted from the following jurisdictions. The app is not listed on any storefront in these regions, and server-side controls prevent account creation and login for users identified as residing in or accessing from these jurisdictions.
3.1 Jurisdictions Restricted by Law
| Jurisdiction | Reason |
|---|---|
| United States of America | The Company does not hold CFTC or NFA registration. The app is excluded from the US App Store and equivalent storefronts. US persons are blocked from account creation. |
| Australia | Services to Australian residents are provided exclusively by the separate Australian entity, Kohle Capital Markets Pty Ltd (AFSL No. 489437, regulated by ASIC). Kohle Capital Markets Limited (Mauritius) is not authorised to serve Australian residents. The app is excluded from Australian storefronts. Australian residents are blocked from account creation on the Mauritius-entity platform and redirected to KCM Trade Plus. |
| Canada | Provincial securities licensing requirements apply. The app is excluded from Canadian storefronts. Canadian residents are blocked from account creation. |
| Japan | Japan Financial Instruments and Exchange Act (FIEA) licensing requirements apply. The app is excluded from Japanese storefronts. |
3.2 Jurisdictions Restricted by International Sanctions
The following jurisdictions are restricted in compliance with applicable international sanctions regimes (UN, OFAC, EU, and equivalent):
| Jurisdiction | Basis |
|---|---|
| North Korea (DPRK) | UN Security Council sanctions; OFAC SDN list |
| Iran | UN, US (OFAC), and EU sanctions |
| Myanmar | FATF Call for Action (blacklist); targeted sanctions under EU, UK, and US regimes |
| Syria | UN, US (OFAC), and EU sanctions |
| Sudan | UN and US (OFAC) sanctions |
This list reflects current known restrictions. Additional jurisdictions may be restricted from time to time based on evolving regulatory, sanctions, or legal requirements. The Company reserves the right to restrict access from any jurisdiction without prior notice.
4. App Store Distribution Configuration
The following table summarises the current distribution configuration across each platform:
| Platform | Distribution Status | Geo-Restrictions Applied | App ID / Reference |
|---|---|---|---|
| Apple App Store | Available Worldwide | US, Australia, Canada, Japan, North Korea, Iran, Myanmar, Syria, Sudan excluded from salable storefronts | App ID: 6717598984 |
| Google Play Store | Available Worldwide | US, Australia, Canada, Japan, North Korea, Iran, Myanmar, Syria, Sudan excluded | Package: com.kcmtrade.app |
| Huawei AppGallery | Available Worldwide | US, Australia, Canada, Japan, North Korea, Iran, Myanmar, Syria, Sudan excluded per AppGallery configuration | — |
Geo-restrictions are implemented at two levels:
- Storefront exclusion — the app is not listed or available for download in restricted regions on each platform.
- Server-side access control — account registration and login are blocked for users whose IP geolocation, device locale, or declared country of residence corresponds to a restricted jurisdiction.
5. Australian Services — Separate Entity
Services to Australian residents are provided by a separate legal entity:
Kohle Capital Markets Pty Ltd — trading as KCM Trade Plus
AFSL No. 489437 | Regulated by ASIC
Website: www.kcmtradeplus.com.au
The KCM Trade application (operated by Kohle Capital Markets Limited) is not directed at Australian residents. Australian users are directed to the KCM Trade Plus platform.
For full details, see the Australian Entity — KCM Trade Plus page.
6. Supporting Documentation
The following documents are available for platform review purposes. All documents are linked from the Regulatory Documents page.
| Document | Relevance |
|---|---|
| Global Business Licence | Primary FSC Mauritius licence — confirms authorisation to operate globally |
| Investment Dealer Licence | FSC Mauritius — confirms authorisation to deal in derivatives and CFDs |
| Written Resolutions of Directors — Amendment to Target Markets (May 2024) | Board resolution amending the Business Plan to designate a global client base across ~150 jurisdictions |
| Legal Opinion — Hong Kong (March 2024) | Confirms no HK SFO licence required absent active marketing |
| Legal Opinion — Global Business Licence Scope (April 2024) | Confirms GBL permits global onboarding subject to EDD |
| Legal Opinion — Thailand (March 2026) | Confirms no Thai CFD licence required; App Store availability does not trigger licensing |
7. Contact for Regulatory Inquiries
For questions relating to this disclosure, licensing evidence, or jurisdictional matters from platform review teams or regulators:
Kohle Capital Markets Limited
Second Floor, The Cyberati Lounge 4.0, The Catalyst
Silicon Avenue, 40 Cybercity, 72201 Ebène
Republic of Mauritius
Refer to the Contact page for current contact details.