Does providing an FX copy service constitute running an MDA service? For example. You operate a master account. You charge clients for access to your accounts. Clients use a mirror service like http://www.fxcopy.com to mirror trade or replicate your trades – when you place a trade on your account, that same trade is mirrored onto the clients accounts.
like fxcopy, zulu etc etc.
you do not receive access to the clients account, the client starts the mirror service, stops the mirror service etc, defines their risk etc.
Based on your description, it sounds like you are not offering an MDA service – this assumes you have no access whatsoever to other people’s funds. However, your buying and selling actions are likely to be “financial product advice” under Australian law. If you operate in Australia or if you induce people from within Australia, it is likely that you will need to apply for an Australian Financial Services Licence (AFSL).
For further information, please contact us to discuss.