As an ECN forex broker FXCC has No Dealing Desk. Our business model is based on Straight Through Processing (STP) in an electronic configured network, we refer to this as our ECN/STP FX trading model.

Client trades are made on prices provided to FXCC by its liquidity providers. The Price Aggregator automatically scans these so traders are assured of only ever getting the best available Bid/Ask price combinations, ensuring that all orders are executed in a truly competitive and transparent method.

38.3
You agree and understand that we will affect any Transactions with you as an agent. Thus we will be transmitting your Orders for execution to another broker(s) and such broker(s) may be transmitting the orders received by us to other liquidity providers. These brokers are not regulated market. ...the Client will not be liable for any negative Balance in their trading account, which negative Balance will be covered by the Company.

Conflict Of Interest
FXCC doesn’t take positions against its clients at all.

Automated Trading/Market Data.
Clients can connect their trading systems to our market data feed through the use of our API, clients can connect their trading models and risk management systems to our market data feed and matching engine. FXCC's live, neutral, executable market data, includes depth-of-market bid and offer prices, as well as quantities available at all price levels.

Instantaneous Trade Execution.

Clients trade instantly on live streaming, experiencing the best executable prices, with immediate confirmations. FXCC does not provide a "last look" to price makers, therefore FXCC trades are final and confirmed as soon as they are dealt. There are no re-quotes.

6.5 Execution Venues
Execution Venues are the entities with which the orders are placed. For the purposes of orders for the financial instrument of CFDs, the Company will act as an agent (therefore some third financial institution(s) will be the Execution Venue).

Likelihood of Execution: The Company will act as agent whereby some other Financial Institution(s) will be Execution Venue(s), in which case execution may be more difficult. This means that likelihood of execution depends on the availability of prices of other market makers/financial institutions.

The trading does not happen in a regulated market. Therefore the Client may be trading with a third financial institution/Market maker (whereby the Company will be acting as an agent).The Client is given the option to place with the Company the following orders for transmission for execution in the following ways:(a) The Client places a “market order” which is an order executed against the price based on a price obtained by a third market maker but although it may be based on such a price it is not necessarily identical (to be called “the Company’s quoted price”).

Over the Counter Transactions Transactions in CFDs are not to be undertaken on a recognised or designated investment exchange and, accordingly, they may expose the Client to greater risks than exchange transactions. The terms and conditions and trading rules may be established solely by the counterparty. The Client may only be able to close an open position of any given contract during the opening hours of the exchange. The Client may also have to close any position with the same counterparty with whom it was originally entered into. In regard to transactions in CFDs with the Company, the Company is using a Trading Platform for transactions in CFD’s which does not fall into the definition of a recognised exchange as this is not a Multilateral Trading Facility.

Conclusion

FXCC is an OTC (Over-the -Counter) CFD Forex broker, with No-Dealing Desk, that routes orders using STP technology to an external execution venues (sometimes historically affiliated), and charges spread mark-ups.

True strict ECN dealing is not possible on OTC market (which Forex is). While ECN-style pricing is the closest definition that applies.