Anti-Money Laundering & CFT / CPF Policy

TopLogical Nigeria Limited ("the Company", "TopLogical", operating "TopSafeAI") is unconditionally committed to preventing its software infrastructure, personnel, and institutional services from being used for Money Laundering (ML), Terrorism Financing (TF), or Proliferation Financing (PF).

The Company maintains a zero-tolerance stance toward illicit financial flows. This Policy sets out mandatory baseline standards to detect, deter, and report suspicious activities in full accordance with the laws of the Federal Republic of Nigeria and international standards established by the Financial Action Task Force (FATF).

This Policy applies unconditionally to:

• All full-time, part-time, contract, and remote employees of TopLogical Nigeria Limited.
• Members of the Board of Directors, executive management, and advisory bodies.
• The design, operational execution, and software pipelines of TopSafeAI transaction monitoring, PEP screening, and regulatory automation engines.
• Third-party contractors, system integrators, and technology partners interfacing with TopSafeAI systems.

This Policy is drafted and executed pursuant to the following primary statutes and regulatory instruments:

Customer Due Diligence is the bedrock of compliance. No institutional relationship may be established, nor API credential issued, without completing mandatory CDD verification:

• Legal Existence: Verification of Corporate Affairs Commission (CAC) registration, Certificate of Incorporation, Memorandum and Articles of Association (MEMART), and Status Report.
• Tax Identification: Direct electronic validation of corporate Tax Identification Numbers (TIN) via FIRS.
• Regulatory Standing: Verification of relevant CBN banking/fintech license, SEC approval, or operational permits.
• Ultimate Beneficial Ownership (UBO): Identification and verification of all natural persons owning or controlling 5% or more of share capital or voting rights.

Enhanced Due Diligence (EDD) is mandatory for high-risk accounts, cross-border remittance providers (IMTOs), high-volume corporate accounts, and Politically Exposed Persons (PEPs):

PEP Requirements: Any account associated with foreign or domestic PEPs, their immediate family members, or close associates (RCAs) requires:

• Senior Executive / Chief Compliance Officer written sign-off prior to onboarding.
• Source of Wealth (SoW) and Source of Funds (SoF) documentary evidence.
• Continuous, intensified transaction monitoring reviewed quarterly.

TopSafeAI executes automated, algorithmic transaction scoring to detect red flags including but not limited to:

• Structuring / Smurfing: Deliberate splitting of transactions below mandatory regulatory thresholds (e.g., ₦5,000,000 for individuals, ₦10,000,000 for corporates).
• Rapid Velocity Spikes: Sudden deviations from established historical behavioral baselines without economic justification.
• High-Risk Geographies: Transactions involving jurisdictions designated on FATF grey or black lists.
• Circular Muling: Pass-through accounts where funds are received and immediately disbursed to unassociated parties.

All suspicious activities and threshold transactions must be filed strictly within statutory deadlines:

• Suspicious Transaction Reports (STRs): Must be filed with the NFIU immediately, and no later than 24 hours after forming the suspicion.
• Currency Transaction Reports (CTRs): Must be filed weekly in accordance with NFIU guidelines for single transactions exceeding statutory thresholds.
• Tipping-Off Prohibition: Employees and institutional users are strictly prohibited by law from disclosing to any customer or third party that an STR has been reported or that an investigation is active.

TopLogical enforces annual mandatory AML/CFT/CPF certification for all staff. Training modules include detection of modern fintech typologies, synthetic identities, cyber-enabled money laundering, and regulatory escalation processes. All staff undergo background vetting, criminal record checks, and credit integrity checks before appointment.

In accordance with Section 8 of the Money Laundering (Prevention and Prohibition) Act 2022, all records relating to customer identity, transaction logs, screening outputs, investigator audit trails, and STR/CTR filings must be retained securely for a minimum period of five (5) years following the termination of the business relationship or completion of the transaction.

The Board of Directors bears ultimate responsibility for AML/CFT/CPF governance. The Chief Compliance Officer (CCO) has direct, unhindered access to the Board Audit & Risk Committee.

Failure to adhere to this Policy constitutes gross misconduct, resulting in summary dismissal, disciplinary proceedings, and immediate referral to relevant law enforcement agencies (EFCC, NFIU, ICPC, and Nigerian Police Force) for criminal prosecution under applicable statutes.