Fraud Management Policy

TopLogical Nigeria Limited maintains zero tolerance for fraudulent conduct, whether perpetrated by internal personnel, institutional clients, third-party contractors, or external bad actors.

The Company is dedicated to safeguarding customer deposits, institutional transactions, and partner balance sheets by deploying cutting-edge hybrid artificial intelligence and deterministic risk controls.

This policy governs detection and mitigation strategies against the following primary financial fraud vectors:

• Account Takeover (ATO): Unauthorized acquisition of legitimate user accounts via credential stuffing, SIM-swap attacks, or phishing.
• Synthetic Identity Fraud: Fabricating hybrid identities blending authentic BVN/NIN elements with fake addresses or contact details.
• Internal / Insider Fraud: Misuse of system access rights, collusion with external syndicates, or unauthorized rule-table alteration by employees.
• Transaction Laundering & Mule Networks: Funneling illicit proceeds through retail and merchant merchant settlement gateways.
• Chargeback & Friendly Fraud: Malicious dispute exploitation across card-not-present (CNP) payment rails.

Preventive controls are engineered into every layer of TopSafeAI:

• Behavioral Biometrics: Passive profiling of typing velocity, touch pressure, and cursor dynamics during authentication.
• Device Fingerprinting: Cross-checking hardware identifiers, OS versions, emulator flags, and VPN/Tor exit nodes.
• Segregation of Duties (SoD): Strict two-party authorization required for threshold modification, rule publishing, and whitelist creation.
• Adaptive Friction: Step-up authentication (hardware OTP / biometric liveness check) triggered dynamically when risk score exceeds baseline.

TopSafeAI combines real-time streaming risk decisioning with batch graph analysis:

• Real-Time Stream Scoring: Parallel model evaluation assessing 50+ risk factors per transaction event.
• Graph Link Analysis: Visualizing multi-hop connections between bank accounts, BVNs, device IDs, and IP addresses to dismantle fraud syndicates.
• Dynamic Velocity Rules: Automated tracking of transaction velocity (e.g. transfers within 60 seconds of password reset).

All flagged transactions initiate an immutable case file. Compliance investigators must adhere to formal chain-of-custody protocols:

• Evidence Vault Logging: Retaining request payloads, risk breakdowns, and timestamped forensic data.
• Investigation Timeframes: High-risk cases must be evaluated within two (2) hours of alert generation.
• Documented Disposition: Case resolution requires clear written rationale categorizing the event as Confirmed Fraud, False Positive, or Suspicious Activity.

TopLogical provides confidential, anonymous reporting channels for staff, partners, and vendors to report suspected internal fraud or regulatory breaches. Whistleblowers are protected from victimization, demotion, or harassment under Nigerian labor laws.

Where confirmed fraud results in unauthorized fund dissipation:

• Immediate recall and lien requests are dispatched through interbank settlement rails (NIBSS / CBN channels).
• The case is immediately referred to the Special Fraud Unit (SFU) of the Nigeria Police Force and the Economic and Financial Crimes Commission (EFCC).

This Policy is approved by the Board Audit and Risk Committee. Any employee found guilty of fraudulent collusion will be summarily dismissed and criminally prosecuted.