Sanctions & PEP Policy

TopLogical Nigeria Limited strictly prohibits the onboarding, execution of transactions, or facilitation of commerce on behalf of any individual, corporate entity, or sovereign vessel subject to targeted economic or trade sanctions.

Under no circumstances may any employee or institutional partner override a confirmed sanctions hit without formal legal and regulatory clearance from the Nigerian Sanctions Committee or appropriate international bodies.

TopSafeAI integrates live, automated screening against the following designated sanctions regimes:

• Nigeria Sanctions Committee: Consolidated list of individuals and entities designated under the Terrorism (Prevention and Prohibition) Act 2022.
• United Nations Security Council (UNSC): All resolution-mandated sanction lists (Al-Qaida, ISIL/Da'esh, Taliban, 1718 DPRK, etc.).
• U.S. Department of the Treasury (OFAC): Specially Designated Nationals and Blocked Persons (SDN) and Sectoral Sanctions Identifications (SSI).
• UK Office of Financial Sanctions Implementation (OFSI): Consolidated list of financial sanctions targets.
• European Union (EU): Consolidated list of persons, groups, and entities subject to EU financial sanctions.

PEPs are natural persons entrusted with prominent public functions, including heads of state, senior politicians, judicial or military officials, senior executives of state-owned enterprises, and prominent political party officials.

Screening Scope: Screening applies to Domestic PEPs, Foreign PEPs, International Organization PEPs, and their Relatives and Close Associates (RCAs). Being identified as a PEP does not automatically disqualify an entity, but mandates immediate Enhanced Due Diligence (EDD), source of wealth validation, and senior executive sign-off.

To counter intentional transliteration, spelling variations, and phonetic permutations, TopSafeAI enforces multi-factor phonetic and token-based fuzzy matching:

• Scoring Matrix: Matches with a similarity confidence score ≥ 85% are automatically held for Level-1 Compliance Review.
• Multi-Identifier Correlation: Matches correlate full names, dates of birth, nationality, aliases (a.k.a.), and government ID numbers to eliminate false positives.
• Secondary Review: False positives must be documented with justifiable legal rationale and logged with immutable timestamped evidence.

Pursuant to the Terrorism (Prevention and Prohibition) Act 2022 and CBN directives, whenever a confirmed positive match is identified against a designated sanctions list:

• Zero Delay: All funds, assets, or outbound transactions must be intercepted and frozen immediately without prior notice to the target.
• No Facilitation: No funds, economic resources, or financial services may be made available directly or indirectly to the designated person or entity.

Confirmed sanctions hits must be reported to the Chief Compliance Officer within one (1) hour of verification and formally transmitted to the Nigerian Financial Intelligence Unit (NFIU) and the Nigerian Sanctions Committee Secretariat within twenty-four (24) hours.

Every screening event—including exact query text, matched entities, similarity scores, investigator review notes, and final disposition—is recorded with cryptographic hashing and preserved in the TopSafeAI Evidence Vault for a minimum of five (5) years.

This Policy is reviewed annually by the Chief Risk Officer and submitted to the Board of Directors. Breaching sanctions enforcement protocols is punishable under Nigerian law with severe financial penalties and criminal imprisonment.