Anti-Fraud Policy

1. Policy Overview

MintrixTrade Limited ("MintrixTrade," "we," "us," or "our") maintains a strict zero-tolerance policy regarding fraud, money laundering, terrorist financing, and other illegal activities. This Anti-Fraud Policy outlines our commitment to maintaining the highest standards of regulatory compliance in accordance with Nigerian laws and international standards.

This policy is designed to comply with the Money Laundering (Prohibition) Act 2011 (as amended), the Terrorism (Prevention) Act 2011, and regulations issued by the Central Bank of Nigeria (CBN), the Nigerian Financial Intelligence Unit (NFIU), and the Economic and Financial Crimes Commission (EFCC).

2. Zero Tolerance Policy

MintrixTrade has a ZERO TOLERANCE policy for the following activities:

🚫 Money Laundering

Any attempt to disguise the proceeds of criminal activity as legitimate funds. This includes structuring transactions to avoid reporting thresholds.

🚫 Terrorist Financing

Providing or collecting funds with the intention that they should be used or in the knowledge that they are to be used for terrorist purposes.

🚫 Gift Card Fraud

Trading in stolen gift cards, fraudulently obtained cards, cards purchased with stolen payment instruments, or cards obtained through unauthorized means.

🚫 Account Takeover

Unauthorized access to user accounts, phishing attempts, social engineering attacks, or credential stuffing.

🚫 Chargeback Fraud

Purchasing assets with the intention of filing fraudulent chargebacks or reversals with payment providers.

3. KYC & AML Compliance

MintrixTrade implements comprehensive Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures as required by Nigerian law.

3.1 Know Your Customer (KYC) Requirements

Tier 1 - Basic Verification

• Full legal name
• Valid email address
• Phone number verification
• Daily and monthly transaction limits apply

Tier 2 - Full Verification (Required)

• Valid government-issued ID (International Passport, Driver's License, National ID, or PVC)
• Clear photograph of the document
• Selfie with the document (liveness verification)
• Bank account verification
• Unlimited trading for verified users

Enhanced Due Diligence (EDD)

Additional verification may be required for:

• High-value transactions exceeding ₦5,000,000
• Politically Exposed Persons (PEPs) and their associates
• Transactions involving high-risk jurisdictions
• Unusual or suspicious transaction patterns
• Corporate and business accounts

3.2 Data Retention

KYC data and transaction records are retained for a minimum of 5 years from the date of account closure or transaction completion, as required by the Money Laundering (Prohibition) Act 2011.

4. Account Freezing Protocol

MintrixTrade reserves the right to immediately freeze or restrict any account when there is reasonable suspicion of fraudulent activity or non-compliance with this policy.

4.1 Grounds for Account Freeze

Suspicious Activity Indicators

• Multiple failed verification attempts
• Use of suspected stolen or forged identification documents
• Transactions inconsistent with stated occupation or income level
• Rapid sequence of deposits and withdrawals (layering)
• Transactions involving flagged addresses or entities
• Gift card transactions showing red flags in our verification system
• Multiple accounts linked to the same individual or device
• Use of VPN or anonymizing services in a suspicious manner

4.2 Freeze Process

1

Detection & Review

Automated systems flag suspicious activity. Our compliance team conducts an initial review.

2

Account Restriction

Account may be restricted or frozen pending investigation. Withdrawals are typically disabled during review.

3

User Notification

User will be notified via email and in-app notification of the restriction and required actions.

4

Investigation Period

Investigations typically take 3-14 business days. Complex cases may require additional time.

5

Resolution

Account may be reinstated, permanently closed, or referred to law enforcement as appropriate.

📋 Required for Account Reactivation

Users may be required to provide:

• Additional identity verification documents
• Proof of source of funds
• Explanation of suspicious activity
• Proof of ownership for any involved assets
• Video call verification (liveness check)

5. Gift Card Verification Protocols

All gift card transactions are subject to rigorous verification processes to prevent fraud and protect both buyers and sellers on our platform.

5.1 Multi-Stage Verification Process

1

Initial Validation

• Card number format validation
• Brand-specific validation rules
• Duplicate card checking
• User transaction history review

2

Balance Verification

• Automated balance checking via secure APIs
• Manual verification for certain card types
• Screenshot of card balance required for some brands
• Photo of the physical card (if applicable)

3

Risk Assessment

• Machine learning fraud detection scoring
• Card origin and purchase method analysis
• User account age and reputation check
• Geographic and IP address analysis
• Cross-reference with known fraud databases

4

Manual Review (High Risk)

Cards flagged as high-risk are escalated to our fraud prevention team for manual review before processing.

⚠️ Cards We Will NOT Process

• Cards with receipts showing "Stolen" or "Lost" status
• Cards purchased with stolen credit/debit cards
• Cards obtained through unauthorized account access
• Cards with altered or photoshopped balances
• Electronic cards from unverifiable sources
• Cards linked to known fraud rings or compromised merchants
• Any card where legitimate ownership cannot be verified

6. Transaction Monitoring

MintrixTrade employs a combination of automated transaction monitoring systems and manual review processes to detect and prevent fraudulent activity.

6.1 Automated Monitoring

Our systems continuously monitor for:

Volume Anomalies

Unusual spikes in transaction volume compared to user's normal activity.

Structuring Detection

Transactions split to avoid reporting thresholds ("smurfing").

Velocity Checks

Rapid succession of deposits and withdrawals within short timeframes.

Geographic Analysis

Logins from unusual locations or multiple locations simultaneously.

Device Fingerprinting

Multiple accounts from the same device or IP address.

Pattern Recognition

Known fraud patterns identified through machine learning.

6.2 Reporting Thresholds

In accordance with Nigerian AML regulations, MintrixTrade maintains the following reporting thresholds:

Single Transaction Report ₦5,000,000 or more

Aggregate Transactions ₦5,000,000+ in 30 days

Suspicious Activity Any Amount (Immediate Report)

7. Suspicious Activity Reporting

MintrixTrade is legally obligated to report suspicious activity to the appropriate Nigerian authorities.

7.1 Reporting Channels

Nigerian Financial Intelligence Unit (NFIU)

Suspicious Activity Reports (SARs) are filed with the NFIU for transactions that may be related to money laundering or terrorist financing.

Economic and Financial Crimes Commission (EFCC)

Cases involving confirmed fraud, cybercrime, or economic crimes may be referred directly to the EFCC.

Law Enforcement Cooperation

We cooperate fully with valid police investigations, court orders, and warrants.

📋 Legal Disclaimer

MintrixTrade is not required to and will not notify users when Suspicious Activity Reports (SARs) are filed with regulatory authorities. This is in accordance with Section 10 of the Money Laundering (Prohibition) Act 2011, which prohibits tipping off.

7.2 How to Report Fraud

If you suspect fraud or security issues:

📧 Email our compliance team at compliance@mintrixtrade.com
💬 Use the in-app messaging system to contact support
📱 Contact us via WhatsApp at +234 800 000 0000

8. Penalties for Fraud

Users found to be engaged in fraudulent activities will face one or more of the following consequences:

Level 1: Temporary Restriction

• Temporary withdrawal suspension
• Enhanced monitoring and review requirements
• Additional verification steps

Level 2: Permanent Account Closure

• Immediate and permanent account termination
• Forfeiture of any proceeds derived from fraudulent activity
• Blacklisting from future use of MintrixTrade services

Level 3: Legal Action

• Reports filed with NFIU, EFCC, and relevant law enforcement
• Full cooperation with criminal investigations
• Provision of all user data and transaction records pursuant to valid legal process
• Civil action for recovery of damages

⚖️ Applicable Nigerian Laws

Fraudulent activities may result in prosecution under:

• Money Laundering (Prohibition) Act 2011 - Up to 10 years imprisonment
• Terrorism (Prevention) Act 2011 - Severe penalties including life imprisonment
• Cybercrimes (Prohibition, Prevention, Etc.) Act 2015 - Up to 5 years imprisonment
• Economic and Financial Crimes Commission Act 2004
• Criminal Code Act (Northern States) and Criminal Code Act (Southern States)

9. Contact Compliance

For questions or concerns regarding this Anti-Fraud Policy, please contact our Compliance Officer:

📧

Email

compliance@mintrixtrade.com

📱

WhatsApp

+234 800 000 0000

⏱️

Response Time

24-48 business hours for compliance inquiries

This Anti-Fraud Policy is subject to change. Users will be notified of material changes.

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