Anti-Fraud Policy

Our position

We have zero tolerance for fraud — by developers, by investors, by vendors, by carriers, by staff, by anyone using the platform.

What counts as fraud

1. Document forgery — submitting forged C-of-O, R-of-O, deed of

assignment, CAC certificate, tax clearance, building permit, or any other document we rely on.

1. Misrepresentation — overstating returns, hiding encumbrances,

misclassifying property use, or hiding material risks.

1. Identity fraud — using another person's BVN/NIN, impersonating a

developer, or assisting an unverified party to use the platform.

1. Smurfing / structuring — splitting investments across nominees to

evade individual caps or AML thresholds.

1. Market manipulation — coordinated bidding, sham listings, fake

reviews, or any attempt to corrupt the matching engine.

1. Insider corruption — any platform employee accepting payment or

benefit to influence an approval, decline, or dispute.

How we detect it

• Independent legal review before any project goes live (see Investor

Protection Charter).

• Independent State Coordinator review after Legal clearance.
• Real-time document fingerprinting — once a document is reviewed,

we lock its hash. Any silent swap revokes the clearance automatically.

• Continuous monitoring of investment cap structures for

smurfing/structuring patterns.

• External authority cross-checks with CAC, LSLR, FCDA, EFCC press

releases, NDLEA watchlist, OFAC, and UN sanctions lists.

• Whistleblower channel — confidential, audit-logged, no retaliation

(see Whistleblower Policy below in Platform Rules).

How we respond

1. Document forgery / misrepresentation:

- Immediate project takedown. - All invested funds in escrow refunded within 5 business days. - Developer's account permanently revoked. - Reported to EFCC + LASRRA (or equivalent state agency). - Public on-platform notice on the developer's profile.

1. Identity fraud:

- Account frozen pending verification. - Funds traced + held until ownership confirmed. - Reported to NIMC and EFCC.

1. Smurfing / structuring:

- Affected investments unwound. - All linked accounts placed under enhanced KYC. - Reported to NFIU.

1. Insider corruption:

- Immediate termination + criminal referral. - Independent audit of every decision the employee touched.

Disclosure

We publish a Trust & Safety Report every quarter summarising:

• Number of projects reviewed
• Number cleared / blocked / changes-requested
• Categories of red flags raised
• Funds protected
• Cases referred to authorities

Personal details are redacted; aggregate trends are not.