Security, custody, and compliance: documented

1.0 ABOUT THIS POLICY

This Legal Policy explains the legal and regulatory basis on which Strails is provided, what we commit to, and what we require of you. It applies alongside our Terms and Conditions, Privacy Notice and any commercial agreement between us. Where this Policy and your commercial agreement conflict, your agreement prevails.

By accessing or integrating with the Strails platform, you accept this Policy.

2.0 OUR REGULATORY POSITION

Strails provides technical financial infrastructure for onramp, offramp, payouts, wallet management and transaction processing.

Certain payment, collection and settlement rails are delivered in partnership with licensed payment and financial service providers. Where a rail is provided by a partner, the regulated activity is carried on by that partner under its own license and terms.

We do not carry out banking business. Balances held in connection with the platform are not insured by the Nigeria Deposit Insurance Corporation.

We do not provide investment, tax, accounting or legal advice. Nothing on the platform or in our documentation should be relied on as such.

3.0 WHO CAN USE STRAILS

Strails is available to corporate clients only. It is not offered to individual consumers, to entities in sanctioned jurisdictions, or to any person prohibited from receiving our services under applicable law.

Access is granted only after successful business onboarding and verification.

4.0 FINANCIAL CRIME

We operate an anti-money laundering, counter-terrorist financing and counter-proliferation financing programme in accordance with the MLPPA 2022 and the TPPA 2022, applying risk-based standards consistent with FATF Recommendations.

We verify our clients and their ultimate beneficial owners, monitor transactions, and report suspicious transactions to the Nigerian Financial Intelligence Unit (NFIU) through goAML.

We screen clients, counterparties and wallet addresses against Nigerian, United Nations, OFAC, EU and UK sanctions lists.

Where required, transactions are subject to originator and beneficiary information requirements under the Travel Rule.

We may delay, block, freeze, decline or reverse a transaction, or suspend access, where we are required to do so by law or by direction of a competent authority. We will act proportionately, but we may be unable to explain our reasons.

5.0 WHAT WE ASK OF YOU

You are responsible for:

1. Providing accurate and current information about your business, ownership, control and licensing status, and telling us promptly when it changes.

2. Maintaining your own financial crime programme appropriate to your risk profile, including customer verification, transaction monitoring, sanctions screening and suspicious transaction reporting.

3. Holding any license, registration or approval your own activities require.

4. Keeping your API credentials secure and telling us immediately if they are compromised.

5. The accuracy of every transaction instruction you submit, including wallet addresses, bank details, amounts and network selection.

6. Cooperating with reasonable requests for information for enhanced due diligence, including source of funds and other information we may seek from time to time.

6.0 PROHIBITED USE

You must not use Strails in connection with money laundering, terrorist financing or proliferation financing, fraud or unauthorised transactions, sanctioned persons or jurisdictions, unlicensed money transmission, deposit taking, lending or securities activity, gambling, narcotics, arms or other unlawful trade, evasion of foreign exchange or capital controls, or any undisclosed downstream or nested service.

You must not reverse engineer, resell, sublicense or white-label the platform without our written consent.

7.0 DATA PROTECTION

We process personal data in accordance with the Nigeria Data Protection Act 2023 and the directives of the Nigeria Data Protection Commission. Our Privacy Notice sets out what we collect, why, and how long we keep it.

We act as an independent data controller for the personal data we process for our own legal and compliance purposes. Where we process personal data on your instructions, we do so under a separate data processing agreement.

We retain records for at least five years from the transaction date or the end of our relationship, whichever is later, as required by MLPPA 2022.

8.0 INTELLECTUAL PROPERTY

The Strails names, marks, API, documentation and underlying technology belong to us. You receive a limited, revocable, non-exclusive right to use the platform for as long as your agreement is in force. You may not use our marks or state or imply an endorsement, partnership without our written consent.

9.0 RISK DISCLOSURE

Digital asset and blockchain carries risk. You should understand before you integrate that:

Blockchain transactions are irreversible and cannot be recalled by us once confirmed.

Networks may experience congestion, outages or protocol or smart contract failure.

Settlement times are indicative and may be affected by network conditions, partner processing windows, banking hours and compliance review.

The regulatory treatment of digital assets in Nigeria continues to develop and may change how services are offered.

10.0 SUSPENSION AND TERMINATION

We may suspend or terminate access immediately where you breach this Policy or our Terms, where we are required to do so by law or a regulator, where financial crime or sanctions risk is identified, or where your conduct exposes us to unacceptable legal or reputational risk.

11.0 COMPLAINTS

If something goes wrong, contact us through the support channel available on the website. We will acknowledge your complaint within one business day and aim to resolve it.

12.0 LIABILITY

This Policy does not exclude liability for fraud, willful misconduct, or any liability that cannot lawfully be excluded.

Subject to that, our liability is limited as set out in our Terms and Conditions.

13.0 GOVERNING LAW

This Policy is governed by the laws of the Federal Republic of Nigeria. Disputes not resolved through our complaints process shall be referred to arbitration under the Arbitration and Mediation Act 2023.

14.0 CHANGES TO THIS POLICY

We may update this Policy from time to time. We will give thirty (30) days' notice of material changes, except where a change is required by law or regulation and must take effect sooner.