AML and Fraud Control Policy

Last updated 28 September 2026.

Why this policy exists

Cointrivio takes money in when you buy tickets and pays money out when you withdraw coins. Anything that does both can be used to move money that should not be moved, or to take money that belongs to somebody else. This policy sets out what we do to stop that, and what we ask of you.

It is written with the Money Laundering (Prevention and Prohibition) Act 2022, the Cybercrimes (Prohibition, Prevention, etc.) Act 2015 and the Nigeria Data Protection Act 2023 in mind.

Who we are

Cointrivio is operated by Trivet Labs (RC 3164913), a company registered in Nigeria. In this policy "we" and "us" mean that company, and "you" means the person using the app.

For anything in this policy, write to compliance@cointrivio.com.

What Cointrivio is, and what it is not

Cointrivio is a trivia game. Contests are decided by what you know and how quickly you answer, not by chance. Tickets let you play. Coins are earned by answering correctly and by placing in contests, and can be withdrawn once they are worth the minimum shown in your wallet.

Cointrivio is not a bank, a wallet, a savings product or a way to send money to another person. You cannot pay money in and take the same money out again. You cannot transfer tickets or coins to another player. Using the app as a way to move funds rather than to play is a breach of our terms, and we will treat it as one.

Proving who you are

We verify identity in stages, so that ordinary play is not interrupted but money does not leave without checks.

• When you register. Your name, email address and a password. We confirm the email address with a one time code.
• Before your first withdrawal. A valid government issued identity document, which may be your National Identification Number, international passport, driver's licence or voter's card, and bank details in your own name.
• For a large withdrawal, or where something looks wrong. A live photograph or short video to confirm that you are the person on the document, and where the size or pattern of your play calls for it, an explanation of where the money you paid in came from.

We may ask for verification again if your details change, if your account has not been used for a long time, or if we have reason to think the account is not being used by the person who opened it.

If you will not complete verification, we will not pay out. We may also close the account. Identity documents and any biometric check are encrypted, are handled under our privacy policy, and are used for verification and fraud prevention only.

Money paid in must be played

Tickets are bought to be used. Where an account has bought tickets and then asks to withdraw without having played them, we will refuse the withdrawal until the tickets have been used in play. This is the main reason the app cannot be used to pass money through.

Coins won honestly in ordinary play are not affected by this. The rule exists to stop deposits being turned straight back into a payout, which is what moving money through a platform looks like.

Payments must be your own

The bank account you withdraw to must be in the same name as the account holder we have verified. We do not pay a third party, and we do not accept payment from one. A bank account already linked to another Cointrivio account will be refused.

If your name has genuinely changed, tell us and we will verify it again rather than simply refusing you.

What we watch for

Our systems record how accounts are used and raise a flag for a person to look at. Among other things, we look at:

• one device or one bank account being used by several accounts
• a first withdrawal, and withdrawals that are large compared with the usual minimum
• answers arriving faster than a person could reasonably give them, or patterns that suggest automation
• money paid in and withdrawn with little or no play in between
• a sudden change in how an account behaves, or repeated failed payments and chargebacks

A flag is not an accusation. Most are explained by ordinary use, such as a family sharing a phone. It means a person will look before money leaves.

What we do when something looks wrong

We try to match the response to what we have found, and we start by asking.

• We ask. We may request identity documents, proof that a bank account is yours, or an explanation of unusual activity.
• We hold. A withdrawal can be held while we check. Contest prizes are held for a short period, shown in the app, before they can be withdrawn at all.
• We limit or suspend. An account can be limited or suspended while we investigate.
• We reverse. Coins obtained through cheating, multiple accounts or exploiting a fault can be taken back, and a payout already made on the strength of them can be recovered.
• We close, and we report. Where we conclude an account has been used for fraud or to launder money, we will close it and report it where the law requires.

Where we hold or refuse a withdrawal we will tell you why, and you may give us your side of it, unless telling you would itself break the law. Coins you earned honestly remain yours, and we will pay what is properly due even where an account is closed for another reason.

Mistakes and reversals

Software has faults. If a fault credits coins, tickets or a prize that you did not win, we may reverse it. If you have already withdrawn the value of an incorrect credit, your balance may go below zero, and the shortfall is recoverable from later winnings or as a debt.

If you notice that your balance is wrong in your favour, tell us. Continuing to play on it or rushing a withdrawal is not a lucky break, and we will treat it as taking money that is not yours. Our server records are what we rely on to establish what actually happened.

Reporting to the authorities

Where the law requires us to report a transaction or an account to the Nigerian Financial Intelligence Unit, to law enforcement or to a regulator, we will. In some cases the law prevents us from telling you that a report has been made, and in those cases we will not.

Records we keep

We keep identity records, payment and withdrawal records, and the records of any investigation, for as long as the law requires and no longer than we can justify. This is set out in our privacy policy. Financial records are kept even after an account closes, because they must be.

Sanctions and public officials

We do not knowingly do business with a person or organisation subject to applicable sanctions. Where an account holder is a senior public official, a close relative or associate of one, we may apply additional checks before paying out.

Our people

A named person at Trivet Labs is responsible for this policy and for deciding what is reported. Staff who review withdrawals or handle player data are trained on it, and what they do inside the dashboard is recorded and can be audited.

What we ask of you

• Hold one account, in your own name, with your own bank details.
• Pay in only from a payment method that belongs to you.
• Play the tickets you buy rather than using Cointrivio to move money.
• Complete verification when we ask for it.
• Tell us about a fault or a wrong balance rather than using it.
• Keep your password and your device to yourself.

Changes

We may change this policy. The date above changes when we do, and we will tell you in the app where the change matters to you.

Questions about this policy go to compliance@cointrivio.com. Anything about your personal data goes to privacy@cointrivio.com.