Compliance & legal
A compliance library built for institutional due diligence.
Our policies, procedures and disclosures — structured to the standard regulated financial institutions expect. We publish only verified credentials and mark work in progress honestly.
Regulatory status. FLOWA PAY INC. is a FINTRAC-registered Money Services Business (reg. no. C100000902). MSB registration is not a licence or endorsement. Read the full regulatory disclosures →
Financial crime & AML
Our framework for preventing money laundering, terrorist financing, bribery and sanctions breaches across the customer lifecycle.
AML PolicyGroup anti-money-laundering policy and control objectives.Read →AML FrameworkProgramme structure, roles and the three lines of defence.Read →KYC PolicyIdentifying and verifying individual customers.Read →KYB PolicyVerifying businesses and beneficial ownership.Read →Customer Due Diligence (CDD)Standard due-diligence measures and triggers.Read →Enhanced Due Diligence (EDD)Heightened measures for higher-risk relationships.Read →Source of Funds (SoF)Establishing the origin of transacted funds.Read →Source of Wealth (SoW)Establishing the origin of overall wealth.Read →Sanctions ScreeningScreening against applicable sanctions lists.Read →PEP ScreeningIdentifying and managing politically exposed persons.Read →Adverse Media MonitoringOngoing negative-news screening.Read →Financial Crime PreventionOverarching financial-crime control statement.Read →Anti-Bribery & Anti-CorruptionZero-tolerance approach to bribery and corruption.Read →Sanctions PolicyOur sanctions position, regimes applied and breach handling.Read →Transaction MonitoringMonitoring activity for unusual and suspicious patterns.Read →Suspicious Transaction ReportingEscalation, reporting to FINTRAC and the tipping-off prohibition.Read →Travel Rule & Transfer InformationOriginator and beneficiary information accompanying transfers.Read →AML Training & AwarenessThe ongoing training programme and how it is evidenced.Read →Compliance Effectiveness ReviewIndependent periodic review of the compliance programme.Read →
Risk & controls
How we identify, measure and control operational, financial and conduct risk to institutional standards.
Risk Management FrameworkRisk appetite, taxonomy and governance.Read →Fraud Prevention PolicyDetecting and preventing transactional fraud.Read →Internal ControlsControl environment and monitoring.Read →Governance FrameworkBoard, committees and accountability.Read →Vendor Due DiligenceAssessing suppliers before onboarding.Read →Third-Party Risk ManagementOngoing oversight of critical vendors.Read →Audit ReadinessEvidence, records and examination support.Read →Outsourcing & Material ArrangementsApproving, governing and exiting critical third-party arrangements.Read →Conflicts of InterestIdentifying, declaring and managing conflicts.Read →
Security & resilience
Protecting data and systems, and staying operational under stress.
Information Security PolicySecurity governance and technical controls.Read →PCI DSS InformationCard-data handling and scope (as applicable).Read →Business Continuity PolicyMaintaining critical services during disruption.Read →Disaster RecoveryRestoring systems and data after an incident.Read →Record Keeping PolicyRetention and integrity of records.Read →
Data & privacy
How we collect, use, protect and share personal data.
Payments & merchant operations
How money moves, what we will and will not support, and the terms that govern refunds, disputes and merchant acceptance.
Refunds & Cancellations PolicyHow refunds and cancellations work across cards, bank rails and local methods.Read →Chargebacks & Dispute ManagementThe dispute lifecycle, evidence, liability and monitoring.Read →Merchant Underwriting PolicyHow merchants are assessed, approved and risk-rated.Read →Prohibited & Restricted ActivitiesBusiness activities we do not support, and those supported on conditions.Read →
Legal & conduct
The terms that govern our services and the standards we hold ourselves to.
Terms & ConditionsTerms governing use of Flowa Pay services.Read →Acceptable Use PolicyProhibited and restricted uses.Read →Complaints Handling ProcedureHow to raise and resolve complaints.Read →Regulatory DisclosuresOur regulatory status and registrations.Read →Risk DisclosureKey risks relevant to our services.Read →Client Onboarding StandardsWhat we require to open an account.Read →Whistleblowing PolicyRaising concerns safely and confidentially.Read →Code of ConductHow our people are expected to behave.Read →