AML Framework
The structure of our anti-money-laundering programme and lines of defence.
1. Programme structure
This document sets out FLOWA PAY INC.'s policy position and control objectives, published for transparency and to support institutional due diligence. It is reviewed periodically and does not constitute legal advice. FLOWA PAY INC. makes no representation that it holds any licence, authorisation or certification except the FINTRAC Money Services Business registration expressly stated in the Regulatory Disclosures.
Our AML framework operationalises the AML Policy through a designated compliance function, documented procedures, systems and training.
2. Three lines of defence
The first line (business) owns day-to-day controls; the second line (compliance and risk) sets policy and monitors; the third line (independent assurance) reviews effectiveness.
3. Review
The framework and enterprise risk assessment are reviewed at least annually and on material change.