AML Framework
The structure of our anti-money-laundering programme and lines of defence.
1. Programme structure
Draft for review. This document is an internal working template prepared to support commercial onboarding and institutional due diligence. It does not constitute legal advice and must be reviewed and approved by FLOWA PAY INC.'s legal and compliance functions before it is relied upon. 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.