AML Training & Awareness

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.

A written policy only works if the people applying it understand it. This policy sets out the ongoing training programme that FLOWA PAY INC. maintains as a required element of its compliance programme, covering what is taught, to whom, how often and how completion is evidenced.

Training is mandatory for all employees, directors and contractors whose role involves customers, transactions, onboarding, support, payouts, risk or compliance, and for anyone with access to systems that process customer or transaction data. Role-specific depth applies: an onboarding analyst receives more detailed due-diligence training than an engineer, who in turn receives training appropriate to the data and systems they touch.

• Money laundering and terrorist financing: how they work and how they present in payments specifically.
• Our obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations, and what that means for day-to-day work.
• Customer due diligence, beneficial ownership, and the triggers for enhanced measures.
• Sanctions, politically exposed persons and adverse media, including how to handle a potential match.
• Red flags and typologies relevant to card acceptance, account-to-account payments, payouts and marketplace flows.
• How to escalate suspicion, and the absolute prohibition on tipping off.
• Record keeping, data protection and confidentiality.
• Personal liability, and the protections available to those who raise concerns.

Training is delivered on joining, before the individual works unsupervised in a relevant role, and periodically thereafter. Additional training is delivered when obligations change, when a new product or market introduces new risk, and where a control failure or review indicates a gap.

Completion is recorded per individual, with dates and content version, and retained as part of our compliance records. Understanding is assessed rather than assumed, and non-completion is escalated to management. Training coverage and outcomes are reported to governance and are examined as part of the periodic effectiveness review described in our Compliance Effectiveness Review policy.