Customer Due Diligence (CDD)

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.

This procedure sets out the Customer Due Diligence ("CDD") measures FLOWA PAY INC. applies to identify and understand its customers, as part of the AML Policy.

We apply CDD when establishing a business relationship, when carrying out occasional transactions above applicable thresholds, when we suspect money laundering or terrorist financing, and when we doubt the veracity of previously obtained information.

CDD includes identifying and verifying the customer (and, for entities, beneficial owners and controllers), understanding the purpose and intended nature of the relationship, and conducting ongoing monitoring. See KYC and KYB.

We keep information current and scrutinise transactions to ensure they are consistent with our knowledge of the customer, their business and risk profile.