Enhanced Due Diligence (EDD)

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.

Enhanced Due Diligence ("EDD") sets out the additional measures FLOWA PAY INC. applies where a business relationship or transaction presents a higher risk of money laundering or terrorist financing.

EDD is applied to, among others, politically exposed persons, customers connected to higher-risk jurisdictions, unusually complex or opaque structures, and relationships that present a higher assessed risk.

EDD may include obtaining additional identification and beneficial-ownership information, establishing source of funds and source of wealth, senior-management approval to establish or continue the relationship, and enhanced ongoing monitoring.