1. Purpose
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 Know-Your-Business ("KYB") Policy describes how FLOWA PAY INC. verifies corporate and other legal-entity customers and the individuals who own or control them.
2. Entity verification
We verify the legal existence and standing of the business using company registries and other reliable sources, and collect constitutional documents, registered details and the nature of the business.
3. Beneficial ownership & control
We identify beneficial owners (typically those holding or controlling a defined ownership threshold) and individuals exercising control, and verify their identities in line with our KYC Policy. Complex ownership structures are subject to Enhanced Due Diligence.
4. Business risk assessment
We assess the business's activities, expected transaction profile, geographies and sector against our risk appetite, and apply due diligence and monitoring proportionate to the assessed risk.