PEP Screening
Identifying and managing politically exposed persons.
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 procedure describes how FLOWA PAY INC. identifies politically exposed persons ("PEPs"), their family members and close associates, and applies appropriate risk-based measures.
2. Identification
We screen customers and beneficial owners for PEP status at onboarding and periodically thereafter using reputable data sources.
3. Risk management
PEP relationships are subject to Enhanced Due Diligence, senior-management approval, establishment of source of funds and wealth, and enhanced ongoing monitoring.