PEP Screening
Identifying and managing politically exposed persons.
1. Purpose
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.
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.