Prohibited & Restricted Activities

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 policy sets out the business activities that FLOWA PAY INC. does not support, and those that may be supported only subject to additional diligence, conditions or partner approval. It exists so that applicants get a clear answer early rather than after a long onboarding process, and so that acquiring and banking partners can see our acceptance posture.

We do not knowingly support, and will not onboard, businesses engaged in:

• any activity that is unlawful in the jurisdictions in which it is carried on, or that is designed to facilitate unlawful activity;
• money laundering, terrorist financing, proliferation financing or sanctions evasion, including structuring to avoid reporting thresholds;
• business with individuals or entities subject to applicable sanctions, or located in jurisdictions subject to comprehensive sanctions;
• child sexual abuse material, human trafficking, forced labour or any exploitation of minors;
• the sale of illegal drugs or controlled substances, or paraphernalia marketed for their use;
• trade in illegal weapons, explosives or controlled military items;
• trade in protected wildlife, endangered species or stolen cultural property;
• counterfeit goods, pirated media or infringement of third-party intellectual property;
• fraudulent, deceptive or predatory schemes, including pyramid and Ponzi structures, chain referral schemes, and "get rich quick" or guaranteed-return offerings;
• unlicensed financial services, including deposit-taking, lending, money transmission, securities dealing or insurance where a licence is required and not held;
• unlicensed gambling, and gambling in any market where it is not lawfully permitted;
• sale or purchase of personal data, credentials, or access to compromised accounts or systems;
• services designed to conceal the origin, ownership or destination of funds.

The following are not prohibited outright, but are supported only where the business holds any licence its activity requires, passes enhanced due diligence, and where an acquiring or payment partner will accept the category. Acceptance is decided case by case:

• licensed gambling and gaming;
• virtual-asset businesses and related services;
• licensed lending, credit and debt-related services;
• money services businesses, remittance and currency exchange;
• pharmaceuticals, nutraceuticals and health claims;
• adult content and services lawful in the markets served;
• tobacco, vaping, alcohol and age-restricted products;
• firearms and related accessories, where lawful and licensed;
• high-value dealers, precious metals, stones and art;
• travel, events and other businesses with long delivery lead times;
• subscription and continuity billing models;
• charities, political organisations and crowdfunding;
• businesses marketing in a way that attracts elevated dispute or regulatory risk.

Category alone is rarely the whole answer. Assessment considers the actual business model, the markets served, the licence position, the delivery and refund model, expected dispute exposure, ownership and control, and whether an acquiring or payment partner will support it. See our Merchant Underwriting Policy.

Availability also depends on jurisdiction, underwriting and the applicable payment or acquiring partner. A category supported for one merchant in one market may not be supported for another.

Merchants must notify us before materially changing their business model, the products sold, the markets served or their ownership. Undisclosed changes are a breach of the merchant agreement, and processing activity inconsistent with the approved business model may result in suspension, settlement being withheld pending review, or termination.

If you are unsure whether your activity is supported, ask before you apply. Send the details to hello@flowapay.co and you will get a direct answer.