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 framework describes how FLOWA PAY INC. identifies, assesses, controls and monitors the risks arising from its business.
2. Risk taxonomy
We categorise risk across financial crime, operational, technology and information security, conduct, regulatory, credit and settlement, and reputational risk.
3. Risk appetite & governance
Risk appetite is set and overseen by senior management, with defined ownership, controls and reporting for each risk category.