Sanctions Screening

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. screens customers and, where relevant, transactions and counterparties against applicable sanctions lists to prevent prohibited dealings.

We screen at onboarding and on an ongoing basis, and we re-screen when lists are updated. Screening covers names, and where available, dates of birth, nationalities and other identifiers to reduce false positives.

Potential matches are investigated by trained staff. Confirmed matches are escalated, the relevant activity is blocked or rejected, and reports are made where required by law. We do not process transactions that would breach applicable sanctions.