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. establishes the source of funds ("SoF") for transactions where required on a risk-sensitive basis.
2. Evidence
Depending on risk, we may request documentary or electronic evidence of the origin of funds, such as records of the underlying activity generating them.
3. Escalation
Where SoF cannot be satisfactorily established, we may decline, delay or exit the relationship and consider reporting obligations.