Suspicious Transaction Reporting

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 how employees and systems escalate suspicion, how reports are made to the Financial Transactions and Reports Analysis Centre of Canada ("FINTRAC"), and the strict confidentiality that attaches to that process. It applies to everyone working for or on behalf of FLOWA PAY INC..

Every employee and contractor has a personal responsibility to escalate activity they know, suspect, or have reasonable grounds to suspect is related to the commission or attempted commission of a money-laundering or terrorist-financing offence. Suspicion is escalated internally to the compliance officer; it is never dismissed informally, and it is never the individual's decision whether a report is filed.

Escalation requires no proof and no certainty. The threshold is reasonable grounds to suspect, which is lower than reasonable grounds to believe and far lower than evidence.

Where our activities engage a reporting obligation under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its regulations, we make the prescribed reports within the prescribed timeframes. These include, as applicable to the activities we carry on:

• Suspicious Transaction Reports, submitted as soon as practicable after the measures that established reasonable grounds to suspect have been completed;
• Terrorist Property Reports, where we know property is owned or controlled by or on behalf of a terrorist group or listed person;
• Electronic Funds Transfer Reports, for prescribed international transfers at or above the reporting threshold;
• Large Cash and Large Virtual Currency Transaction Reports, where we carry on activity that engages those obligations.

Related transactions conducted within a 24-hour period are aggregated where the rules require it, and we do not permit transactions to be split to avoid a reporting threshold.

Where a customer asks why an account has been restricted, responses are limited to what may lawfully be said, and the compliance officer determines what that is.

The compliance officer determines whether a report is required, and that decision is documented whether or not a report is filed. The rationale, the information considered and the timing are all recorded, because the quality of a decision not to report is examined as closely as a decision to report.

No one who escalates a concern in good faith will suffer detriment for doing so, regardless of the outcome. Concerns about the handling of an escalation can be raised under our Whistleblowing Policy.

Escalations, decisions, reports filed and supporting material are retained for the period required by applicable law and are available to FINTRAC and to law enforcement on lawful request.