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.
We screen customers and beneficial owners for adverse media that may indicate financial crime, sanctions or reputational risk.
2. Process
Screening is performed at onboarding and periodically thereafter. Relevant results are investigated and, where material, escalated and factored into the risk assessment.