1. Purpose
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.
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.