Merchant Underwriting Policy

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 FLOWA PAY INC. assesses applicants, decides whether to onboard them, and sets the conditions under which they may process. Underwriting protects customers, acquiring and banking partners, the card schemes and Flowa Pay itself, and it determines what capability an approved merchant actually receives.

• Risk-based. Diligence depth is proportionate to assessed risk. A low-risk applicant with clear ownership is not subjected to enhanced measures for appearance's sake.
• Evidence-led. Decisions rest on verified information, not on assertions in an application form.
• Documented. Every decision records its rationale and the evidence relied upon, so it can be explained to a partner or examiner later.
• Early and honest. Where we cannot support a business, we say so at the earliest point rather than after a long process.

• The legal entity. Registration, status, registered address, trading names and the jurisdictions of establishment and operation.
• Ownership and control. The chain traced to the natural persons who ultimately own or control the business, together with directors and authorised signatories.
• The business model. What is actually sold, to whom, at what price, how it is delivered, and whether the live website matches what the application describes.
• Markets and methods. Where customers are, which currencies and payment methods are required, and whether a partner supports that combination.
• Volumes. Expected monthly volume, average transaction value and seasonality, assessed against the business model's plausibility.
• Processing history. Prior statements, prior terminations, and existing chargeback and refund performance where available.
• Financial crime risk. Sanctions, politically exposed person and adverse-media screening of the business and its associated individuals.
• Category. Whether the activity is prohibited, restricted or standard under our Prohibited & Restricted Activities policy.
• Consumer-facing terms. Whether refund, cancellation and delivery terms are published and adequate, and whether the billing descriptor will be recognisable.

An application results in one of four outcomes: approved; approved with conditions, such as a volume cap, a reserve, restricted methods or a review date; further information required; or declined. Conditions attached to an approval are stated explicitly rather than applied silently, and the merchant is told what would be needed to remove them.

Approval by Flowa Pay does not substitute for approval by an acquiring or payment partner, which applies its own underwriting. Both are required before the relevant capability is enabled.

Each approved merchant is assigned a risk rating that drives the depth of ongoing monitoring and the frequency of periodic review. Rating is reassessed on a trigger basis, including material change in volume or model, a change in ownership, a screening alert, deteriorating dispute performance, or adverse information coming to light.

Ongoing monitoring covers transaction patterns against the expected profile, chargeback and refund ratios, and periodic re-screening. See our Transaction Monitoring Policy.

Where risk changes materially we may apply additional controls, adjust settlement terms, require remediation, suspend processing, or terminate the relationship under the merchant agreement. Suspension is limited to what is necessary, and where the law permits us to explain the reason, we do.

On exit, funds are settled in accordance with the agreement, subject to any amounts withheld for disputes, refunds or other liabilities, and records are retained for the period required by law.

Questions about underwriting can be sent to hello@flowapay.co.