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.
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.