Travel Rule & Transfer Information

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.

Transfer-of-information requirements, commonly called the travel rule, require prescribed information about the originator and the beneficiary to accompany a transfer and to be passed on to the next institution in the chain. This policy sets out how FLOWA PAY INC. meets those requirements for the transfers it is involved in.

Where a transfer falls within scope, we include and transmit the prescribed information, which typically comprises the name, address and account or reference number of the person or entity requesting the transfer, together with the beneficiary information required by the applicable rules. The precise data set is determined by the rules applicable to the transfer and by the requirements of the partner institution carrying it.

• Obtain and verify the required originator information before the transfer is sent, rather than reconstructing it afterwards.
• Include that information with the transfer and ensure it remains with the transfer through the chain.
• Retain the information for the period required by applicable law.
• Ensure the information is accurate and meaningful, and not generic placeholder data.

Transfers received with missing or incomplete required information are identified and treated as a risk indicator. Depending on the circumstances we request the missing information, delay or reject the transfer, or escalate the matter, and we consider whether the deficiency gives rise to suspicion requiring escalation under our Suspicious Transaction Reporting Policy. A pattern of deficient transfers from a particular counterparty is escalated in its own right.

Transfers at or above prescribed thresholds may also give rise to reporting obligations. Meeting the travel rule does not discharge those obligations, and the two are handled as separate requirements against the same transaction.

Originator and beneficiary information, and the record of what was transmitted, are retained in line with our Record Keeping Policy and are available for examination.