Enhanced Due Diligence (EDD)
Heightened measures applied to higher-risk customers and situations.
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.
Enhanced Due Diligence ("EDD") sets out the additional measures FLOWA PAY INC. applies where a business relationship or transaction presents a higher risk of money laundering or terrorist financing.
2. Triggers
EDD is applied to, among others, politically exposed persons, customers connected to higher-risk jurisdictions, unusually complex or opaque structures, and relationships that present a higher assessed risk.
3. Additional measures
EDD may include obtaining additional identification and beneficial-ownership information, establishing source of funds and source of wealth, senior-management approval to establish or continue the relationship, and enhanced ongoing monitoring.