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.
This policy sets out how FLOWA PAY INC. detects and prevents fraud across onboarding and the transaction lifecycle.
2. Controls
We use adaptive fraud scoring, rules, velocity checks and device and behavioural signals, with case management and continuous tuning.
3. Response
Suspected fraud is investigated, blocked where appropriate, and reported as required, with learnings fed back into controls.