1. Control environment
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.
We maintain a documented control environment with clear ownership, segregation of duties, approvals and reconciliations.
2. Monitoring
Controls are monitored and tested on a risk basis, with issues tracked to remediation and reported to management.