KYC Policy

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 Know-Your-Customer ("KYC") Policy describes how FLOWA PAY INC. identifies and verifies individuals before and during a business relationship, as part of our wider AML Policy.

We collect identifying information which may include full legal name, date of birth, residential address and nationality, together with government-issued identification. The exact requirements depend on the customer's risk profile and applicable law.

We verify identity using reliable, independent sources, which may include documentary verification, electronic identity verification and biometric checks through vetted verification providers. Verification is completed before a customer can transact, save for limited, risk-assessed exceptions permitted by law.

We keep customer information current and re-verify on a risk-sensitive basis and on trigger events, such as significant changes in behaviour or a screening alert.

Identification and verification records are retained in line with our Record Keeping Policy and applicable law.