AML / KYC Disclosure

Flowa Pay Inc., operator of Xchangely, is registered as a Money Services Business with FINTRAC (No. C100000902) and operates an anti-money-laundering and anti-terrorist-financing (AML/ATF) compliance program under Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and its regulations.

• Identity verification (KYC). Every customer must verify their identity before transacting. We verify identity using government-issued identity documents, proof of address, and electronic and database checks, including sanctions and watchlist screening.
• Ongoing monitoring. We monitor transactions and business relationships on a risk basis to detect activity that is unusual or inconsistent with what we know about a customer.
• Source of funds. In some circumstances we are required to ask you for information or documents about the source of your funds. See "Why we ask for Source of Funds."
• Sanctions. We screen customers against applicable sanctions and listed-entity sources and comply with any directives in force. We do not deal with sanctioned persons or prohibited jurisdictions.
• Reporting. Where the law requires, we report certain transactions and any suspicious activity to FINTRAC. We are legally prohibited from telling a customer that a suspicious-transaction report has been or may be made.
• Record-keeping. We create and retain the records the law requires, for at least the period the law prescribes.

Provide accurate and complete information, respond to verification and source-of-funds requests, and use Xchangely only for lawful purposes and for your own account. We may decline, delay, suspend or report activity, and freeze funds, where we are required to do so by law.

Compliance-related questions: support@xchangely.io.