Last Updated: 4th February 2026

1. PURPOSE

This Sanctions Compliance Statement (the “Statement”) outlines Flowapay Inc.’s (“Flowapay”, “we”, “us”) commitment to complying with applicable economic sanctions laws and regulations.

Flowapay maintains a risk-based sanctions compliance framework designed to prevent the provision of services to sanctioned persons, entities, jurisdictions, or activities.

Flowapay operates exclusively as a business‑to‑business Money Services Business (MSB) and is not a bank, electronic money institution, or consumer‑facing payment provider.

2. APPLICABLE SANCTIONS REGIMES

Flowapay screens customers, counterparties, and relevant transactions against applicable sanctions lists, including but not limited to:

• United Nations Security Council sanctions lists;
• European Union consolidated sanctions list;
• United Kingdom sanctions lists;
• Canadian sanctions lists (including those administered by Global Affairs Canada);
• Any other sanctions regimes applicable to Flowapay’s operations.

In addition to formal sanctions regimes, Flowapay considers guidance issued by the Financial Action Task Force (FATF), including jurisdictions identified as high-risk or under increased monitoring, as part of its risk assessment and enhanced due diligence processes.

3. SANCTIONS CONTROLS

Flowapay’s sanctions controls include, at a high level:

• Screening of merchants, beneficial owners, directors, and authorised representatives at onboarding;
• Ongoing sanctions screening where appropriate;
• Transaction monitoring designed to identify potential sanctions exposure;
• Escalation and review procedures for potential sanctions matches.

Sanctions screening is conducted using reputable third-party screening tools and supplemented by manual review where necessary.

4. ESCALATION AND RESPONSE

Where a potential sanctions match or exposure is identified:

• The matter is escalated to the Compliance function;
• Services may be restricted, suspended, or declined pending review;
• Flowapay takes appropriate action in accordance with applicable law, including reporting where required.

Flowapay does not knowingly process transactions or provide services that would violate applicable sanctions laws

5. GOVERNANCE AND OVERSIGHT

Sanctions compliance is overseen by Flowapay’s Compliance function and forms part of Flowapay’s broader AML/CTF and financial crime compliance framework.

Policies, procedures, and controls are reviewed periodically to ensure continued alignment with applicable sanctions requirements.

Flowapay’s sanctions compliance obligations apply solely within its own regulatory perimeter and do not extend or confer the regulatory permissions of any banking or payment partners.

6. LIMITATION

This Statement is provided for transparency purposes only. It does not create contractual obligations beyond those set out in Flowapay’s Merchant Agreement or AML policies.