1. Purpose of the Approval Workflow
SILO’s approval workflow supports:
Documented two-person sign-off
Escalation and oversight for high-risk clients and PEPs
Clear audit trail of due diligence decisions
Alignment with FATF and jurisdictional best practices
2. Default Approval Workflow Tiers
Tier 1 – Basic Due Diligence Confirmation
Applies to: All profiles where "Is Client" = Yes or No and CDD is required
Users: Data Entry or Compliance staff
Action:
Update Due Diligence Status to Complete or Needs Review
Tier 2 – Risk Rating Review
Applies to: Same as Tier 1
Users: Relationship Manager, Responsible Professional, or Compliance Manager
Action:
Set Active Date and Profile Status
Log Risk Score and Risk Rating
Approvers should only review profiles assigned to them or their backup
Define internal procedures for declining approvals
Tier 3 – High-Risk Profile Oversight
Applies to:
"Is Client" = Yes or No
AND either:
Risk Rating = High
OR Due Diligence Method = Simplified or Exempt
Users: Senior Management
Action:
Train reviewers on screening interpretation
Require clear, relevant approval notes
Establish guidelines for when to reject high-risk approvals
Note: A profile can trigger multiple tiers depending on risk configuration
3. Customizing Approval Workflows
Approval tiers can be configured using combinations of:
Client Status
Risk Rating
PEP Type
Due Diligence Method
Example Configuration Table:
Tier | Condition 1 | Condition 2 | Condition 3 |
Tier 1 | Is Client = Yes/No | CDD Required | – |
Tier 2 | Same as Tier 1 | – | – |
Tier 3 | Same as Tier 1 | Risk Rating = High | OR DD Method = Simplified/Exempt |
Tier 4 | (Deactivated) |
|
|
All high-risk profiles are assumed to require Enhanced Due Diligence (EDD)
4. Governance and Approval Requirements
Best Practice
Align approval workflows with internal written policies and procedures
Required
Formal written authorization is required to change approval tiers or scoring rules
Must be signed by a Director or Senior Manager
SILO Support cannot proceed without this approval
5. Submitting a Change Request
To request approval tier modifications:
Draft changes using SILO fields:
Client Status
Risk Rating
PEP Type
Due Diligence Method
Obtain approval from the Head of Compliance or a board-level authority
Submit request to: [email protected]
6. Related Resources
Refer to High-Risk Connections for guidance on when Tier 3 approval is applicable