1. Key SILO Reports for Periodic Reviews
SILO includes built-in reports to track and manage periodic review obligations:
Upcoming Periodic Reviews Report
Shows clients due for review this quarter or within a specified timeframe
Filterable by Office/Department
Approval and Periodic Reviews Report
Lists last, current, and next scheduled review dates
Audit Review Report
Captures completed review activity including date, reviewer, and notes
PEP Report
Displays review dates along with PEP indicators
Documents Report
Helps track if required review documents are uploaded or missing
2. Practical Guidance for SILO Users
Enter the Periodic Review Due Date
After assigning a risk rating, enter a review due date in accordance to your policies:
e.g., High-risk clients: Annually
e.g., Standard-risk clients: Every 2 years
e.g., Low-risk clients: Every 3 years
Ensures alerts appear on the dashboard when reviews are due
Log Every Review in SILO
Open the client profile
Choose Scheduled Periodic Review or Trigger Event Review
Enter summary in Review Notes (max 2,048 characters)
Upload supporting documents (e.g., IDs, ownership documents)
Click Save
Upload Updated Documents
Add any updated ID or due diligence documents during the review
Document Changes Promptly
If business activity, ownership, or other profile info has changed, update the profile immediately
Monitor Risk Score Changes
Review whether updates (address, service, ownership) have changed the risk score
A material increase may trigger a full review
3. Practical Guidance for Senior Management
Manage Client Expectations
Clients should be aware that documentation updates may be required throughout the relationship
Train Relationship Managers
Ensure staff understand:
Regulatory need for periodic reviews
How to manage clients who resist updates
Train Compliance Staff
Review team should follow internal SOPs when logging reviews
Leverage SILO Reports
Require periodic review reporting quarterly
Monitor for:
Overdue reviews
Missing review dates
Persistent bottlenecks
Consider remediation staffing or external support where necessary
Reassign During Absences
Reassign reviews during:
Extended leave
Resignation
Team changes
SILO Support can assist with bulk reassignment
Audit Periodic Review Quality
Confirm all reviews are logged and documents uploaded per policy
4. Key Areas to Focus On During Reviews
Customer Identification & Information
Re-verify identity, address, and contact details
Confirm PEP status for client and connections
Corporate: Review legal structure, signatories, and beneficial owners
Client Profile & Risk Assessment
Confirm client activity aligns with expected purpose
Check for:
New services requested
New industries or jurisdictions
Update the risk rating if risk score has changed materially
Screening & Monitoring
If screening is not enabled:
Record date of last external screen
Note any hits or adverse findings
Transaction & Communications Monitoring
Look for:
Unusual patterns
High cash transactions
Velocity inconsistent with client profile
Source of Funds Verification
Validate source of funds/wealth with new documentation as needed:
Audited statements
Salary evidence
Investment records
Record-Keeping
Retain records for minimum five years or per local regulatory standard
Escalation
If red flags appear:
Follow escalation protocols
Apply EDD
Consider filing a Suspicious Transaction Report (STR)
5. SILO Configuration Considerations
Ensure the following are configured in SILO:
Document Type: Periodic Review Note/Form/Report
Document Category: Periodic Reviews (optional but recommended)
6. Internal Policy & Procedures Considerations
Document the following policies internally:
Review Frequency
High-risk: Annually
Medium-risk: Every 2 years
Low-risk: Every 3 years
Trigger Events
Adverse media
New sanctions
Significant profile changes
Link to high-risk connections
Escalation Protocols
Increase to EDD if needed
Notify RM and obtain senior management sign-off
7. Next Steps & Support
Review your review schedule configuration
Confirm escalation logic for risk score changes
Request support for bulk updates or reassignment if needed
For assistance, contact: [email protected]