Regulators in jurisdictions such as the Cayman Islands, the British Virgin Islands, and the Channel Islands require that business relationships assessed as high-risk must be reviewed and approved by senior management. It is a legal and regulatory requirement. SILO provides a system-driven, auditable workflow that ensures these approvals are captured, documented, and reported accurately and consistently.
The Approvals feature in SILO provides a structured and auditable way to document who approved a profile, when the approval took place, and any notes or comments provided. This functionality ensures compliance with regulatory expectations that high-risk business relationships be explicitly approved by senior management.
Every approval is automatically recorded in the Activity Log, giving firms a defensible trail of decisions made and by whom.
How Approvals Work
Each profile (e.g. individual, entity, or trust) in SILO can have one or more approval tiers, depending on the organization’s configuration.
SILO supports up to five approval tiers, though most firms typically utilise three, with the third tier only required for high-risk profiles.
Typical configurations include:
Tier 1 – Compliance Officer or Analyst
Tier 2 – Senior Compliance Officer or Risk Manager
Tier 3 – Senior Management or Board-Level Approval (for high-risk cases)
(Tiers 4 and 5 are available for firms that require more complex multi-level approval structures.)
Once the required number of approvals is met, the record’s approval status indicator turns green. If an approval is still pending, it will remain yellow or red, depending on configuration.
Approvals and Risk Ratings
The number of approvals required depends on the risk rating of the profile, most instances are set up as follows:
Low or Medium Risk: requires Tier 1 and Tier 2 approvals.
High Risk: requires Tier 1, Tier 2, and Tier 3 approvals.
SILO dynamically updates the required approval levels whenever a profile’s risk rating changes.
For example:
If a profile is upgraded from Medium to High risk (e.g. during a periodic review or due to a trigger event such as adverse media or new PEP status), the system will automatically mark the record as requiring an additional Tier 3 approval.
Once that approval is logged, the status updates to “Complete” and the change is captured in the Activity Log.
Logging an Approval
Users assigned to a given tier can add their approval without entering edit mode:
Scroll to the bottom of the profile and click Add Approval.
Select the applicable approval tier.
Optionally, backdate the approval if documenting a historical decision.
Enter comments or notes, such as “Proceed – reviewed and approved.”
Click Save.
SILO records:
The name of the approver
The approval date
The tier level
Any comments entered
All entries appear in the profile’s Activity Log and feed into the Approvals & Periodic Reviews Report, providing a clear, visual overview of pending and completed approvals.
Configuration
Each SILO instance can be tailored to reflect the firm’s internal approval policies:
Define the number of approval tiers required (up to five).
Assign specific users or roles to each tier.
Enable or disable the Approval Guidance Flag, which visually indicates if a record meets its required approval level.
If your firm has not yet configured its approval tiers, reach out to the SILO team to have this set up. Configuration ensures approvals match your policy and risk framework.
Behind the Scenes (Logic Summary)
SILO checks the profile’s risk rating and approval tier configuration.
Each profile’s approval status is recalculated whenever:
The profile’s risk rating changes.
An approval is added or removed.
A “Complete” status (green) appears once all required tiers for that risk level are fulfilled.
Approvals are immutable audit records—each includes timestamp, user, and notes for accountability.
Benefits
Eliminates the need for email or paper-based sign-offs.
Ensures consistent and auditable approvals across the organization.
Reduces time spent tracking approval evidence.
Provides real-time visibility via dashboards and reports.
Enhances compliance assurance that all high-risk profiles have senior management approval.