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Show me your decision: counterparty approvals you can reconstruct months later

Who signed off on that counterparty? If answering takes an afternoon of searching inboxes, that is a problem. Most compliance teams still approve high-risk counterparties over email and spreadsheets: the analyst flags it, the MLRO signs off somewhere, and six months later nobody can reconstruct who approved what, or why.

· 2 MIN READ · BY THE KYCK DESK


Scattered approvals are not evidence

An approval given in a reply to a forwarded email proves very little. It does not show what the approver saw, which version of the file it was, or whether the counterparty changed afterwards. When a regulator asks you to show your decision, a thread of messages is something you have to explain, not something that explains itself.

What a defensible approval record contains

  • Who approved, and at which level of the chain.
  • When, to the minute.
  • Why, in the approver's own words, at least wherever the decision departs from the normal path.
  • What it rested on: the verification, ownership and screening results in the file at that moment.

How KYCK records it

Approval in KYCK runs through tiers you configure, in the order you set. Each decision is stored against the counterparty with the approver, the tier, the time and their comment. Sending a file back requires a written reason. An administrator can step in for a tier, but only with a written justification, and the record marks that approval as an override so it can never pass as a normal one.

The same file holds the business verification, the ownership map and the sanctions, PEP and adverse media results, with a timestamped audit trail. When a counterparty resubmits changed details, the approval starts again from the first tier, so an old sign-off never covers new information.

Due diligence is not only the screening. It is being able to prove who made the call, and on what. For who should sit in each tier, see why approval should never be a one-person job.

Sources

Related reading

Who signed off on your last counterparty?Counterparty onboardingDue diligence checklist

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