New-customer approval

Every application from KYC Core arrives in CDD Core already scored and screened. An officer reviews it, asks for anything missing, and proposes approval or refusal; the decision is signed on a route set by the risk level. At the Approver step one executive or a committee decides — from the e-mail on their phone, confirmed with Microsoft MFA. On approval the customer enters the book and the account opens by itself.

Who may do it: Maker (claim, review, propose) · Checker and Approver (sign on the route) · Compliance Officer (sign where the route names the role) · Head of Compliance and Internal Audit (read).

The application queue

• One list per institution, oldest submission first. Drafts stay hidden unless you choose to show them.
• Waiting on states the one fact the application is stuck on.
• Waiting for me shows only applications whose next step is your role.

The application file

The header shows the status, the risk level in force with its factors, and the sign-off route. Below it: what the applicant submitted (read-only), the identity results, the screening results, the documents, and the EDD Intel tab — so the officer sees adverse findings before proposing.

Steps

1. Maker opens the application from the queue or from your work and presses Claim.
2. Review the particulars, the identity results, the screening results and the documents. If something is missing, request information: the application becomes INFO_REQUESTED and the applicant edits in KYC Core.
3. When the readiness list is empty, press Propose approval — or Propose refusal, which is always possible.
4. Each signer on the route opens the application from their work and confirms the proposal or returns it with a reason. At the Approver step a committee votes instead — from the console or from e-mail.
5. On approval the customer is created in the customer book and the account opens.

Sign-off routes

Risk level	Route
Low · Medium	Maker → Checker
High	Maker → Checker → Approver (senior management)

High-risk customers go through EDD before the Approver signs.

The Approver: one executive or a committee

Each institution decides who signs the Approver step, and records that decision in CDD Core as an approval policy:

Policy	Who decides	Rule
Sole approver	One named executive, with an optional alternate	The alternate votes only inside a delegation window the executive opens (start, end, reason); the first vote decides
Committee	2 to 12 named members holding the Approver role	Approved at half, more than half or all of the members; one Return sends the case back to the Maker with its comment

• The policy is frozen on the case. When the Checker endorses, the policy in force — mode, members, rule — is copied onto the application. A later change never moves a case already waiting.
• Separation holds for every member. A member who was the Maker or Checker of the case cannot vote on it, and still counts in the base.
• Everyone sees the vote. The application file shows the committee, the rule, each vote with its channel and time. Every Approver sees the item in the work list as Waiting for the vote · 1 of 2; nobody picks it up — members open it to vote.
• Set as access administration. Only the System Admin saves a policy, each version with its approval reference, effective date and reason; Internal Audit sees every version.

Vote from e-mail, signed with Microsoft MFA

One e-mail per member, one tap, one fresh Microsoft sign-in with MFA. Nothing is recorded until all three line up.

Members do not need to open the console to approve. Each member who may vote receives one e-mail per case: reference, decision, customer name, risk level and why it reached the Approver, the Maker’s and Checker’s comments, and the votes so far — no identity number, no document, no attachment.

1. The member presses Approve or Return in the e-mail.
2. A fresh Microsoft Entra ID sign-in with MFA follows (Microsoft Authenticator, number matching or passkey).
3. CDD Core accepts the vote only when the sign-in is the member’s own account in the institution’s tenant, carries MFA, and happened after the button was pressed. The institution chooses one-tap confirm or automatic recording.

Opening the link alone records nothing — mail scanners such as Defender Safe Links can open it safely — and a forwarded e-mail cannot vote for someone else. The console itself signs in through the same Microsoft account with MFA, so a console vote and an e-mail vote carry one standard of evidence.

Approval by amount range

The same policy carries an amount band and an order. For decisions that carry an amount — a credit or trading limit, for example — the institution sets a ladder: a sole approver up to one band, a committee above it, a stricter quorum for the top band. The band is chosen from the amount on the case and frozen with it, so the ladder is configuration, not a change to the product.

Low-risk entities

Low risk is never chosen by an officer. When the engine finds that a customer may qualify under the closed list — a government agency, a listed company, a fund, and so on — the customer is treated as Medium until verified. The Maker sees the candidate rule, the declared fact and the evidence on file, records verified or not verified with the evidence reference, and the Checker approves. Low risk takes effect only then. See Risk scoring.

DA Dealer edition

• EDD triggers for a dealer are a high risk level plus dealer events: the light-brown mule tier, a wallet result marked possible, and a request for withdrawal class M or L. Dealer-event cases close at the Compliance Officer.
• Approval opens no service until the investor class, DA suitability, knowledge test and wallet registration are recorded. The customer stands as approved, service not opened.

What the system does or refuses

• No approval with an open readiness item. The button stays closed until the list is empty.
• Nothing else happens while a decision waits for signature, except confirming the destination account.
• A change after signing voids the signatures, and everyone signs again.
• An outstanding weak name hit blocks approval until the Checker or Approver acknowledges it. See Name screening.
• You cannot sign your own proposal.

Related

• KYC Core — signing and submission
• Name screening
• Roles and controls