Step 5 — Sign-off
The final step is formal compliance approval. A compliance officer or authorised individual reviews the completed CDD pack, confirms the nature and purpose of the engagement, and records their decision. The audit trail locks on submission.
Pre-approval checklist
Confirm all of the following before proceeding to sign-off.
| Step | Status required |
|---|---|
| Client disclosure form | All fields saved |
| Risk assessment | Rating recorded; EDD completed if medium or high |
| VOI | All UBOs cleared |
| PEP and sanctions screening | All UBOs and the entity cleared |
| Nature and purpose of engagement | Confirmed and documented |
Recording the decision in SBOS
- Open the Sign-off section of the CDD run.
- Review the summary of all completed steps.
- Confirm the nature and purpose of the transaction or service being provided.
- Select Approve or Refer (refer to a more senior officer or for escalation).
- Add any notes relevant to the decision.
- Submit. The CDD run status updates to Approved and the audit trail is locked.
Who can sign off
Sign-off requires the CddRun.Approve permission. This is typically limited to compliance officers, principals, or other authorised signatories as defined in your firm's AML/CTF program. Contact your administrator if you do not have this permission.
What the audit trail records
SBOS retains the following for every sign-off. The record cannot be edited after submission.
| Item | Detail |
|---|---|
| Approver | Name and role at the time of approval |
| Date and time | Recorded as a UTC timestamp |
| Decision | Approved / Referred / Declined |
| CDD pack snapshot | Disclosure form, risk assessment, VOI, and screening results as they stood at approval |
| Notes | Any comments recorded by the approver |
If a correction is required after sign-off, create a new CDD run or record an addendum through an authorised user. The original record is preserved.
Ongoing monitoring and re-verification
Approval does not end your obligations. Set a review date based on the client's risk rating and monitor for changes in circumstances between reviews.
| Risk rating | Re-verify within |
|---|---|
| Low | 3 years from sign-off |
| Medium | 18 months from sign-off |
| High | 12 months from sign-off |
SBOS can generate reminders at the configured interval. Contact your administrator to enable re-verification reminders for your tenant.
Where a client's circumstances change materially between scheduled reviews — for example, a change in beneficial ownership, a new high-value transaction, or a PEP association — initiate a new CDD run outside the standard schedule.