What is SILO?

SILO is an easy-to-use application that enables you to archive and retrieve your client due diligence materials; to risk-rate and monitor your clients; to run the necessary reports on them; and to train your staff. It is, therefore, the ideal application to meet all your AML obligations.

With SILO you can identify higher-risk clients, see which clients still have outstanding due diligence, learn when clients are due for monitoring or have expired documentation on file and satisfy yourself that all your staff have been adequately trained. Additionally, immediately upon log-in, SILO provides you with critical statistics on your AML compliance obligations.

In this economy, how are we able to justify spending money on a new compliance application?

SILO’s licence fee is very inexpensive, and one of its main purposes is the long-term benefits it provides. It can eliminate additional overhead as your business grows, or actually increase revenues when you no longer feel you have to turn away business for fear of taking on too much risk.

SILO should also help you avoid falling victim to fines, increased inspection or negative reputational issues if your business fails to meet proper compliance standards.

As with any good investment, whatever small upfront cost there may be should pay for itself many times over as time goes by.

Is SILO secure?

It’s as safe as your system is now.
SILO and its data sit on your server behind your firewall, and neither should be accessible to anyone except the users you assign.

What distinguishes SILO from other AML systems?

Many features do, including:

  • Clear visuals at log-in provide senior management with immediate compliance status updates.
  • Dashboards for compliance staff show outstanding due diligence and client monitoring due.
  • Multiple permission levels allow greater access across your business, while protecting data integrity.
  • Customisable data fields are designed to accommodate your particular business and client base.

Built primarily with the user in mind, SILO is simple to learn and use. Reports are easy to produce, and there’s no longer any need to rely on spreadsheets generated and/or maintained by multiple staff members.

Training sections allow you to customise your own training program, which staff can take at their convenience.

Learning new software can be time-consuming, especially if it’s complicated. Is SILO any different?

It is. Although our standard license agreement provides for up to 20 hours of online training, we’ve never had a licensee need more than 3 hours. This is because we put a high priority on ease of use and intuitive design.

As former compliance professionals, we know what it is like to spend hours training new users who never “get it” and avoid using it again. SILO’s user-friendliness has eliminated that problem.

We need something that provides a means for us to undertake real risk analysis. Can SILO help?

Yes. SILO provides customisable fields for risks and risk-mitigators to allow you to perform your own risk analysis with confidence in the outcome.

For the more mechanical requirements of AML regulation, conventional “box-ticking” features are also available.

We sometimes need to collect and store information on businesses and trusts as well as individuals. How can SILO help with that?

SILO is flexible and comprehensive enough to handle data collection on trusts, partnerships and corporate entities and their “associated individuals” like members, partners, shareholders, directors and officers.

Additionally, for trusts, SILO collects and stores data on all relevant parties, including settlors, trustees and beneficiaries.

Our group has offices in several jurisdictions, each of which has different AML standards. We don’t want to ask for more due diligence than necessary from clients in one jurisdiction or not enough in another, and we don’t want a system that assumes that all jurisdictions have the same due diligence requirements. How can SILO help us?

SILO includes a unique due diligence grading system which allows you to establish a required “grade” for each of your offices. That means you can fix an appropriate level of due diligence on existing clients for one jurisdiction as opposed to others.

We have highly-regarded clients who we know are low-risk and yet may have a lower due diligence grade because they don’t necessarily “tick all of the boxes” in most AML programs. We don’t want to trouble them for minor items like copies of utility bills. Can SILO help?

Yes. We’ve encountered this problem in the past and wanted to make sure we built a solution for it. This is why SILO gives you the final say in assigning an appropriate risk rating and due diligence status. You can also add any comments regarding the assigned risk rating and due diligence status in the Notes section of the client’s profile so that your colleagues will be aware of any non-standard procedures you may have signed off on.

While we keep track of our Politically Exposed Persons, our regulator always seems to want more information than we have. Can SILO help?

Yes. We showed SILO to several regulators and designed its PEP report based on their comments. An individual’s profile page now includes a PEP notes section where you can explain why you regard someone as a PEP. The PEP report includes the PEP’s nationality, when they were last monitored and are next due for monitoring, the senior manager who approved the PEP relationship, and the PEP notes.

Keeping track of expiring documents such as passports is creating a lot of work for us. Can SILO help?

Yes. When you upload any document into SILO, you can enter an expiry date. You are notified of your clients with expired documents at log-in. Our customers use this feature to keep track of expiry dates of passports, business licenses and the like.

We want to know more about our clients than just basic data such as nationality and date of birth. Can SILO help?

Yes. SILO allows you to capture any other helpful information, such as connected industries and/or businesses and other relevant jurisdictions.

A “Notes” section also provides space for any additional data you might think is important.

With so many levels of staff, a “one-size-fits-all” compliance training program isn’t working for us. Can SILO help?

Yes. SILO lets you assign training by user level. You can also upload your own training videos, quizzes and documents. SILO then tracks and records when a staff member has completed training and what his/her results were.

This makes complying with statutory training obligations easier than ever.

We can’t get a handle on who does what within our compliance staff, or even how well they do it. Can SILO help?

Yes. You can assign an individual compliance staff member to each of your clients. You can then run reports on that staff member’s overall workload, to use in his/her evaluations and general supervision.

We already have a system but would like to convert to SILO. How are we able to migrate our system’s data into SILO?

One of our best features is how easy it is to transfer data from an old system to SILO, using an Excel or CSV file import.

All we need is to start with is to talk to your IT team. Then we will build a plan to migrate your data to SILO. It’s that simple.

Who owns and operates SILO?

SILO is owned by SILO (BVI) Ltd, a British Virgin Islands company jointly owned by Kimberly Smith and Charles Jennings (details below). Charles is its sole director.

SILO (BVI) Ltd licenses SILO to SILO Compliance Ltd (“SCL”), a Cayman Islands company wholly owned and controlled by Charles. SCL sub-licences it to customers.

IP Launch Services LLC, a Colorado LLC wholly owned and controlled by Kimberly, provides marketing, development, etc, services to SCL in relation to SILO.

Charles Jennings retired in 2009 as worldwide managing partner of an international law firm (148 lawyers worldwide) in the Cayman Islands, where he still lives and works. During his time with that firm (1986 – 2009), he also lived in the British Virgin Islands for a year to open and manage a new office there, and managed the firm's London office for two years before returning to the Cayman Islands to manage the firm globally. He was president of the Cayman Islands Law Society from 2001 to 2012, and is presently chairman of the Cayman Islands Financial Services Legislative Committee and a commissioner on its constitutional Judicial and Legal Services Commission.

Charles is a UK citizen with Caymanian status, and apart from those overseas postings has lived in the Cayman Islands for 30 years.

Kimberly Smith was the head of compliance and MLRO at the London office of the same firm. She spent several years there working on front-line AML compliance, and it was on the basis of that hands-on practical experience that we conceived SILO.

Kimberly is an American citizen based in Longmont, CO, from which she operates IP Launch Services LLC.

Kimberly received her Graduate Diploma in Anti Money Laundering from the International Compliance Association and her Bachelor’s in Finance from Golden Gate University in San Francisco.