Payment Approval Hierarchy

Purpose

This document establishes the Bank's payment approval hierarchy, defining the authorisation levels, thresholds, and escalation requirements for all payment transactions. Adherence to this hierarchy is mandatory for all staff involved in payment initiation, processing, and approval.

Scope

This policy applies to all payment types processed through the Bank's Core Banking System (CBS), SWIFT Alliance, and any ancillary payment platforms, including domestic transfers, international wire transfers, bulk payments, standing orders, and direct debits.

General Principles

All payments require at least one level of authorisation before execution.
No individual may approve a payment that they themselves initiated (maker-checker principle).
Approval authority is granted based on role, seniority, and delegated limits as recorded in the Bank's Authorised Signatory Register.
Temporary delegations of approval authority must be documented in writing and approved by the delegator's line manager.
All approvals are logged in CBS with timestamps and user identifiers for audit trail purposes.

Approval Thresholds — Domestic Payments

Threshold (USD)	Approver(s)	Turnaround Time
Up to 10,000	Operations Officer (Level 1)	30 minutes
10,001 – 50,000	Operations Officer + Supervisor (Level 2)	1 hour
50,001 – 250,000	Supervisor + Operations Manager (Level 3)	2 hours
250,001 – 1,000,000	Operations Manager + Head of Payments (Level 4)	4 hours
Above 1,000,000	Head of Payments + Chief Operating Officer + Compliance (Level 5)	Same business day

Approval Thresholds — International Payments

Threshold (USD equivalent)	Approver(s)	Turnaround Time
Up to 25,000	Payments Officer (Level 1)	1 hour
25,001 – 100,000	Payments Officer + Team Lead (Level 2)	2 hours
100,001 – 500,000	Team Lead + Payments Manager (Level 3)	4 hours
500,001 – 2,000,000	Payments Manager + Head of International Payments (Level 4)	Same business day
Above 2,000,000	Head of International Payments + COO + Compliance Officer (Level 5)	Same business day (prior to cut-off)

Approval Thresholds — Bulk Payments

Total Batch Value (USD)	Approver(s)
Up to 100,000	Bulk Payments Officer + Supervisor
100,001 – 500,000	Supervisor + Bulk Payments Manager
Above 500,000	Bulk Payments Manager + Head of Payments + Compliance review

Special Conditions

High-Risk Jurisdictions

Payments to or from jurisdictions designated as high-risk by the Financial Action Task Force (FATF) or the Bank's internal risk classification require an additional Compliance sign-off, regardless of value. The Compliance team must review and clear such payments within four (4) hours of submission.

Politically Exposed Persons (PEPs)

Payments involving accounts flagged as PEP-related require approval one level above the standard threshold. For example, a domestic payment of USD 30,000 involving a PEP account requires Level 3 approval instead of the standard Level 2.

Emergency Payments

In exceptional circumstances, the Head of Payments or the Chief Operating Officer may authorise an expedited payment outside the standard hierarchy, provided that a retrospective review and documentation are completed within 24 hours.

Monitoring and Compliance

The Internal Audit department conducts quarterly reviews of payment approval compliance. Any breaches of the approval hierarchy are reported to the Operational Risk Committee and may result in disciplinary action.