It depends on the amount and the risk, but the rule is the same: the approver must hold delegated authority for that amount, be trained and currently certified to review it, and have had no part in preparing or requesting it. Above a threshold, or for new payees and changed bank details, two such people should approve.
Why is moving money treated differently?
Depth 4 covers actions that move money or are hard to undo: releasing a payment, refunding a customer, paying a claim, disbursing a loan. Once money settles, recovery is slow and sometimes impossible. Some actions sit even higher: reversing a settled payment on the firm's own rail is withheld from every agent at every depth by the platform.
An agent may be certified to move money within the customer's own limits. Above those limits, the action is held for a named person. Who that person is decides whether the hold is a control or a formality.
What makes a person a fit approver?
Four conditions, all at once:
- Delegated authority for the amount. The approver's authority must cover the payment. Splitting a payment to fit under a limit is a control failure, whether a person or an agent does it.
- Competence, shown and current. The approver must be trained to read the hold reason, the provenance of the instruction and the payee check. A business can choose to make approval rights depend on a current certificate.
- Independence from preparation. The person who requested the payment, set up the payee or set the agent's limits should not be the sole approver.
- Access to the evidence. The approval screen should show the instruction's source, the payee verification result and why the agent held it, not just an amount and a button.
Who approves what?
| Money movement | Typical first approver | When a second approver is needed |
|---|---|---|
| Supplier payment | Accounts payable approver | New payee, changed bank details, above threshold |
| Customer refund | Support or billing approver | Above refund limit, repeated refunds to one account |
| Claim payment | Claims handler | Above authority, payee not the policyholder |
| Loan disbursement | Loan officer or payout team | Above threshold, newly added account |
| Payroll release | Payroll administrator | Always, for the full run |
| Client withdrawal | Investment operations | New destination account, instruction not via secure channel |
Payments firms and insurers rank these roles in more detail; see which roles in payments need training and which roles in insurance need training.
Why are two people sometimes needed?
One person can be deceived, rushed or wrong. Two independent approvers reduce that risk, but only if the second one checks the evidence rather than the first person's name. The cases that justify two are those where fraud concentrates: new payees, recent changes to bank details, instructions arriving from outside the firm's systems, and large amounts. An external claim, such as an emailed invoice, cannot authorise a payment however many people approve it; it must be confirmed through a sealed or signed source first.
How to set this up in practice is covered in how to set up two-person approval for money moved by AI agents. Where an approver changes the amount or payee before approving, the rules on what edit and approve means apply.
What does it look like in practice?
Take a distributor whose agent prepares the weekly supplier run. Payments under 5,000 to established payees release at depth 4 within the customer's own limits. A 48,000 payment to a supplier whose bank details changed by email last week is held. The first approver, an accounts payable supervisor, sees the provenance flag, calls the supplier on the number from the original contract, and confirms the change was genuine. The second approver, the financial controller, checks the call note and the payee verification result before releasing. Both names, and the reasons, are filed in the record.
How should a business choose and prepare approvers?
Write down, per money movement, who may approve, up to what amount, and when two are needed. Train approvers before the agent prepares any payment. Hiring for these roles is covered in how to hire for AI operations roles, and the wider role map in AI agent skills by role. Some businesses use the Certified Pryme Operator credential from Pryme Intelligence Academy as the competence condition for depth 4 approval rights.
Questions people ask
Can an agent be the second approver?
No. A second agent shares the same blind spots as the first. The second approver must be an independent person.
Should managers approve everything above a threshold?
Only if they have the time and training to check the evidence. A manager who approves in batches adds a name, not a control.
What if the approver is on leave?
Name a deputy with equivalent authority and certification in advance. Never let held payments be released by whoever happens to be available.