Could this work/have worked as well...
As a sequel to Hannibal rather than a prequel to TSotL?
I think the only big inconsistencies are the opening scene (Hannibal would have had to use an alias if he was able to be so visible in public at all and the news accounts in the credits would be different) and Chilton being alive (unless he always somehow survived the end of Silence). Otherwise I'm not sure a lot indicates that the film is before Silence or is set in the '80s.