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Segregation of duties when your finance team is small

By the EMPOBase team · · 4 min read

Short answer

Segregation of duties means no one person controls a whole transaction from start to finish. In a small team, split four tasks: authorizing, recording, handling money and reconciling. If you cannot give each task to a different person, give at least two of them to different people, add an outside review, and keep a record of every decision so someone else can check.

Key points

  • Four tasks should not sit with one person: authorize, record, handle money, reconcile.
  • When you lack staff, move tasks to program managers, a board treasurer or an outside reviewer.
  • Compensating checks, such as a monthly review by a second person, reduce risk when you cannot split a task.
  • Write down each exception, who agreed to it and when it will be reviewed.

What is segregation of duties?

Segregation of duties is a simple rule: the person who starts a payment is not the person who approves it, and neither of them is the person who checks the bank statement. The aim is that one mistake or one dishonest act cannot pass through the whole process unseen.

Auditors and donors look for it because it is cheap, and it removes most of the easy routes to fraud and error. It does not assume anyone is dishonest. It protects honest staff, too, because it shows who did what.

Which tasks should be kept apart?

Think of four tasks in any money process:

  1. Authorize. Decide that the spend may happen.
  2. Record. Enter it in the books.
  3. Handle. Hold or release the money, or the cheque, or the payment file.
  4. Reconcile. Compare the books to the bank statement.

One person doing all four can hide a problem forever. One person doing any two can often still do harm, for example authorizing and handling, or recording and reconciling.

What can you do with only two or three people?

You will not always have four people. These workarounds are common and acceptable if you write them down:

ProblemWorkaround
One finance officer records and prepares paymentsA manager approves each payment and reviews the payment list before release
The same person reconciles and recordsA second person, such as the director or a board treasurer, reviews the reconciliation each month and signs it
The only approver is the budget holderA second approver from another team signs above a set amount
One person holds petty cash and approves top-upsThe manager counts the cash at random times and signs the count
No one to review at allAn outside accountant or a volunteer reviewer checks a sample of entries each quarter

These are called compensating checks. They do not remove the risk, but they make it visible.

Who else can take a task?

Look beyond the finance office. Useful second people include:

  • A program manager, who confirms that the work was done before payment.
  • A country director or executive director, who approves above a limit.
  • A board treasurer, who reviews bank reconciliations and unusual items.
  • An outside accountant, who checks a sample on a schedule.

Keep roles clear. The program manager confirming delivery should not also be the person who raised the request. Our guide to payment request approvals shows how to set that up.

What rules help most?

Four rules cover most of the risk:

  • The requester never approves their own request.
  • One person never approves two steps of the same payment.
  • The person who reconciles the bank does not record the transactions or release payments.
  • Changes to payee bank details are confirmed by a second person, by a call to a known number.

Add a rule for leave. When the approver is away, a named delegate acts for a set period. The delegate is never the requester.

How do you handle an exception?

Sometimes you truly cannot split a task, for example during a staff gap. Treat it as a short, recorded exception:

  1. Write what task is combined and why.
  2. Name a second person who will review the result.
  3. Set an end date.
  4. Record who agreed.

A written exception is a control. A silent one is a finding waiting to happen. Review exceptions at your monthly finance meeting, and close them when the gap ends.

What should you record?

For each approval, keep the approver’s name, role, date and decision, plus a note when something is unusual. For each reconciliation, keep the preparer, the reviewer and the sign-off date. An auditor will ask for these. If you can produce them in minutes, you have shown the control works.

Where EMPOBase fits

EMPOBase applies some of these rules for you inside the workspace. In Payment Requests and Procurement, the requester cannot approve their own request and one person cannot approve two steps of the same request. Each decision records who acted, when and any note. Roles and permissions control who can approve and who can see what. EMPOBase does not make bank transfers, so the person who releases the payment and the person who checks the bank statement remain a matter for your own process. See the platform overview or ask for a walk-through.

Questions people ask

What is the minimum split for a two-person finance team?

One person authorizes and reviews. The other records and prepares payments. Neither reconciles the bank alone; the reviewer checks the reconciliation each month.

Can a director act as the second person?

Yes, for authorizing and for reviewing the reconciliation. The director should not also record transactions or prepare payments.

Does this apply to petty cash?

Yes. The person who holds the cash should not be the person who approves top-ups or counts the box alone.