Glossary

Controls

What is segregation of duties?

Segregation of duties is the control principle that no single person can both create and approve a payment or a change to payment data, so that one compromised or coerced individual cannot complete a fraudulent transaction alone.

Also called separation of duties · SoD · dual control · maker checker

In payments this usually means splitting four capabilities: creating a vendor, changing bank details, entering a payment, and releasing it. Small finance teams often collapse these into one or two people, which is the condition most commonly cited in post loss reviews.

Dual control only works if the second approver is looking at something meaningful. Approving a payment batch without visibility into what changed since the last run is a signature, not a control.

The quiet failure is access that outlives the split. Someone keeps a banking token from a previous role, a shared login sits in a password manager, or an administrator can grant themselves an approval right and then use it. On paper the duties are separated; in the entitlement report they are not. Reviewing who can do what, at the system level, is the only way to see that.

Segregation of duties also has to survive the exceptions: month end, an absent approver, an acquisition, a vendor threatening to halt delivery. Write the break glass path down in advance, require a named second person for it, and log every use. An undocumented exception path is where the control is actually spent.

Common questions

Split the highest risk pair first, changing bank details and releasing payments, and use the bank's own approval tiers to enforce a second approver even when only two people are available.

Dual approval is one implementation of it. Segregation of duties also covers who can create records and who can execute, not only who signs off.

Changing a vendor's bank details and releasing payments to that vendor. When one person holds both, a single deception completes the whole fraud.

Define the exception path in advance with a named alternate approver, require the same verification evidence, and log each use so exceptions can be reviewed rather than repeated quietly.

On a fixed schedule and again after every role change, because separated duties on paper are frequently rejoined by leftover access in the banking portal or the accounting system.

Sources and further reading

Citing this entry? Cite as Coffr, LLC and link to https://getcoffr.com/glossary/segregation-of-duties.

Read the longer research behind this in Blog, or browse the full glossary.

Disclosures

  1. Coffr, LLC carries insurance for its own benefit. That insurance does not cover you, your payments or your funds, and Coffr does not guarantee any payment. Coffr does not hold or transmit customer funds. See the Terms of Service.
  2. "Verified" means the identity, business and bank account checks shown passed on the date shown. A verification confirms who you're paying at that time. It doesn't guarantee that a payment will reach the intended recipient.
  3. Coffr records a cryptographic fingerprint of each verification on a public ledger run by independent organizations. Fingerprints contain no names, bank account numbers or tax IDs, and they can't be changed or deleted.
  4. Sources: ACH volume, Nacha 2025 ACH Network volume; online crime losses, FBI IC3 2025 Internet Crime Report.