A bank balance is not controlled because the CFO can see it. Every account and payment route needs independent reconciliation and access governance.
Treasury lead and CFO
Daily monitoring, monthly certification
Maintain the bank-account register.
Bank statements and confirmations.
Maintain a complete bank-account register including current, deposit, escrow, card, payment gateway and dormant accounts. Identify signatories, tokens, limits and purpose.
Bank reconciliation should match ledger and bank records and explain outstanding cheques, deposits, fees, interest, reversals and unidentified entries by age.
Payment preparation, approval and release should be separated. Beneficiary changes and bulk files need independent verification before release.
| Control | What it covers | Operating rule |
|---|---|---|
| Account governance | Every account, user and limit is authorised. | Remove dormant access. |
| Reconciliation | Bank and ledger differences are aged. | Escalate unidentified items. |
| Payment workflow | Maker, approver and releaser are separated. | Use transaction limits. |
| Fraud response | Bank and cyber reporting routes are ready. | Preserve logs and timing. |
Use transaction alerts independent of the payment preparer. Large or unusual payments should reach senior management instantly.
Run periodic payment-recall and fraud-response drills so staff know the bank, 1930 and evidence-preservation steps.
Record the decision, owner, due date and evidence expected. A verbal explanation should become an approved working, board note, contract amendment, statutory filing or reconciliation before the item is treated as closed.
Rules, forms, thresholds and procedures can change. Use the latest official source and the actual company facts rather than copying a prior-year control or another entity’s legal position.
Classify every exception as a timing difference, data error, missing document, legal non-compliance, control-design gap or control-operating failure. This prevents management from treating fundamentally different problems as one ageing list.
The exception file should show amount or exposure, root cause, immediate correction, preventive action, owner and board-escalation threshold. Repeated low-value issues can become material when they reveal weak systems or management override.
Close the item only after the evidence agrees across source documents, books, portal data and management reporting. A screenshot or email promise is not equivalent to a completed filing, lender waiver, signed contract or reconciled ledger.
The control should operate across the full transaction population, not only the samples management expects a reviewer to inspect. For this topic, the key stages are account governance, reconciliation, payment workflow, fraud response. Each stage should identify the source system, preparer, reviewer, deadline and evidence retained.
A useful management review asks whether the legal document, accounting entry, bank movement, tax treatment and public filing describe the same event. Differences may be valid, but they should be reconciled through a dated working rather than explained from memory during audit or diligence.
Materiality should determine escalation, not whether the company keeps a record. Repeated small exceptions can show weak master data, unclear authority, system bypass or management override. Root cause and preventive action should therefore be documented separately from the immediate correction.
Control evidence should show operation, not merely design. A policy document proves what management intended; a reconciliation, access review, approval log or exception report proves whether the control actually worked during the period.
Manual journals, spreadsheet uploads, administrator access and post-close changes deserve additional scrutiny because they can bypass automated workflows. The reviewer should assess both the entry and the reason normal processing was not used.