Segregation conflicts after a hiring surge
Rapid fintech growth often reuses admin roles across finance and engineering — here is how to find conflicts before a licence review does.
Early-stage fintech teams survive by wearing multiple hats. That works until the same person can approve a payout, change a velocity limit, and sign off the daily reconciliation. Licence reviewers and investors notice those combinations quickly.
A practical segregation review starts with systems that move money or change customer balances. Export role assignments. Map each role to create, approve, settle, and reconcile actions. Then look for people who hold two steps in the same flow.
Compensating controls help when you cannot hire overnight: dual review of daily exception reports, temporary removal of production admin from finance staff, or time-boxed break-glass accounts. Document the compromise and a date to unwind it.
We run segregation of duties reviews for platforms that need a conflict catalogue before the next regulatory conversation — not a theoretical matrix that ignores how the team is actually staffed.