Segregation of duties means no single person controls every step of a critical process, such as requesting, approving, and carrying out a system change. For community banks and credit unions with lean IT and operations teams, it is one of the hardest controls to sustain day to day. <\/p>\n\n\n\n
When access, approvals, and review responsibilities drift together over time, the result can be a repeat examination concern, an internal audit finding, or a board-level question about oversight. Most institutions document segregation of duties in policy. Keeping that documentation accurate as people and systems change is where programs tend to slip.<\/strong>\u00a0<\/p>\n\n\n\n Small teams make overlap common, and most conflicts start as a practical necessity. Overlap like this is often unavoidable, and it still needs to be identified, documented, and independently reviewed. The conflicts we see most often include:<\/p>\n\n\n\n Shared administrator accounts make each of these harder to manage, because the institution cannot show who made a given change. Our post on rogue service accounts covers a related blind spot in account ownership.<\/p>\n\n\n\n The FFIEC IT Examination Handbook<\/a> recognizes that full segregation of duties is not always feasible at smaller institutions. Examiners expect management to know where full segregation is not practical. Management should identify and understand the resulting risks<\/strong> and implement appropriate compensating controls, such as rotation of duties, independent monitoring, supervisory review, or activity-log review.\u00a0<\/p>\n\n\n\n Compensating controls are additional safeguards that reduce the risk created by a conflict. Common examples include independent review, dual approval, and audit logging that someone other than the process owner reviews.<\/p>\n\n\n\n Strong documentation answers the questions an examiner or internal auditor will ask about each conflict. For every overlap, record: <\/p>\n\n\n\n For most institutions, a conflict matrix maintained in a spreadsheet is enough, as long as it stays current, and the evidence behind it is retained.<\/p>\n\n\n\n Most institutions can name their segregation of duties conflicts when asked. The harder part is the ongoing maintenance behind that answer: <\/p>\n\n\n\n This work rarely shows up on an org chart, which is why it often gets done once for an audit and then left alone until the next one. Tying a review to known triggers, such as a staffing change, a new system, or the annual risk assessment<\/strong>, keeps the picture from going stale.<\/p>\n\n\n\n Segregation of duties works best when someone outside the day-to-day process owns it. At institutions without a full-time security executive, a virtual CISO can fill that role. A vCISO can review access patterns,<\/a> evaluate compensating controls, coordinate with management and internal audit, support examiner conversations, and keep the control environment aligned as roles, systems, and processes change.\u00a0<\/p>\n\n\n\n If your institution relies on the next audit to surface segregation of duties gaps, it may be time for a closer look. CyberAssurance’s Virtual CISO<\/a> services help community banks and credit unions map where duties overlap, put the right compensating controls in place, and keep that work current as the organization changes. Contact CyberAssurance<\/a> to talk through what that looks like for your institution. <\/p>\n\n\n\n <\/p>\n","protected":false},"excerpt":{"rendered":" Segregation of duties means no single person controls every step of a critical process, such as requesting, approving, and carrying out…<\/p>\n","protected":false},"author":8,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-7114","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"_links":{"self":[{"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/posts\/7114","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/users\/8"}],"replies":[{"embeddable":true,"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/comments?post=7114"}],"version-history":[{"count":3,"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/posts\/7114\/revisions"}],"predecessor-version":[{"id":7118,"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/posts\/7114\/revisions\/7118"}],"wp:attachment":[{"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/media?parent=7114"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/categories?post=7114"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/cyberassurancenow.com\/index.php\/wp-json\/wp\/v2\/tags?post=7114"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}Where Segregation of Duties Conflicts Show Up at Smaller Institutions <\/strong><\/h2>\n\n\n\n
\n
\n
\n
\n
\n
What the FFIEC Expects When Duties Overlap <\/strong><\/h2>\n\n\n\n
How to Document Compensating Controls<\/h2>\n\n\n\n
\n
\n
\n
\n
\n
\n
How to Keep Segregation of Duties Current <\/strong><\/h2>\n\n\n\n
\n
\n
\n
\n
Who Should Own Segregation of Duties? <\/strong><\/h2>\n\n\n\n
Get Support for Your Control Environment <\/strong><\/h2>\n\n\n\n