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FRM Part II · FRM Exam Part II · Risk Mitigation

A bank's operations team reviews its payment-release process. A single clerk can create a new beneficiary, approve the payment and release funds. Which type of control weakness does this most directly represent, and which control would best address it?

This is a segregation of duties weakness, because one clerk can initiate, approve and release payments. The best fix is a preventive maker-checker control that assigns these steps to different people, rather than detective reports, physical security or continuity measures.

  1. ALack of segregation of duties; require that initiation and approval be performed by different peopleCorrect
  2. BLack of detective monitoring; add a monthly variance report
  3. CWeak physical access control; install badge readers
  4. DInadequate business continuity planning; add a backup site

Explanation

One person controlling initiation, approval and release of payments is a classic segregation of duties failure. The preventive remedy is the separation of these functions (maker-checker). A monthly report would only detect problems after the fact, and physical access or backup sites do not address the conflict.

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