Segregation of duties in small fintech teams

Classic segregation assumes separate people for initiation, approval, and recording. A six-person fintech in Taitung or Taipei often cannot staff that cleanly. Auditors who insist on textbook role charts without discussing compensating controls miss how small firms actually operate.

Compensating designs that hold up under review include dual approval for releases above a threshold, immutable logs of who changed beneficiary details, and a weekly independent scan of privilege changes by someone outside the payments desk.

What fails quietly: shared admin credentials for the processor console, or a founder who both posts journals and signs bank transfers without a second set of eyes. Those patterns appear in findings regardless of company size.

If you are months from a formal audit, map each funds-moving action to two names. Where you cannot, write down the compensating check and who performs it. That map becomes the spine of your later controls narrative.