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Branch Operations: Dual Control vs. Dual Presence

2/8/2018 - By Susann Kunz, CAFP

Most branch environments have higher-risk areas that require dual control to access.  This is mainly because the theft or misappropriation of the contents in these areas could result in the financial institution suffering a loss.  Increased regulatory scrutiny is often applied to such areas.

What is Dual Control?

A dual-controlled area requires at least two employees to simultaneously access. For example, the ATM may require both a key and a combination to open. The key should be assigned to one employee and the combination to another.  

  • Dual control will typically apply to access of the following areas:
  • Branch’s cash vault
  • ATMs
  • Night depository
  • Available safe deposit box keys
  • Reserve supplies of official checks

What is NOT Dual Control?

More times than you’d imagine, I come across “dual presence” in branches to access highly-secured areas.  The practice of taking a key off a hook behind the teller line and having two people go together to access the ATM, one of which has the combination, is not dual control. This practice is simply “dual presence.”

Just because employees access dual-controlled areas in tandem and both sign an access card, vault log, or night deposit log does not mean these areas are dual-controlled.  When it’s possible that one employee could access a highly-secured area, the contents of that area are at risk.

During internal branch audits, I encourage management to include the testing of dual control vs dual presence to protect both the financial institution and the branch employees.  It’s a far more common issue than you’d think!

If you have any questions about this or other branch operating procedures, please feel free to email me or any member of our Financial Institutions Consulting Team.

About the Author | Susann Kunz
Susann is a consultant in the Financial Institutions Advisory Group at Saltmarsh, Cleaveland & Gund. Susann joined Saltmarsh in May 2005 after working in the banking industry since 1996 in operations, compliance, lending, and internal auditing. As a result, she brings significant experience to our Financial Institution Advisory Group. 

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