Settlement breaks that policy never mentions
Policy binders describe initiation checks and dual control on high-value releases. They seldom describe the three-day lag when a partner credit arrives without a matching customer reference, or the manual spreadsheet that “temporarily” closes the gap.
Cross-border payment audits should sample those breaks. A clean policy with dirty reconciliations is still a control failure. We treat unexplained aging items as findings even when staff insist the process is “understood informally.”
Brands that fix ownership and aging thresholds before diligence meetings spend less time explaining the same spreadsheet twice.