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17.
A DTFC should ensure that the performance of multiple functions by its relevant persons does not and is not likely to prevent those persons from discharging any particular functions soundly, honestly and professionally. The senior personnel within the DTFC should define arrangements concerning the segregation of duties within the DTFC and the prevention of conflicts.
18.
A DTFC should ensure that no single individual has unrestricted authority to do all of the following:
i.
Initiate a transaction;
ii.
Bind the DTFC;
iii.
Make payments; and
iv.
Account for it.
19.
Where a DTFC is unable to ensure the complete segregation of duties because the DTFC has a limited number of staff, it should ensure that there is adequate compensating controls in place such as frequent review of an area by relevant DTFC senior managers.
