Field notes

What boards miss in safeguarding packs

Three recurring gaps we see when e-money boards review client-money narratives before they reach a supervisor’s desk.

Desk with charts and printed board papers

Many board packs show a tidy reconciliation total and stop there. The harder questions sit one layer down: which bank accounts are truly segregated, who can move funds, and how quickly a break ages before it reaches the risk committee.

Concentration risk is often buried in an appendix. If a single correspondent bank holds most client float, directors should see that fact on the same page as the safeguarding claim—not three slides later.

We also ask whether weekend and holiday settlement calendars are reflected in the narrative. A safeguarding story that assumes every business day looks the same will not survive a holiday week with elevated wallet balances.

None of this requires new jargon. It requires the board to see the same bank evidence the operations team already holds, presented without decorative summaries.

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