Dual-control matrices that match who actually holds keys

The most common gap we find in custody record reviews is a dual-control matrix that still lists someone who left six months ago. Counsel notices. So do insurers.

Rewrite the matrix whenever roles change, not only at annual policy refresh. Name backups for each authorizing seat, and state whether remote approval by video is allowed or whether physical presence at the vault is required.

Separating custody from approval

Some desks let the person who opens the safe also approve the destination address. That may be intentional; if it is not, the procedure should say so. SecureSaaS documentation packages describe the split you actually run — inventing a stricter model on paper creates contradictions during transfer verification.

Evidence beside the matrix

Keep dated acknowledgments when someone accepts an authorizing role. Chat screenshots are weak; a short signed form or logged email acknowledgment survives questions better.