2 week leave required for employees with access to accounts, records, transactions, etc. Financial institutions safety and soundness policies and procedures should document and require mandatory absence and review of activities for high risk positions in their company. FDIC, OCC, Federal Reserve guidance, regulatory risk and compliance. Attorneys and Compliance officers or Internal Audit.

1. Required Absence Guidance
Sensitive Position - Leave

2. Employees in sensitive positions must be absent from their duties for a
minimum of two consecutive weeks to enhance the viability of a sound
internal control environment by avoiding fraud and embezzlement which
most often occurs under the continual presence of a perpetrator.
Guidance from the FDIC, OCC, Federal Reserve pursuant to federal laws:
12 CFR 30 Safety and Soundness
12 CFR 363 Annual Independent Audits and Reporting Requirements
15 USC 78m, Securities Exchange Act of 1934
One of the Basic Tenets of Internal Control

3. Institute a comprehensive system of internal controls (policies, procedures, processes) to safeguard assets
and capital and to mitigate reputational and legal risks.
1. Make a critical assessment of significant “high risk” areas and sensitive positions by considering all
employees especially those with authority or ability to influence authority to
a. Execute transactions,
b. Signing authority, and or
c. Access to books and records
2. Establish a policy and procedure for Sensitive Position Leave for every high risk employee and activity.
3. During the 2 week mandatory absence, provide for independent monitoring of the transactions or activities
the absent employee was responsible for initiating or processing.
4. Smaller financial institutions should require alternative duties for every sensitive position employee for a
two week period (e.g. rotational assignment) in lieu of sensitive leave or absence.
5. Daily work should be assigned to & processed by another employee who is “independent” e.g. not subject
to the supervision of the absent employee.
6. During the sensitive leave or rotational assignment, absent employee should not be allowed
1. Access to electronic access to systems or records or
2. Access to or from other employees
7. Company should audit compliance with the policies and procedures including the required physical
absence, electronic absence, and ongoing work processing by an independent employee.
Summary of Guidance from Regulators: