Operations
Dual control for credit committees: encode the policy so the override is the exception
How growing Ghanaian lenders should encode credit policy, exception matrices, and dual-control approvals so examinations and fraud both get harder.
Kojo Ampah, Risk & Compliance Lead · 28 August 2026 · 14 min read
Credit committees that meet to rubber-stamp files already decided in a WhatsApp group are theatre. Credit committees that cannot see the policy the system used are also theatre. The useful version is a core that applies limits, scores, and related-party checks automatically, then queues true exceptions with the reason the officer is asking to break the rule.
Put numbers on products, not in emails
Maximum tenor, maximum amount, minimum score, debt-service threshold, and collateral rules belong on the product. When marketing wants a campaign, change the product with a named approver — do not tell branches to 'just go ahead'. OrbitMFI stores those parameters so origination cannot silently ignore them.
Four-eyes is a login, not a stamp
The second approver must be a different user, not the same password on a shared PC. Dual control that can be bypassed by knowing where the stamp lives is not dual control. Log the time, the device if you can, and the comment. Examiners sample this.
Related parties at origination
Staff, directors, and their relatives should be flagged before disbursement, not after a portfolio review. Block or escalate. Do not rely on someone 'knowing the town'.
Minutes that match the system
If the committee minute says declined and the core says disbursed, you have a problem no software vendor can charm away. Export the decision list into the minute pack. OrbitMFI's audit trail is designed to be that pack, not a reconstruction.
