WF-17 — Client-money Receipt & Release

Process map protecting customer, security-deposit, stakeholder, trust and escrow funds whenever the company receives or controls them: classify → receipt → segregate/attribute → reconcile → approve release/refund → settle. Owner: Treasury (Finance Manager — Fatima Rashid).

WF-17 FIN-13

Client-money workspace Reconciliation report

Process map — happy pathVersion 1.3 · active since 01 May 2026

Funds received / due for release→ Classify (client money? applicability + purpose)→ Issue receipt to payer→ Segregate & attribute to beneficiary subledger→ Daily reconcile (bank ↔ subledger ↔ GL)→ Release / refund approval (dual + evidence)→ Settle to beneficiary · evidence sealed

A release is only payable to the attributed beneficiary for the documented purpose. A release to an unrelated purpose is denied: beneficiary balance and segregated funds remain unchanged and the attempt itself is audited (§19.2 scenario).

Exception paths5 defined recoveries

Classify→ Unknown owner / no matching deal→ Park in suspense (segregated)→ Identify within 10 business days?→ Return to remitting bank · audited

Release approved→ Bank transfer fails→ Funds auto-return to segregated account · beneficiary balance restored→ Re-verify bank details (maker-checker) · re-settle

Exception	Detection	Recovery	Evidence retained
Unknown owner	Inbound credit with no payer/deal match	Suspense within the segregated account; KYC-safe outreach; return to source bank after 10 business days unidentified	Suspense entry, outreach log, return SWIFT ref
Unmatched receipt	Daily reconciliation break (bank ↔ subledger)	Break aged and worked in Bank Reconciliation; no release from unreconciled balances	Break item, aging, resolution note
Hold / dispute	Deal dispute, court order, AML case flag from AML Cases	Beneficiary balance frozen with legal hold reason; release blocked until authorized lift (Legal + MLRO)	Hold order, authority, lift approval
Failed transfer	Bank return / rejection code	Balance restored automatically; beneficiary bank data re-verified maker-checker; idempotent re-settlement (no double pay)	Return code, re-verification, new settlement ref
Stale funds	Balance idle > 12 months post contract end	Escalate to Treasury + Legal; documented tracing effort; disposition per policy/regulator direction	Tracing log, disposition approval

Owner & definition (§8.3 standard)

Workflow ID: WF-17 · Client-money Receipt & Release
Owner: Treasury — Fatima Rashid (Finance Manager)
Version: 1.3 · approved 26 Apr 2026 · effective 01 May 2026
Trigger: Client/escrow funds received, or funds due for release/refund
Preconditions: Applicability decision active (APL-2026-003); segregated account open; beneficiary subledger enabled; dual-approval roles assigned
States: Received → Classified → Receipted → Attributed → Reconciled → Release-requested → Approved → Settled / Held / Returned
Terminal outcomes: Settled to beneficiary Refunded to payer Returned to source (unidentified) Escheat/disposition per policy
Required evidence: Receipt, attribution record, reconciliation state, purpose documents (contract clause), dual approvals, settlement confirmation, policy version
Approval snapshot: Release authority resolves from policy snapshot at request; legal/security re-evaluation rule applies on AML flags (§8.3)

Controls (Table 14, expanded)FIN-13 baseline · P0

Control	Implementation	Checked at
Applicability	Legal decision per entity/branch; explicit non-applicability recorded where funds are not controlled	Classify
Beneficiary subledger	Every dirham attributed to a named beneficiary + purpose; subledger totals reconcile to segregated bank balance daily	Attribute + Reconcile
Segregation	Dedicated client-money bank accounts; no operating payments from them; cross-use technically blocked, not just policy	Every posting
Dual approval + evidence	Release/refund needs maker (Daniel Chen) + two approvers: Finance Manager and Legal; purpose evidence attached before approval is possible	Release gate
Unrelated-purpose denial	Payment to a payee/purpose not matching the attribution is denied; balances unchanged; attempt audited	Release gate
No silent adjustment	Attribution changes are versioned maker-checker events with reason; original record retained	Any amendment

Timers & escalation (§8.3)

Timer	Calendar	Warning	Breach	Escalation
Receipt issuance after credit	Business (UAE, Sun–Thu)	> 4h	> 1 business day	Treasury task escalates to Finance Manager
Daily reconciliation	Business, daily 09:00	Break open > 1 day	Break open > 3 days	Finance Manager + RPT-29 flag; releases suspended on affected balances
Release approval pending	Business	> 2 days	> 5 business days	Second approver reminded → Treasury owner escalation
Unidentified funds	Business	Day 5 of 10	> 10 business days	Return to remitting bank; MLRO notified if pattern suspicious
Stale balance	Calendar	> 6 months idle	> 12 months idle	Treasury + Legal disposition workflow

Screens involved

Step	Screen	Role
Subledger, holds, release requests	Client Money, Trust & Escrow	Treasury / approvers
Receipt issuance & allocation	Receipts & Allocation	Accountant (Daniel Chen)
Daily bank ↔ subledger reconciliation	Bank Reconciliation	Treasury
Deal context & deposit terms	Deal Workspace	Agent / Sales Manager
AML holds on balances	AML Case Management	MLRO (Ahmed Al Blooshi)
Certified reconciliation reporting	RPT-29 Client Money & Escrow Reconciliation	Finance Manager / audit
Attempt & approval audit trail	Audit Explorer	Auditor (Grace Okafor)

Segregated account position — AMP Client Money 01Reconciled 17 Jul 2026 09:00

Class	Beneficiaries	Subledger balance	State
Buyer booking funds	14	AED 1,286,500.00	Reconciled
Security deposits	22	AED 607,300.00	Reconciled
Stakeholder / escrow	3	AED 371,000.00	1 legal hold
Suspense (unidentified)	1	AED 25,000.00	Day 6 of 10 — return clock
Total = bank balance	40	AED 2,289,800.00	Δ 0.00

Denied release — audited attempt (static demo)

⛔ Release denied — unrelated purpose

Request RLS-2026-0142: pay AED 25,000.00 from Amina Noor’s booking-fund balance to GulfTech Facilities LLC (maintenance invoice). The payee/purpose does not match the attribution “buyer booking — unit PR-A-1103, SPA clause 4.2”.

Result: payment denied; beneficiary balance and segregated funds unchanged; the attempt, requester and reason are recorded in the Audit Explorer (FIN-13 required scenario).

Requester note (recorded) *

Operating expenses are payable only from the operating account.

Worked instance — Amina Noor booking deposit · Deal DL-2026-0114 · unit PR-A-1103Partially settled · balance reconciled

02 Jul 2026 · 10:14
Inbound credit AED 185,000.00 — segregated account
Transfer from Amina Noor (IBAN AE12 0260 ●●●● ●●●● ●●●● 771) into “AMP Client Money 01”. Classified: client money — buyer booking, applicability APL-2026-003.
02 Jul · 11:02
Receipt RCP-2026-01418 issued to payer
EN/AR receipt via Receipts & Allocation; Emirates ID on file masked 784-19●●-●●●●●●●-●.
02 Jul · 11:05
Attributed to beneficiary subledger
Beneficiary: Amina Noor · purpose “booking deposit, unit PR-A-1103, SPA clause 4.2” · deal DL-2026-0114 linked.
03 Jul · 09:00
Daily reconciliation clean
Bank ↔ subledger ↔ GL: Δ AED 0.00. Release eligibility opens (funds cleared, no holds).
12 Jul · 14:20
Release request RLS-2026-0138 — AED 92,500.00 to developer escrow
Milestone “SPA signed” evidenced by executed contract in E-signature Evidence. Maker: Daniel Chen.
13 Jul · 10:35
Dual approval completed
Approver 1: Fatima Rashid (Finance Manager) · Approver 2: Mariam Al Suwaidi (Legal). Beneficiary + purpose match verified against attribution; authority snapshot v6 recorded.
13 Jul · 12:01
Failed transfer — bank return R03 (account closed)
Noor Development Group escrow IBAN had changed. Funds auto-returned; Amina’s balance restored to AED 185,000.00; no double settlement (idempotent reference RLS-0138-x1).
14 Jul · 09:40
Beneficiary bank details re-verified (maker-checker)
New escrow IBAN confirmed via signed developer letter; checked by Noura Saeed; re-settlement RLS-0138-x2 executed 14 Jul 11:15 — Settled.
17 Jul · 09:00
Position today
Remaining attributed balance AED 92,500.00 (final instalment release due on handover milestone). Reconciled Δ 0.00 · visible in Client-money workspace and RPT-29.

Static render mockup — no live data. Source: ERP Modern Development Specification v2.0 (§8.2 Table 14, §8.3, FIN-13, §19.2) · Covers: WF-17, FIN-13.