Global Financing, Capital Markets and Treasury

Introduction

Multinational enterprises must finance operations across jurisdictions while managing currency exposure, taxation, regulation, liquidity and counterparty risk. A financing instrument that appears inexpensive in its contractual currency may become costly after exchange-rate movements, arrangement fees, hedging costs and taxes. Likewise, surplus cash in one subsidiary may coexist with expensive borrowing elsewhere because legal, tax or operational barriers prevent funds from moving freely.

International financial management therefore integrates three decisions:

1. Financing: selecting among debt, equity, syndicated lending and alternative funding;
2. Capital structure: balancing risk, flexibility and the cost of capital; and
3. Treasury management: controlling liquidity, cash, working capital, financial risks and intercompany funding.

These decisions must be evaluated through cash flows rather than headline rates alone.

Learning Objectives

After studying this chapter, students should be able to:

• compare international debt, equity, syndicated loans and alternative funding;
• calculate the effective cost of domestic and foreign-currency borrowing;
• assess capital structure using trade-off, pecking-order and agency perspectives;
• estimate the weighted average cost of capital for international investment decisions;
• design global liquidity, cash-pooling and working-capital arrangements;
• evaluate intercompany funding under tax, transfer-pricing and governance constraints; and
• explain how technology, regulation and ethical conduct affect global treasury operations.

1. The International Financing Environment

International capital markets connect borrowers and investors across national borders. They may provide deeper liquidity, broader investor access and currency matching, but they also introduce additional risks.

1.1 Sources of international financing

1.2 International debt markets

A domestic bond is issued in the borrower’s home market and currency. A foreign bond is issued by a foreign borrower in a domestic market and denominated in that market’s currency. A Eurobond, despite its name, is generally issued outside the jurisdiction of the currency in which it is denominated. For example, a US-dollar bond issued outside the United States may be described as a Eurodollar bond.

Debt instruments may have fixed or floating coupons, secured or unsecured status, amortising or bullet repayment, and senior or subordinated claims. Floating-rate debt commonly references a risk-free benchmark plus a credit spread. The appropriate comparison must include coupon payments, benchmark movements, fees, discounts, hedging and expected tax effects.

1.3 International equity

Equity financing avoids compulsory interest and principal payments, strengthening resilience during downturns. International listings can broaden the investor base, improve trading liquidity and enhance visibility. However, equity usually has a higher required return than senior debt, dilutes existing ownership and subjects the issuer to disclosure and governance requirements in additional jurisdictions.

Depositary receipts allow investors to trade claims representing foreign shares through a local market infrastructure. They reduce some settlement barriers but do not remove the issuer’s underlying business, currency or governance risks.

1.4 Syndicated lending

A syndicated loan is provided by multiple lenders under common documentation. An arranging bank structures the transaction, negotiates key terms and invites participating institutions. An agent bank subsequently administers payments and communications.

Syndication is appropriate when the required amount exceeds one lender’s preferred exposure. Facilities may include term loans, revolving credit lines and multicurrency tranches. Pricing can include:

• a benchmark interest rate plus credit margin;
• an arrangement or underwriting fee;
• a commitment fee on undrawn funds;
• agency and legal fees; and
• currency or interest-rate hedging costs.

Financial covenants may regulate leverage, interest coverage, asset disposals or distributions. Covenant headroom is therefore an important component of financial flexibility.

2. Comparing Financing Alternatives

Financing decisions should be based on a structured comparison rather than the lowest advertised rate.

2.1 Decision criteria

A multinational should evaluate:

• effective cash-flow cost: including fees and hedging;
• currency matching: whether debt service aligns with operating cash inflows;
• maturity and refinancing risk: including maturity concentration;
• control: dilution and voting rights arising from equity;
• financial flexibility: covenants, security and prepayment restrictions;
• market capacity: the amount that can be raised under realistic conditions;
• tax treatment: deductibility, withholding taxes and interest limitations;
• accounting effects: classification, earnings volatility and hedge accounting;
• regulatory exposure: securities, banking and capital-control rules; and
• sustainability conditions: use-of-proceeds or performance-linked obligations.

2.2 Debt versus equity

Debt normally has priority over equity and may provide an interest tax shield. It can nevertheless increase expected financial-distress costs. Equity provides a permanent risk-bearing base but requires returns through dividends or capital appreciation and may dilute control.

Hybrid instruments—such as convertible bonds and preference shares—combine characteristics of both. Their accounting classification depends on contractual substance. Under IAS 32, an obligation to deliver cash may create a financial liability even when the instrument is legally described as a share.

2.3 Alternative and contemporary funding

Private credit funds increasingly provide customised loans where banks or public markets are unsuitable. Securitisation converts pools of receivables or other assets into tradable claims. Supply-chain finance enables suppliers to receive early payment based partly on a stronger buyer’s credit quality. Green bonds finance eligible environmental projects, while sustainability-linked instruments adjust pricing according to defined performance targets.

These structures are not automatically cheaper or safer. Sustainability targets can create reputational and pricing risks if they are weak, unverifiable or missed. Supply-chain finance may obscure borrowing-like obligations if presented as ordinary trade payables despite materially altered payment terms.

3. Measuring the Effective Cost of Borrowing

3.1 Cash-flow approach

The effective borrowing cost is the internal rate of return that equates net funds received with contractual and associated cash outflows:

where:

• P₀ = net proceeds received at inception, in the relevant currency;
• C_t = borrower cash outflow at time t, including interest, principal and relevant fees;
• k = effective periodic borrowing cost; and
• n = number of periods.

All amounts must use the same currency and consistent period. An upfront fee deducted from proceeds reduces P₀; it should not also be treated as a later payment. A simple addition of quoted interest, annual fees and hedge percentages is only an approximation when all components use the same base and timing.

3.2 Worked example: fees, hedging and taxation

A company obtains a three-year bullet loan with:

• principal: $10,000,000;
• annual interest: 4.50%;
• upfront arrangement fee: 1.00% of principal;
• annual hedge cost paid in cash: 1.00% of principal; and
• corporate tax rate: 25%.

Assume the arrangement fee is deducted at inception. Interest and the arrangement fee are immediately deductible, and the company can use the tax deductions in the same periods. The hedge cost is not tax-deductible. There are no other payments.

The initial net proceeds are:

Each annual interest payment is $10,000,000 × 4.50% = $450,000, while annual hedge cost is $100,000. Pre-tax outflows are therefore $550,000 in years 1 and 2, and $10,550,000 in year 3.

The pre-tax effective cost solves:

The solution is approximately 5.87% per year. By contrast, 4.50% + 1.00% + 1.00% ÷ 3 = 5.83% is only a simple additive approximation; it does not fully reflect the timing of the upfront fee or the use of net proceeds.

For the after-tax calculation, the immediate fee tax saving is $100,000 × 25% = $25,000. Effective initial proceeds become $9,925,000. Annual after-tax interest is:

Because the hedge is not deductible, total annual operating outflow is $337,500 + $100,000 = $437,500. The after-tax effective cost solves:

The solution is approximately 4.65% per year.

It would be incorrect to multiply the entire 5.87% effective cost by (1−0.25), because the hedge cost is not deductible and the arrangement-fee deduction occurs at inception.

More generally, an approximate component method is:

where c_j is cost component j, T is the usable tax rate, and d_j is the deductible proportion of that component. This approximation requires compatible rate bases and timing. The special-case formula C_AT ≈ C_pre(1−T) is valid only when every component is fully deductible, deductions have equivalent timing, the tax shield can be used, and an additive rate approximation is otherwise appropriate. A full after-tax cash-flow IRR is preferable whenever these conditions fail.

3.3 Foreign-currency borrowing

Let S₀ and S₁ denote domestic currency per unit of foreign currency at borrowing and repayment. Ignoring fees and interim payments, the domestic-currency cost of a one-period foreign loan is:

where i_F is the foreign-currency interest rate. If the foreign currency appreciates by 5% and foreign interest is 3%, domestic cost is 1.03 × 1.05 − 1 = 8.15%.

When repayment is fully hedged with a forward contract at rate F₀, replace S₁ with F₀. Fees and tax effects must still be incorporated separately. An unhedged expected cost is not a guaranteed cost; exchange-rate forecasts are uncertain and may have asymmetric consequences for solvency.

4. Capital Structure in an International Setting

4.1 Theoretical foundations

The Modigliani–Miller benchmark demonstrates that, under highly restrictive assumptions—including perfect markets, no taxes, no distress costs and equivalent information—financing does not alter firm value. Real firms violate these assumptions.

The trade-off theory proposes that firms balance debt tax benefits against expected distress and agency costs. The pecking-order theory predicts a preference for internal funds, then debt, and finally equity because managers possess information not fully available to investors. Agency theory highlights conflicts among managers, shareholders and lenders. Debt may discipline managers but can also encourage excessive risk-taking or underinvestment. Market-timing theory suggests that firms issue securities when managers consider market conditions favourable.

For multinational firms, capital structure is also affected by sovereign risk, capital controls, withholding taxes, local borrowing capacity and the location of assets and cash flows.

4.2 Weighted average cost of capital

For a firm financed by ordinary equity and interest-bearing debt, the conventional WACC is:

where:

• E = market value of equity;
• D = market value of debt;
• V = E+D;
• k_e = required return on equity;
• k_d = pre-tax cost of debt; and
• T = usable marginal tax rate on deductible interest.

The formula assumes that the debt cost being adjusted is deductible interest and that the tax shield is expected to be usable. Nondeductible fees, hedging costs and country-specific interest limitations require separate treatment. Market-value weights are preferable because WACC represents investors’ current opportunity costs.

Example. A company has equity worth $60 million with a required return of 11.2% and debt worth $40 million costing 6.4%. If all interest is deductible and a 25% tax shield is usable:

WACC is an appropriate project discount rate only when the project has operating risk, financing structure and country exposure comparable to those embedded in the estimate. A high-risk foreign project should not automatically be evaluated using the parent company’s unadjusted WACC.

4.3 Cost of equity and country risk

A common starting point is the capital asset pricing model:

Here r_f is a risk-free rate consistent with the cash-flow currency, β measures systematic equity risk, and (r_m−r_f) is the market risk premium. Analysts may add a carefully estimated country-risk premium where sovereign, political or market-segmentation risks are not already reflected in cash flows or beta. Adding risk premiums indiscriminately can double-count risk.

5. Global Treasury and Liquidity Management

Corporate treasury safeguards liquidity, secures financing, manages financial risks and supports the efficient movement of funds. Its priority is not simply to maximise investment yield: preservation of capital and timely payment capacity are fundamental.

Figure: A central treasury coordinates subsidiary liquidity, external markets, operating cash flows and control requirements.

5.1 Cash forecasting and liquidity reserves

A treasury forecast identifies the amount, currency and timing of receipts and payments. Short-term forecasts often use transaction-level data, whereas longer horizons use budgets and scenarios. Forecast accuracy should be measured by currency and business unit, with systematic bias investigated.

Liquidity consists not only of bank balances but also committed undrawn facilities and readily realisable investments. Stress testing should consider delayed customer receipts, collateral calls, market closure, covenant pressure and the failure of a major bank.

5.2 Cash concentration and pooling

Physical cash concentration transfers balances into a central account. Zero-balancing sweeps participating accounts to a target balance, producing actual intercompany claims where legal entities are involved.

Notional pooling offsets debit and credit balances for interest calculation without necessarily transferring legal ownership of funds. Availability depends on banking and legal rules, and participants may provide guarantees or cross-indemnities.

A pooling structure must address insolvency law, bank set-off rights, withholding tax, transfer pricing, exchange controls and minority-shareholder interests. Cash should not be extracted from a subsidiary if doing so threatens its solvency or violates directors’ duties.

5.3 Working-capital management

The cash conversion cycle measures the approximate time for operating investment to return as cash:

where:

• DIO = days inventory outstanding;
• DSO = days sales outstanding; and
• DPO = days payables outstanding.

Common approximations are:

These measures should use consistent annual flows and averaging conventions. Seasonal businesses require more frequent balance averages.

If DIO is 55 days, DSO is 48 days and DPO is 35 days, the CCC is 68 days. Suppose annual sales are $180 million and cost of sales is $108 million. Reducing DSO by six days releases approximately:

Reducing DIO by five days releases approximately:

The combined release is approximately $4.44 million, assuming activity levels and margins remain stable. Aggressive collection or delayed supplier payment may damage relationships, so financial benefits must be balanced against operational resilience.

6. Intercompany Funding

A multinational can move funds through equity contributions, intercompany loans, cash-pool balances, dividends, service charges and royalties. Each route has different legal, tax and accounting consequences.

An intercompany loan should specify currency, principal, maturity, repayment, interest, security and subordination. The interest rate should satisfy the arm’s-length principle by considering borrower creditworthiness, currency, maturity, guarantees and market comparables. A parent guarantee may reduce borrowing cost, but tax authorities may require a guarantee fee where it provides a measurable benefit.

Key constraints include:

• withholding tax on cross-border interest;
• thin-capitalisation or earnings-based interest deductions;
• transfer-pricing documentation;
• controlled foreign company rules;
• exchange controls and trapped cash;
• debt-versus-equity recharacterisation; and
• treaty-benefit and beneficial-ownership requirements.

OECD base-erosion initiatives and national anti-avoidance rules limit arrangements designed mainly to shift profit through excessive interest. Treasury should document the commercial purpose, borrowing capacity and pricing method before funds are advanced.

IAS 21 governs foreign-currency translation, while IFRS 9 addresses financial instruments and hedge accounting. IAS 24 requires disclosure of material related-party transactions, and IFRS 7 requires disclosures concerning liquidity and financial risks.

7. Risk Management, Governance and Technology

7.1 Financial risk controls

Global treasury commonly manages:

• foreign-exchange risk;
• interest-rate risk;
• refinancing and liquidity risk;
• bank and investment counterparty risk;
• commodity-price risk; and
• operational fraud and cyber risk.

A board-approved treasury policy should define authorised instruments, exposure measurement, counterparty limits, hedge ratios, permitted tenors and reporting responsibilities. Derivatives should hedge identifiable exposures rather than create speculative positions outside the firm’s risk appetite.

Hedge accounting can reduce accounting volatility when qualifying hedging relationships are formally documented and effectiveness requirements are met. Economic hedging and accounting qualification are related but distinct questions.

7.2 Ethical and governance issues

Treasury personnel control highly liquid assets and market transactions, creating significant fraud risk. Sound controls include segregation of dealing, confirmation, settlement and accounting; dual approval; independent bank reconciliation; access reviews; and direct confirmation with counterparties.

Ethical concerns also arise when firms conceal borrowing through working-capital structures, manipulate sustainability metrics or transfer funds from financially vulnerable subsidiaries. Legal permissibility does not eliminate fiduciary and stakeholder responsibilities.

7.3 Technology and artificial intelligence

Treasury management systems integrate bank balances, forecasts, debt schedules and derivatives. Application programming interfaces can provide near-real-time bank data, while robotic process automation can reconcile transactions and initiate approved sweeps.

Machine-learning systems may improve cash forecasts or detect anomalous payments. However, models can fail after structural change, inherit biased data and generate false confidence. Human approval, explainability, cybersecurity controls and model-performance monitoring remain necessary.

8. Illustrative Integrated Case: Meridian Components Group

Background

Meridian Components Group is an illustrative multinational manufacturer. It plans a $60 million expansion in Southeast Asia. The project will generate revenue mainly in US dollars, while wages and local purchases will be paid in local currency. The group also holds recurring cash surpluses in Europe but experiences seasonal borrowing needs in Asia.

Problem

Management is considering three funding routes:

1. issuing parent-company equity;
2. obtaining a five-year syndicated US-dollar loan; or
3. funding the subsidiary through short-term intercompany loans drawn from European surpluses.

The group must also reduce idle cash, avoid excessive refinancing exposure and comply with transfer-pricing and exchange-control rules.

Analysis

Equity would provide maximum loss absorption but dilute shareholders and carry a relatively high required return. Short-term intercompany loans would use existing liquidity, but financing a long-lived asset with short maturities would create rollover risk. Some European cash is also needed for operating contingencies and cannot safely be committed for five years.

A syndicated US-dollar loan provides maturity matching and aligns debt service with the project’s principal revenue currency. Nevertheless, Meridian must incorporate arrangement fees, commitment fees and any hedge required for local-currency expenditures. Covenant stress tests indicate that a severe demand decline could materially reduce headroom.

Treasury analysis also identifies $8 million of structurally surplus European cash and a further $6 million of seasonal surplus. Tax advisers confirm that arm’s-length intercompany lending is permitted, but interest deductions in the borrowing subsidiary are restricted beyond a statutory earnings threshold.

Approach and solution

Meridian adopts a layered structure:

• $36 million from a five-year syndicated US-dollar term loan;
• $16 million of parent equity to preserve covenant capacity; and
• $8 million from a documented five-year intercompany loan funded by structural European surplus.

The short-term seasonal surplus remains in the cash pool to support group liquidity. The intercompany rate is benchmarked using comparable borrower credit spreads, and potential withholding tax is included in the cash-flow analysis. Treasury establishes a minimum liquidity reserve, diversifies deposits among approved banks and hedges committed local-currency construction payments with forwards.

The group also introduces daily physical concentration where legally permitted. Countries with exchange controls remain outside the pool and maintain locally determined liquidity buffers.

Outcome

The blended solution avoids excessive shareholder dilution, reduces reliance on a single funding source and matches most project debt with dollar revenue. Retaining a liquidity reserve prevents the apparent surplus from being overcommitted. Formal transfer-pricing support and covenant monitoring reduce tax and refinancing risks.

Learning points

• Financing should match asset life and operating cash-flow currency.
• Intercompany cash is not automatically available for unrestricted use.
• Effective cost analysis must include fees, hedging, tax timing and withholding taxes.
• Diversification and covenant headroom may justify a higher headline rate.
• Treasury design must integrate liquidity, tax, legal and governance considerations.

9. Practical Best Practices and Limitations

A professionally managed multinational treasury should:

1. compare financing alternatives using complete cash-flow models;
2. distinguish quoted, effective, expected and after-tax costs;
3. maintain diversified maturities, currencies and funding providers;
4. preserve liquidity buffers based on stress scenarios;
5. centralise visibility while respecting local legal duties;
6. document intercompany pricing and commercial purpose;
7. monitor covenants and tax-deduction capacity prospectively;
8. segregate transaction initiation, approval and settlement; and
9. review technology models and access controls regularly.

Quantitative models remain limited by uncertain exchange rates, credit spreads, tax positions and market access. WACC estimates are particularly sensitive to beta, risk premiums and capital-structure assumptions. Cash-pooling benefits may also be overstated if trapped cash, guarantees and insolvency risks are ignored. Managerial judgement and scenario analysis are therefore essential.

Chapter Summary

International financing involves more than choosing the lowest coupon. Debt, equity, syndicated loans and alternative instruments differ in cost, maturity, control, flexibility, disclosure and risk. Effective borrowing cost should be calculated from net proceeds and the timing of all relevant cash flows. Tax shields apply only to qualifying deductions that can actually be used; nondeductible hedge costs must not receive an assumed tax benefit.

Capital structure reflects the interaction of tax benefits, distress costs, information asymmetry, agency conflicts and market conditions. WACC uses market-value financing weights and is suitable only when its risk and financing assumptions match the investment being assessed.

Global treasury coordinates funding, liquidity, cash concentration, risk management and working capital. Cash pools and intercompany loans can reduce external borrowing, but they create legal, tax, transfer-pricing and governance obligations. Strong forecasting, stress testing, segregation of duties and transparent reporting are central to resilient treasury practice.

Key Terms

All-in cost: The effective financing cost including interest, fees, hedging and other relevant cash flows.

Capital structure: The mixture of debt, equity and hybrid financing used by an entity.

Cash concentration: The physical transfer of account balances into a central account.

Cash conversion cycle: The time represented by inventory and receivable days less payable days.

Committed facility: Credit that a lender is contractually obliged to provide subject to agreed conditions.

Country-risk premium: Additional required return associated with political, sovereign or market-segmentation risk.

Covenant: A contractual restriction or performance requirement imposed on a borrower.

Depositary receipt: A tradable certificate representing shares in a foreign company.

Effective interest rate: The rate that discounts contractual cash flows to net proceeds or carrying amount.

Eurobond: A bond issued outside the jurisdiction of its denomination currency.

Hedge accounting: Accounting that aligns qualifying hedging gains or losses with the hedged exposure.

Intercompany loan: A loan between entities under common control.

Notional pooling: Interest offsetting across accounts without necessarily transferring balances.

Pecking-order theory: The view that firms prefer internal finance, followed by debt and then equity.

Syndicated loan: A credit facility provided by a group of lenders under common documentation.

Tax shield: The reduction in tax produced by a deductible expenditure.

Transfer pricing: Pricing of transactions between related entities under applicable arm’s-length rules.

Weighted average cost of capital: The market-value-weighted required return on the firm’s financing sources.

Review Questions

Short Answer Questions

1. Distinguish a foreign bond from a Eurobond.
2. Why can a syndicated loan support a larger borrowing requirement than a bilateral loan?
3. What is the difference between physical cash concentration and notional pooling?
4. Why should market values normally be used in WACC weights?
5. Identify two regulatory constraints affecting intercompany loans.

Long Answer Questions

1. Compare international debt, public equity, private credit and syndicated lending as sources of multinational finance.
2. Explain the trade-off, pecking-order and agency theories of capital structure.
3. Discuss the objectives, benefits and risks of centralising multinational treasury operations.
4. Evaluate the tax, accounting and governance considerations associated with global cash pooling.
5. Explain how foreign-exchange exposure changes the effective domestic-currency cost of foreign borrowing.

Analytical / Application Questions

1. A four-year loan has an upfront fee, annual interest, a nondeductible hedge cost and a bullet principal repayment. Construct the pre-tax and after-tax cash-flow schedules needed to estimate its effective costs.
2. A multinational has DIO of 70 days, DSO of 52 days and DPO of 41 days. Calculate its cash conversion cycle and recommend operational measures to shorten it without damaging key stakeholders.
3. Design a financing and liquidity strategy for a multinational entering a country with exchange controls, volatile currency and limited local capital markets.

Multiple Choice Questions with Answers

Question 1

Which financing source normally results in dilution of existing voting ownership?

A. Revolving bank facility

B. Ordinary equity issue

C. Senior bond issue

D. Trade credit

Correct Answer: B. Ordinary equity issue

Question 2

A company receives loan principal of $5,000,000 and pays an upfront fee of $50,000 from the proceeds. What amount should be used as initial net proceeds in an effective-cost calculation?

A. $4,950,000

B. $5,000,000

C. $5,050,000

D. $4,500,000

Correct Answer: A. $4,950,000

Question 3

A foreign-currency loan carries interest of 3%. The foreign currency appreciates by 5% against the borrower's domestic currency over one period. Ignoring fees and taxes, what is the domestic-currency borrowing cost?

A. 2.00%

B. 5.00%

C. 8.00%

D. 8.15%

Correct Answer: D. 8.15%

Question 4

When is the approximation C_after ≈ C_pre(1−T) most defensible?

A. When every cost component is fully deductible with equivalent timing and the tax shields are usable

B. Whenever the borrower reports an accounting profit

C. When hedging costs are nondeductible but interest is deductible

D. Whenever debt is denominated in the domestic currency

Correct Answer: A. When every cost component is fully deductible with equivalent timing and the tax shields are usable

Question 5

A firm has 60% equity costing 11.2% and 40% debt costing 6.4%. All interest is deductible and the usable tax rate is 25%. What is its WACC?

A. 7.68%

B. 8.64%

C. 9.28%

D. 10.24%

Correct Answer: B. 8.64%

Question 6

Which capital-structure theory predicts that firms generally prefer internal funds, followed by debt and then equity?

A. Market-efficiency theory

B. Purchasing-power-parity theory

C. Pecking-order theory

D. Dividend-irrelevance theory

Correct Answer: C. Pecking-order theory

Question 7

A business has DIO of 55 days, DSO of 48 days and DPO of 35 days. What is its cash conversion cycle?

A. 42 days

B. 68 days

C. 103 days

D. 138 days

Correct Answer: B. 68 days

Question 8

Which statement best describes notional pooling?

A. All subsidiary balances are permanently converted into equity

B. Balances are offset for interest calculation without necessarily being physically transferred

C. Every subsidiary must borrow separately from an external bank

D. Receivables are sold to investors through securitisation

Correct Answer: B. Balances are offset for interest calculation without necessarily being physically transferred

Question 9

Which feature most directly reduces the refinancing risk of a long-lived project?

A. Financing it entirely with overnight borrowing

B. Using debt with a maturity aligned to the project's cash-generating life

C. Holding all cash with one bank

D. Replacing committed facilities with uncommitted lines

Correct Answer: B. Using debt with a maturity aligned to the project's cash-generating life

Question 10

Which control best supports segregation of duties in treasury?

A. Allowing the dealer to initiate and settle the same transaction

B. Using one shared password for all treasury employees

C. Separating dealing, confirmation, settlement and reconciliation responsibilities

D. Permitting unlimited transactions with approved banks

Correct Answer: C. Separating dealing, confirmation, settlement and reconciliation responsibilities