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Organization Design & Governance · Corporate Governance and Internal Control

Segregation of Duties and the Four-Eyes Principle

Separate risky work from its approval and checks, so no one does and checks it alone.

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The script Atlassian ran on the morning of April 5, 2022, had been through the proper checks.

It had been peer reviewed. It had been tested in staging. It had already run once in production, against 30 customer sites, and removed an old app from them without trouble. The second run was meant to do the same for 883 more.

But between the team that asked for the job and the team that did it, the list had changed meaning. Instead of the ID of the old app on each site, it now held the ID of each site itself. The review, Atlassian wrote afterwards, “focused on which endpoint was being called and how. It did not cross-check the provided cloud site IDs.” The staging test couldn’t catch it either, because those IDs didn’t exist in staging.

The script started at 07:38 UTC and finished at 08:01. It deleted 883 sites belonging to 775 customers, some of whom were without their tools for up to two weeks. The case has the rest.

Atlassian had a second pair of eyes. They were looking at the wrong thing.

Two people, two jobs

The four-eyes principle says that a risky action needs two people: one to do it and one to check it. Its older cousin, segregation of duties, splits a process so that the person who does something isn’t also the person who records, approves or reconciles it.

Without either, one person’s slip goes straight through. Before Knight Capital’s trading disaster in 2012, one technician copied new code onto the firm’s order-routing servers and missed one of eight. According to the Securities and Exchange Commission, Knight “did not have a second technician review this deployment,” and had no written procedure requiring it.

Without segregation, one person’s deception can go through too. Barings, a London bank with more than 230 years in merchant banking, collapsed in 1995 after losses run up by Nick Leeson, its trader in Singapore. In a summary of the official inquiry, Australia’s central bank listed the first failing: “a lack of separation between the front and back offices.” As general manager, Leeson “effectively controlled both sides of the trading operation,” which let him trade without authority and then alter the records of what he had done. Secret accounts hid the losses. Among the inquiry’s lessons: “clear segregation of duties is fundamental to any effective control system.”

What the second pair of eyes needs

A second check is only as good as what it looks at. Atlassian’s review followed its standard process, and that process looked at how the code called the system, not at the data it was fed. The first fix it set out in its review was a change to the system itself: route every deletion of customer data through a “soft delete,” so the data can still be recovered for a while.

Two other things matter. The checker needs to be independent of the doer, not a colleague nodding along to finish the day. And the check has to happen where it can still stop something, before the action takes effect, not in a report read afterwards.

The shared account

Imagine a small charity where the treasurer both pays the bills and reconciles the bank statement each month. She is honest, and has been for years. One month a supplier’s bank details are changed by a convincing email, and three payments go to a stranger. The reconciliation looks fine to her, because she is reconciling against the same wrong details she typed in.

The charity’s fix costs almost nothing. A second trustee now approves any change of payee details, and someone other than the treasurer reads the bank statement each month. Neither step accuses anyone of anything.

Four eyes and an agent

AI coding agents make it easy to collapse the roles again. One person can now ask an agent to write a change, ask another agent to review it, and press merge, all without a second human looking.

Software platforms already have a guard for this, built for people. GitHub lets a repository require that “the most recent reviewable push must be approved by someone other than the person who pushed it.” When an agent pushes code on someone’s behalf, the useful second pair of eyes belongs to a person who didn’t direct that agent, looking at what can go wrong: which records the change touches, which IDs it uses, what it deletes.

A second model reviewing the first can help as an extra filter. It is a different check from a second person who answers for the result.

Stories behind it

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Sources

  1. Atlassian, Post-Incident Review on the Atlassian April 2022 outage, April 2022
  2. U.S. Securities and Exchange Commission, In the Matter of Knight Capital Americas LLC, Release No. 70694, October 16, 2013
  3. Reserve Bank of Australia, Implications of the Barings Collapse for Bank Supervisors, Bulletin, November 1995
  4. GitHub Docs, About protected branches
  5. Sri Viswanath (Atlassian CTO), Update on the Atlassian outage affecting some customers, April 12, 2022
  6. SEC, In the Matter of Knight Capital Americas LLC, Release No. 70694, October 16, 2013
  7. Reuters via NBC News, Knight Capital gets $400 million lifeline, August 6, 2012
  8. CNN, Finance worker pays out $25 million after video call with deepfake 'chief financial officer', February 4, 2024
  9. Hong Kong Free Press (AFP), Multinational loses HK$200 million to deepfake video conference scam, Hong Kong police say, February 5, 2024
  10. CNN, British engineering giant Arup revealed as $25 million deepfake scam victim, May 16, 2024
  11. The Guardian, UK engineering firm Arup falls victim to £20m deepfake scam, May 17, 2024
  12. World Economic Forum, 'This happens more frequently than people realize', Arup chief on the lessons learned from a $25m deepfake crime, February 4, 2025
  13. Department of Employment and Workplace Relations, Targeted Compliance Framework Assurance Review, Final Report (report page and revision notes)
  14. The Guardian, Deloitte to pay money back to Albanese government after using AI in $440,000 report, October 6, 2025
  15. Associated Press, Deloitte to partially refund Australian government for report with apparent AI-generated errors, October 7, 2025
  16. Australian Financial Review, Deloitte AI report: Firm admits to using AI in error-filled government report, October 5, 2025
  17. CFO Dive, Deloitte refunds over $60K for report with AI errors, Australian government says, October 21, 2025