Sanctions for Corporate Credit Card Noncompliance

Sanctions provide a framework to address program violations. Non-adherence to these guidelines will result in a notification of infraction, revocation of individual Cardholder privileges or permanent revocation of the card. Serious infractions could result in disciplinary action which may include termination, criminal charges, and/or combination of all.

The Corporate Credit Card must never be used for personal use even if the Cardholder intends to reimburse the University. If it is found that the transaction was not for university business, the Cardholder will be required to reimburse Emory for the full amount of any inappropriate transaction. If the reimbursement does not occur, then sanctions noted above may occur. This amount will be added onto the Cardholder's W2 at year end.

Personal use of the Corporate Credit Card may result in permanent revocation of Cardholder privileges.

All alleged infractions will be thoroughly reviewed by Accounts Payable. Additional information may be requested from the Cardholders to be used as supporting documentation.

Examples of failure to comply with program guidelines include, but are not limited, to the following:

  • Failure to properly secure the Corporate Credit Card from theft or unauthorized use
  • Sharing your card or card number with another employee for use
  • Failure to maintain documents
  • Failure to review card activity
  • Incomplete documentation: inclusion of erroneous information, missing information, proper description of purchases, etc.
  • Use of the Corporate Credit Card for personal gain
  • Falsification of records/documentation
  • “Splitting” of purchases to circumvent purchasing card limits

Escalation Notification

The escalation steps noted below are based on best practices. Note that Management and Accounts Payable reserve the right to make changes or modify the consequences based on the infraction. Considering the severity of the infraction, the Cardholder's privileges may be revoked, or other action taken, regardless of the number of infractions on file.

First Infraction

An email notification outlining infraction (s) will be sent to the Cardholder, and may also include the Approver/Manager, CBO, and Internal Audit, as deemed appropriate. The Cardholder may be required to make changes to become compliant.

Second Infraction

An email notification outlining infraction (s) will be sent to the Cardholder and will include the Approver/Manager, CBO, and Internal Audit. The Cardholder may be required to make changes to become compliant.

Third Infraction

An email notification outlining infraction (s) will be sent to the Cardholder and will include the Approver/Manager, CBO, Internal Audit, and Human Resources. The Cardholder may be required to make changes to become compliant.

Additionally, Cardholder privileges will be suspended for up to thirty (30) days. Reinstatement of the Cardholder privileges will occur at the end of the suspension period or upon rectification of the infraction.

Fourth Infraction

An email notification outlining infraction (s) will be sent to the Cardholder and will include the Approver/Manager, CBO, Internal Audit, and Human Resources. The Cardholder may be required to make changes to become compliant.

Additionally, Cardholder privileges will be suspended for up to ninety (90) days. Reinstatement of the Cardholder privileges will only be reinstated upon approval by the CBO. If approval is not granted, the Cardholder will no longer be eligible to obtain a Corporate Credit Card through the University.