Payment transmission

We are using Oracle payments (12.1.3) to send payment files to the bank.  Our auditors require the different steps in the process to be performed by different responsibilities.  Specifically, we want one responsibility to be able to create the payment file, but not transmit it, and another responsibility to do the opposite (transmit the file, but not create it).  Is there any built-in functionality for this?  Can I do this with function security, or do I need to do this with OA framework personalization?