Federal Reserve Board issues enforcement action with former employee of First Financial Bank

When an employee exploits institutional access, the failure began upstream—at the moment authority was granted without a recorded owner, justification, or review cadence. Decision Governance would have required a system-of-record artifact capturing who approved the access, under what business rationale, and which manager held review responsibility. The enforcement action reflects not just individual misconduct but the structural absence of decision lineage: no logged grant, no periodic revalidation, no evidentiary trail to surface anomalies before they escalated to regulatory intervention.