Federal Reserve Board issues enforcement action with former employee of United Bank

When an employee commits fraud against customer accounts, the failure often begins with the access grant itself—an undocumented decision that conferred privilege without a stated business need, approval chain, or recertification schedule. The absence of a formalized access decision record means no single owner was responsible for periodically asking whether the grant remained justified, and no artifact existed to demonstrate that supervisory review had occurred. Decision Governance would require that every access authorization be produced as a system of record at the moment of grant, complete with the approving manager's rationale, the employee's role-specific justification, and a defined review interval—turning privilege from an inherited state into an examinable decision.