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When an employee misuses access, the failure begins upstream in the decision to grant that access without a durable record of scope, purpose, and periodic review. The enforcement actions signal that neither institution maintained decision artifacts tying each access grant to a named approver and a documented rationale, leaving no audit trail to detect deviation or abuse. Decision Governance would have required a system-of-record entry at the moment access was authorized—owner, scope, business need, review interval—turning retrospective enforcement into preventable control. The lesson is direct: access is a decision, and every decision deserves engineering rigor.

From the FED release

Federal Reserve Board issues enforcement actions with former employee of Regions Bank and former employee of First Interstate Bank

Read the original FED release →

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