Federal Reserve Board issues enforcement actions with former employee of Regions Bank and former employee of United Community Bank

When insider misconduct occurs, the failure typically begins with the access decision: who approved this employee's system privileges, what business need justified that scope, and who was accountable for reviewing whether the grant remained appropriate. Without a decision record tying each permission to an owner and a rationale, banks operate on inherited access and assumed need, turning every login into an unexamined risk. The general lesson is that access is not infrastructure—it is a renewable decision, and like all decisions it requires a recorded owner, a documented reason, and a scheduled expiration or review.