Federal Reserve Board issues enforcement actions with former employee of Northstar Bank, former employee of American Express Travel Related Services Company, Inc., and former employee of Regions Bank

When employee misconduct surfaces only after termination, the failure is upstream: no one owned the decision to grant access, no one documented the rationale for maintaining it, and no periodic review was scheduled or logged. Decision Governance requires that every access grant and authority delegation be recorded at the moment it is made — owner, rationale, evidence, outcome — so that recertification is not aspirational but engineered into the control environment. The pattern across three institutions suggests that access decisions remain ad hoc, invisible until audit or departure forces reconstruction. Decisions deserve engineering rigor, and access grants are decisions.