Federal Reserve Board issues enforcement action with former employee of Sandy Spring Bank

When an individual acts outside their authority, the root cause lies in the decision to grant that authority in the first place—or in the absence of a structured revocation process. A decision record tying every permission to a specific approver, a time-bound scope, and a review cadence creates both a deterrent and an audit trail. The enforcement action confirms that employee behavior is downstream of governance architecture: decisions about who may do what deserve the same engineering rigor as decisions about capital or credit.