If the bank failed to apply industry-standard security techniques then yeah, I'd say the bank leaked money. The criminals are obviously the most culpable, but when you're storing more than 100 million SSNs it's not unreasonable to expect your IT department to:
* Update their dependencies within two months of a critical security vulnerability being patched (Mar 7 to May 12).
* In the event of a breach, detect it within a reasonable timeframe (76 days is not reasonable when you're the Fort Knox of financial information).
* Have a reasonably well-segmented network such that a compromise in a single user-facing web app doesn't lead to your entire network being compromised.
* Update their dependencies within two months of a critical security vulnerability being patched (Mar 7 to May 12).
* In the event of a breach, detect it within a reasonable timeframe (76 days is not reasonable when you're the Fort Knox of financial information).
* Have a reasonably well-segmented network such that a compromise in a single user-facing web app doesn't lead to your entire network being compromised.