There was nothing stopping a gullible manager from just ... transferring all the money away? uh

So he was the CEO, all the way at the top, not just a manager -- but yes, it seems like there were some things that could be improved with their controls, in retrospect.

It was a small bank, looks like probably only a dozen or so employees total, if that paints a picture of how this might have happened.

Aha, here's the writeup by the Federal Reserve, very well-done!

> Heartland employees circumvented the bank’s internal controls and policies; following those internal controls and policies may have prevented or detected the alleged fraudulent activity. We believe that the CEO’s dominant role in the bank and prominent role in the community contributed to a reluctance on the part of Heartland employees to question or report the alleged fraudulent activities earlier.

> The events leading to Heartland’s failure revealed a significant breakdown of internal controls, including controls related to wire transfers and suspicious activity reports (SARs). Specifically, senior bank employees circumvented the bank’s wire policy and daily limits to approve and process the CEO’s alleged fraudulent wire transfer requests. Additionally, Heartland employees did not follow the bank’s Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) (together, BSA/AML) policy.

https://oig.federalreserve.gov/reports/board-material-loss-r...

Yer policies are only as good as the people following them...

Sure makes it seem trivial to just take the money and run. No need to involve any pig butchers in the process.