[Liz]

Phony trading tickets also come under the jurisdiction of NASD----the supposed self-regulatory body of the securities industry (now called FINRA).

If this was done on a computer, that would entail wire fraud, electronic fraud, computer trespass........and the like.

[Liz]

Federal investigators should examinine the criminal MO of “structuring” in connection with Madoff's activities.

If Madoff "structured" cash transactions to evade reporting requirements, he may be guilty of a felony.

31 U.S.C. 5324 prohibits certain actions by any person who acts with the purpose of evading the reporting requirements of Section 5313 (Currency Transaction Reports).

The elements of the structuring regulations are: A person acting alone, in conjunction with others, or on behalf of others , Conducts or attempts to conduct, One or more transactions in currency, In any amount, At one or more financial institutions, On one or more days, For the purpose of evading the reporting requirements of 31 C.F.R. 103.22 (requiring CTRs).

The definition is specifically written to include those transactions which occur beyond a single business day and transactions which are conducted through more than one financial institution.

(The definition of "structuring" for purposes of currency transaction reporting is found at Criminal Code 31 C.F.R. 103.11(gg).)