This is the government fishing for a law to prosecute unrelated behavior that is insufficiently regulated or completely legal. This was not a ponzi scheme as many others have commented. They kept enough cash to pay more than enough of the anticipated withdrawals, and had an operating business that could quickly earn any need for more funds should withdrawals spike. This is standard practice in banking and insurance. I hear Warren Buffet heads a big ponzi scheme too.

If FTP did not segregate finds as advertised, perhaps they committed some sort of fraud, but theft and ponzi this is not.