SBF is so so bad. But,

When does it become criminal to skip the step of establishing an accounting system....prior employees say they didn't even know their cash, liability, or trading positions.

FTX customer deposits went into Alameda bank account. Could be that they stayed there and somebody just kept a spreadsheet of deposits?

My point is that the astounding lack of records and systems may make it very difficult to prosecute him. For example, trades and payments were executed just on verbal orders so it will be hard to pin specifics on SBF.

Probably testimony of insiders will be the most compelling evidence against him.