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What's hard is the temptation. If you are running a fiat backed stablecoin with a big market cap, and you are willing to be a bit dishonest you can make yourself obscenely wealthy. There is no one making you keep your hand out of the cookie jar. Resisting that is hard.

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And here "a bit dishonest" is just a matter of leverage. Slightly increase the risk, and on average you'll come out ahead and have extra money you can siphon off.

This is one reason why economic downturns always expose fraud.

I think a wire fraud/bank fraud charge is on the table for people who give in to the temptation.

We only need one case to be successful for the precedent to be set that you cannot fraudulently issue unbacked stable coins for there to be a sufficient deterrent effect.

It seems that with the FTX bankruptcy, SDNY is looking to set that precedence now.

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