To be able to further recover money for the victims, Picard would have needed to recover transfers that were made abroad between foreign entities, such as Madoff “feeder funds” and banks. Due to the intricacies of bankruptcy law, however, a U.S. District Judge ruled that doing so would not be allowed. The reasoning being that the United States does not have the jurisdiction to control the financial happenings in other countries, even in cases that stemmed in America.

While this was a setback for Picard and the many people who were duped by Madoff, the judged suggested that Picard could attempt to recover the money by directly dealing with the foreign countries’ authorities.

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