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Again a situation in which the rich simply cannot lose. Fraud for 400 million, worst case they “catch” you and you have to settle for double, but he could have used that 400 million for years to expand his fortune, now that settlement is still cheap for him. Besides, if they never caught him, he would have had even more.
The only real punishment for these people is taking away their time, i.e jail time.
Taking their time in jail, pay the taxes they owe, plus pay the potential interest they gained from the fraud, plus a fine at least double the amount of the fraud would be a good start I think. Make it painful and not just a cost of doing business.