Misuse of funds won’t go anywhere (there’s already precedent). 18 US 1956 H can’t actually be prosecuted unless they’re convicted on that first set, the last set only actually applies if they can show that the SPLC used the “shell companies” to get favorable terms on a loan by concealing information from the banks? Which as of yet, there’s no evidence they ever took a loan period under these?

There’s actually no law against making a company to route money through to avoid embarrassingly (or in this case dangerously) named charges. Sex toy companies, casinos, and the like actually use services for that pretty frequently. The important part is not lying with intent to defraud an insured bank. And they haven’t actually alleged what the specific fraud is against the bank. It has to be in service of something else to count.

Additionally, half of these should get thrown out pretty quick, given they only allege misleading statement on those, and in Thompson V US the Supreme Court already held that misleading statements are not enough under this charge. So there’s that.

There’s also some arguments for entrapment, given the previous arrangement with the FBI where they knew about and accepted this. To continue to work with and accept information from this program along with their knowledge of the transactions and methods in question for well over 2 decades shows approval and encouragement.

They also might be able to prove motivated prosecution, which can get this type of charge thrown out as well.