I didn’t know about any fraud; isn’t that a complete defense?
The receiver contends that any gain received by holders of Millennium Bank CDs is not legitimate and must be returned, even if the recipients didn’t know anything about the alleged Ponzi scheme. A recipient’s lack of knowledge of any fraudulent scheme, and good faith, may be factors considered as part of defending against the receiver’s claims, but mere lack of knowledge may not be a complete defense, depending on the facts of an individual recipient’s case.