[wslh]

> The problem is that the CNAF deliberately targets small unintentional errors rather than large-scale intentional fraud.

I think your observation is the greatest one: you don't target "Madoffs or SBFs" you just look at the low hanging fruit where you look at simple probabilistic causality A => B instead of, or at the same time, targetting big malicioous actors. Big and/or complex crimes and corruption are protected.

The irony is that many times the crimes commited by big actors could be simpler to analyze based on tax and financial information.