The gov't says 'reckless indifference to the truth' qualifies as intent.

Reckless indifference to the truth, then, should condemn both SBF and his aggrieved.

All involved knew what they were doing, or took extraordinary measures to blind themselves to knowing.

Yes, it's intentionally set up like that to facilitate crime.

The “intentional” part of your claim is extremely dubious, even if I agree with it if you omit that word.

I don’t think there’s an unintentional relationships which facilitates and under-punishes fraud, but I don’t think there’s a conspiracy afoot.