The trustee’s filing in the US District Court for the Southern District of New York includes a proposed amended claim against Sonja Kohn, the former president and majority shareholder of Bank Medici - a large source of investment into Madoff’s funds - and other members of the Medici enterprise. These include UniCredit, Pioneer Global Asset Management, UniCredit Bank Austria and Alessandro Profumo.

The opposition filed by Picard provides a detailed overview of the trustee’s position under law to recover the funds for the estate of BLMIS, as well as damages governed by the Racketeer Influenced and Corrupt Organizations (RICO) Act.

The amended complaint relates to an original one filed on 11 December 2010, alleging that Kohn and her co-conspirators committed some 8,000 predicate acts violating the RICO Act, to establish a pattern of racketeering.

It would add 23 additional defendants to the case, who “participated and benefited” from the fraud scheme, according to a statement on the trustee’s website. These additional defendants include Kohn family members and several executives from the banks and related entities alleged to have participated in RICO predicate acts. These include money laundering, transactions in criminally derived property, transportation of funds taken by fraud, receipt of stolen funds, financial institution fraud, and wire fraud.

The amended complaint also contains new information and evidence on the alleged wrongdoing of the UniCredit/Bank Austria defendants, such as secret transfers which benefited and furthered the illegal scheme, the statement claims.

“The new factual allegations provide additional support for the trustee’s contention that the UniCredit/Bank Austria defendants are liable for $19.6 billion in damages to the estate of BLMIS as a result the Medici Enterprise’s 23-year money laundering scheme and its indispensible role in prolonging Madoff’s Ponzi scheme,” it alleges.