The US government says it was fraud from the jump. The complaint made public today by the Commodity Futures Trading Commission has some hair-raising details — and if it’s right, Sam Bankman-Fried hasn’t been telling the truth for quite some time. According to the complaint, Bankman-Fried operated Alameda Research and FTX as a common enterprise, for instance. This complaint is civil.

In a press conference today, US attorney Damian Williams characterized Alameda Research and FTX as “one of the biggest financial frauds in American history.”

Bankman-Fried said that he “didn’t know exactly what was going on” at Alameda Research and that he “wasn’t running Alameda.” According to the CFTC complaint, that’s not even a little true. It says that Bankman-Fried was a signatory on Alameda’s bank accounts, and was an “authorized trader for Alameda’s accounts with CFTC futures commissions merchants.” He also had direct authority “over all of Alameda’s major trading, investment, and financial decisions.” He made calls in person and over “mobile chat communications” with senior Alameda personnel.

From May 2019 through November 11th, 2022, FTX customer deposits — including both fiat currency and cryptocurrencies such as Bitcoin and Ethereum — were regularly held by “and / or appropriated” by Alameda for its own use, the complaint alleges. Only a small circle of insiders knew that. Alameda traders could tap an “essentially unlimited” line of credit on FTX, and there were special exceptions to FTX’s usual processes that gave Alameda faster execution times than everyone else.

Still, Bankman-Fried wanted the world to think there was a strong separation between the two entities, the complaint says. That was a major motivator for his resignation as the CEO of Alameda.

But wait! There’s more! When FTX was on the verge of collapse, Alameda Research’s traders were instructed to sell everything, fast, and “generally do anything possible to quickly obtain billions of dollars in capital to send to FTX,” the CFTC complaint says. When a trader summarized this directive to him, Bankman-Fried confirmed it. He also said “‘there is definitely a fair bit of urgency’ and asked for the ‘ETA on getting at least $2b of USD,”” according to the complaint.

When FTX executives found a shortfall in FTX US, according to the complaint, Bankman-Fried said he would fill the hole using Alameda Research’s assets, and on November 8th, “Bankman-Fried directed Alameda traders to prioritize meeting FTX US capital requirements and to send excess capital to FTX US.” Alameda sent more than $185 million to cover the shortfall, the complaint says.

Although Alameda CEO Caroline Ellison previously stated that she and Bankman-Fried keep the two companies “quite separate in terms of day-to-day operations,” the CFTC makes a pretty strong argument indicating that this, too, could be false.

Bankman-Fried and other senior managers at both Alameda and FTX are accused of having “widespread access to each other’s systems and accounts.”

Both teams shared office spaces, as well as “key personnel, technology and hardware, intellectual property, and other resources,” according to the complaint.

In an interview at The New York Times’ DealBook Summit, Bankman-Fried said, “I didn’t knowingly commingle funds” between FTX and Alameda. The government thinks otherwise.

When Bankman-Fried launched FTX, customers who wanted to send fiat currency to their FTX accounts were told to wire their money to Alameda Research. Those funds weren’t kept separate from Alameda’s money, or placed into accounts labeled “for the benefit of” FTX customers, the complaint says. The Alameda accounts that held FTX money were labeled “fiat@ftx” on FTX’s internal ledger system.

The agency also alleged a longtime pattern of Alameda and FTX sharing funds. “Alameda accessed and used FTX customer funds for Alameda’s own operations and activities, including to fund its trading, investment, and borrowing / lending activities,” the complaint says.

Alameda isn’t just accused of using money sent to its own bank accounts. According to the SEC, it had the ability to make unlimited withdrawals from its FTX trading account and could tap digital assets there, too.

The CFTC claims that Bankman-Fried, his parents, and his employees at FTX and Alameda used customers’ funds for personal benefit: luxury real estate, private jets, personal loans, and political donations. The customer funds were also used for a Super Bowl commercial starring Larry David and the sponsorship of FTX Arena in Miami. These advertisements, which the CFTC says were paid for by customers’ funds, said that FTX was “the safest and easiest way to buy and sell crypto.”

FTX’s terms of service said that none of the digital assets in a user’s account “shall or may be loaned to FTX Trading.” According to the CFTC complaint, that was a lie. The use of customer funds wasn’t authorized by FTX customers, and they didn’t know their funds were being used by Alameda Research, the complaint says.

The CFTC’s complaint also indicates that Bankman-Fried may have lied to Congress about FTX’s terms of service during his appearance on February 9th, 2022. At the time, Bankman-Fried told US lawmakers, “As a general principle, FTX segregates customer assets from its own assets across our platforms.”

Bankman-Fried’s reputation as a liberal do-gooder was largely founded on his generous donations made to Democrats and progressive groups. But in its indictment published Tuesday, the Southern District Court of New York accused SBF of violating multiple campaign finance laws over his last three years at FTX.

Specifically, US attorney Damian Williams said in a Tuesday press conference that SBF’s “contributions were disguised to look like they were coming from wealthy co-conspirators when in fact the contributions were funded by Alameda Research’s stolen customer money.”