First, Picard (the trustee) can only clawback transactions for six years per NY law. Second, from https://en.wikipedia.org/wiki/Recovery_of_funds_from_the_Mad

First, Picard (the trustee) can only clawback transactions for six years per NY law. Second, from https://en.wikipedia.org/wiki/Recovery_of_funds_from_the_Madoff_investment_scandal https://en.wikipedia.org/wiki/Recovery_of_funds_from_the_Mad... he seems to have primarily gone after people who knew, or should have known, that Madoff was doing something fraudulent. eg, from the article, > On May 7, 2009, Madoff Bankruptcy Trustee, Irving Picard filed a lawsuit [38] against J. Ezra Merkin, seeking to recover almost $500 million withdrawn from Madoff accounts in the last six years. The complaint alleges that since 1995, Merkin steered more than $1 billion to Madoff through three private hedge funds, Ascot Partners, Ariel Fund, and Gabriel Capital. Since 2002, the funds withdrew at least $494 million from Madoff — returns that Merkin “knew or should have known” were fraudulent. There were at least 500 instances in the last ten years when his Madoff account statements showed large blocks of stock bought or sold at prices that did not match the stock’s trading range for the day when the transactions supposedly occurred.