I'm not sure what this says about my turn of mind - probably too devious. But I wonder if one tack that fraudsters could follow would be to publish a paper with

I'm not sure what this says about my turn of mind - probably too devious. But I wonder if one tack that fraudsters could follow would be to publish a paper with the named author(s) being legitimate scientists, and then include some citations inside the paper to the fraudster's other papers. You'd need to use some obfuscated correspondence email to complete the loop.