In a case last year, that court said that if a third party engaged in conduct that created a false appearance or furthered a "scheme to defraud, " the third party could be held liable for participation in the scheme, even if it didn't make a statement of guilt or deliberately omitted such a statement.

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He lived in Spain under a series of false identities, "frequently changing his appearance, " Matt Burton, the organized crime agency's head of investigations, said in a statement announcing his capture.

CNN: Poolside raid in Spain nabs British fugitive