There remains some dispute about when Madoff turned his operation into a Ponzi scheme.
Half of all those offered a choice of where to have their heart operation in the nationwide cardiac scheme took up the offer.
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All targets had been met for full bonuses to be paid out in what was the second year of the scheme's operation, the firm said.
But this is easily overcome: often (as with the Caixa's operation of the national student-loans scheme) the banks are simply acting as distributors of government funds in return for a fee.
The company said it hoped to have the scheme up and running in commercial operation in 2015.
He has urged ministers to follow the route taken in Ireland, where a compensation scheme for abuse victims was put into operation.
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One large company, the paper firm Venepal (now Invepal), was confiscated earlier this year and put back into operation with government money under a co-management scheme.
By the standards of 2013, that positively marks it as a small time operation, the corporate equivalent of a three-card monte scheme.
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The scheme was carried out in Madoff's investment advisory operation, which occupied office space immediately below the offices of his broker-dealer, Bernard Madoff Investment Securities.
"This compensation scheme has existed on the statute books since 1886 with its operation having stood the test of time for the last 125 years, " the ABI said.
The scheme, based on the Neighbourhood Watch model, has been in operation for two years.
When the scheme was scrapped in late 1943, all papers relating to the operation as well as materials including handcuffs, petrol vouchers, cash, pistols and ammunition had to be returned to headquarters.
But regional analysts believe the operation was too sophisticated to have been planned so quickly, and Sallal said the hostage scheme had been hatched over months.
He said the scheme could take shape very swiftly if permission is given and the warehouse could be in operation by autumn 2013.
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