Saying his legal arguments were “too clever by half,” U.S. District Judge Jed Rakoff dismissed civil racketeering claims by Madoff trustee Irving Picard against a handful of European banks that allegedly helped keep the Ponzi scheme alive. In an 18-page order released to lawyers today, Rakoff dismissed Unicredit S.p.A, Pioneer Global Asset Management, Unicredit Bank Austria and former Unicredit chief executive Allesandro Profumo from Picard’s lawsuit seeking to recover $20 billion stolen from Madoff investors. More in Forbes here.