In recent cases I’ve reviewed, ERC mills show the same tells: cloned payrolls across 10–15 shell LLCs, identical 941‑X narratives, and batches e‑filed from a single EFIN/IP within minutes. Prosecutors are stacking 26 USC 7201/7206 with wire fraud and 18 USC 1956, so exposure now runs beyond restitution to forfeiture and multi‑year sentences — anyone else seeing BOI data pulled to tie control persons?