Transfers in excess of $1 billion between foreign parties connected to the Bernie Madoff Ponzi scheme cannot be recovered by the trustee for the liquidation of Bernard L. Madoff Investment Securities, a federal judge ruled Tuesday.

Southern District Bankruptcy Judge Stuart Bernstein said some 88 clawback actions—where the initial transferee was a foreign feeder fund and the subsequent transferee was also a foreign entity—cannot be pursued by Securities Investor Protection Act trustee Irving Picard.

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