GREENBELT, Md. (AP) — Federal prosecutors say an Israeli woman should be ordered to pay $28 million in restitution to thousands of investors who were defrauded in a scheme she orchestrated.

Lee Elbaz, 38, was sentenced in December to 22 years in prison, but U.S. District Judge Theodore Chuang hasn’t decided how much restitution Elbaz owes to her victims.

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Before Elbaz was sentenced, prosecutors said the scheme involving her and other defendants cost investors more than $137 million between May 2014 and June 2017. But the judge calculated that $28 million was the loss that could be attributed to Elbaz’s role in the scheme.

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Now prosecutors say their restitution calculations support the judge’s tally. In a court filing last Wednesday, a government expert said the $28 million calculation “likely represents a conservative estimate of loss and restitution.” Elbaz’s defense lawyer hasn’t responded to prosecutors’ filing.

Elbaz is appealing her conviction and sentence. She is one of at least 21 defendants charged in the fraud case and was the first to be tried. Five pleaded guilty and agreed to cooperate with prosecutors.

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In August, a federal jury in Greenbelt, Maryland, convicted Elbaz of three counts of wire fraud and one count of conspiracy to commit wire fraud.

Elbaz was CEO of Yukom Communications, an Israel-based company that operated in the “binary options” industry under the brand names BinaryBook and BigOption. A superseding indictment unsealed in November charged 15 people, including two former Yucom Communications company owners, with participating in the fraud scheme involving BinaryBook and BigOption.

The binary options market largely operates outside the U.S. through unregulated websites. The payout on a binary option typically is linked to whether the price of a particular asset, such as a stock, rises above or falls below a specified amount at a particular time, at which point the investor receives either a predetermined amount of cash or nothing.

Yukom employees pretended to be from other countries, lied about their professional qualifications and adopted “stage names.” Yucom employees also falsely guaranteed profits, lied about their historical rates of return and didn’t tell investors that they only made money if their customers lost money, prosecutors said.

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