"the amount of the alleged âwinningsâ was far less than the amount the victim had sent in" but that's how a lottery works. The payouts are less than the draw. This wasn't a charity, it was a for profit business.
What I get you're saying is that their model was to steal from the pot far less than the government does. If this is correct then the alleged winnings cannot also be far less than the amount sent in, seeing how the government usually pays out about half to two thirds.
So this can come down to a debate as to whether or not lotteries themselves are moral.
No, it can come down to a debate of whether taking in 25mn, paying out 6mn and keeping 19mn of other people's money does or does not constitute 19mn worth of fraud. Hardly much of a debate, I agree.