Like all other form of scam, Bitcoin cheater can also be prosecuted with legal action so far you can trace the perpetrator of the scam beyond all reasonable doubt. The problem is that bitcoin because of its decentralized nature is very difficult to unmask the real person behind the bitcoin cheater. This is one of the pitfall of the world of cryptocurrency. That is why up till date now bitcoin cheater has not been prosecuted not because there is no provision in the law against scam in which it falls under but majorly because of the problem of putting a face behind the crime.