I don't know why you assume those tasks are similar in difficulty. In general, if you don't factor in the chance of getting caught, it's easier to make money with a an illegal scheme than a legal one. Nobody would break the law if it weren't so.
I can't reply to all comments, so since you posted first I'm replying here...
It's a minor thing to learn a criminal skill that lets you con your way into a couple thousand dollars. The combination of knowledge, connections, moxie, and motivation to raise an ill gotten 37 million dollars are another thing entirely. Not anyone can just say "oh sure I'll lie my way to 37 million". Given the skills, time, and dedication it must have taken to get this far by a person with these talents, could have been used to be reasonably successful in a whole host of careers or ventures. Perhaps not 37 million effective, but enough to live comfortably and happy for sure, without the constant fear of the long arm of the law creeping up behind you at any moment.
