Fairfield Greenwich Group, has been sued by the trustee for Bernardo Madoff’s now inactive money management firm, seeking $3.54 billion.

The suit was filed Tuesday in U.S. Bankruptcy court for the Southern District of New York (Manhattan) by trustee Irving Picard, who says will use the money to repay some investors in Madoff’s $65 billion Ponzi scam.

In the complaint, Picard alleges that funds run by Fairfield invested about $4.5 billion in Bernard L. Madoff Investment Securities LLC.

Receiving “unrealistically high and consistent annual returns” should have tipped off Fairfield about fraudulent activity, Picard said in the complaint, according to Bloomberg.

Fairfield withdrew $3.2 billion from Madoff’s securities business in the six years prior to the money manager’s arrest late last year, the suit states.