Irving Picard’s efforts to spread money among Bernard Madoff’s Ponzi victims hit a snag this week, when a judge ruled that Picard must present more potent allegations in order to proceed with so-called avoidance actions against entities like Societe Generale SA and UniCredit SpA that handled Madoff funds.

Picard, a partner at Baker Hostetler, is serving as the liquidation trustee for Madoff’s defunct firm. As Picard explains on a website for Madoff victims, avoidance actions are a way of undoing money transfers that Madoff made to investors or third parties in the years before he got busted. The idea is to put the transferred funds, which total in the billions of dollars, back into a common pool for victims.