Not sure what to call this since I assume this has been regulated to death in normal finance ?
But it wouldn't surprise me if it had happened at some point at FTX, considering all the greed and hype around crypto...
Though I guess it might be a moot point : information doesn't travel instantly, and a judge might still deem you "guilty of Ponzi" (or whatever term is appropriate) if you haven't literally been shouting "We are insolvent !" from the rooftops ? See again : regulation.
There will probably be a lengthy argument in court (but which court - Bahamas?) as to whether they should have realized this earlier and whether their accounting was deceptive or incompetent.
(those interested should read "Lying for Money" by Dan Davies, it's an entertaining and escalating history of fraud)
It's not clear at what exact point FTX became insolvent, but I think the CEO writing an $8bn disguised accounting entry for tokens he'd lent to his girlfriend may have been it.