If the site offers accept money under color of an "independent" scrubbing service, or as lawyers when they are not, they are even more exposed to wire fraud. Fraud is easy: it's a knowingly made false statement of material fact ("I am a lawyer", "this scrubbing service is independent") made with the intent to deceive a victim who could reasonably rely on that statement (ie, "oh, you're independent, I'll pay you" as opposed to "oh, the sky is polka dot orange, I'll pay you") into taking some action against their will.
People do what they are familiar with and can wrap their hands around.
The typical guy who runs the local pizza shop or small import export business does not evaluate what is the best way to earn money for their time and energy after carefully assessing their abilities and advantages in a methodical way. They do what they can wrap their hands around and get done. Something they feel comfortable with.
I don't think it's good to confuse intelligence with what someone uses their time for. Or ends up doing.
In the battle of idiots vs morons, only the lawyers win.
A business doesn't have to be sustainable to be profitable.