The synonyms encompass a large continuum of meaning, hence the carefully chosen vagueness of "operating".
Since you've offered up that way out for MDGC, pick a synonym that you believe applies most correctly.
Is he "cooking", "percolating", "bending"...?
I'm gonna go with bending. He's bending the truth at that address.
Of course this post is my opinion. Every post by anyone is an opinion. I'm not writing a white paper on scams… in this post, anyway...