@JOFI 

I do enjoy providing resources, and here is one on "the Strategy" and maybe your client has the right idea:

https://www.irafinancialgroup.com/learn-more/self-directed-ira/roth-ira/excess-roth-ira-contribution...

Also, I overlooked mentioning the Form 5498 also is reported to the IRS. They "know" about the retirement accounts. Whether they have the man power to do anything about it, remains to be seen.