ALL of it is criminal, the abuse that is obvious and that which is not obvious.
If you went to a car dealer and paid him for a Lamborghini but he delivered you a Kia instead that would be a felony.
And that IS essentially what CoS does. They sell you states of Clear and OT yet not a single person has achieved these states (as they are described by Hubbard). Both of these examples, with the car dealer and the CoS are just different types of marketing fraud.