> but creating multiple accounts, even if they're fake, is usually just a TOS violation, or maybe a civil matter, not criminal.

Yes, in and of itself, creating multiple accounts in violation of TOS is probably not a criminal fraud under either state or federal law.

But when you do it as the mechanism to conceal streaming manipulation in violation of the agreement that governs the terms of payment, and thereby to secure large amounts of money from the streaming service under false pretenses (and, given the structure of streaming payments, to deny payment to other song owners which they would have received without the deception) on the other hand is a different story.

Like yeah, flexing your index finger isn’t a crime, either, but if you are holding a gun with that finger on the trigger and the barrel pointed at someone's head...

The law very often is focussed more than anything about the purpose and effect of an action, and that you can ignore that and describe the action in terms that aren't criminal without considering purpose and effect really doesn't matter.