I re-read the article and you're right. The article seems to imply Madoff as an exception rather than the common case, but I still feel that if data is being manipulated at such a vast scale where an entire countries economic activity is misrepresented, you will be able to find people as smart as Madoff to 'fit' the data as per requirements.
You certainly can find people smart enough to make sure that their fraudulent statistics will meet Benford's Law (or any other data model you wish). The article points out that Greece didn't find people this smart.
Not meeting Benford's Law is a good indicator that there has been some dodgy dealing. However, meeting Benford's Law is not a good indicator that everything is above board.
