Annette Bongiorno must surrender by 3 p.m. Tuesday. She has been under house arrest but had trouble making her $5 million bail.
Bongiorno is charged with helping Madoff cover up a multibillion-dollar Ponzi scheme that made her wealthy and wiped out thousands of clients. Prosecutors have argued the 62-year-old defendant has the means to flee because she has stashed away untold millions in stolen investor money.
Madoff is serving a 150-year sentence.