Defending the Whistleblower: Phil Brewster | Designated

Have you ever met a corporate whistleblower? Most of us haven’t. They do make the subjects of great movies, though. There's intrigue, suspense, and high stakes.  And usually a happy ending. But what exactly happens in real life when someone high up in a company, privy to corporate secrets, witnesses illicit dealings in their midst? How does that process play out? And at what cost.. Personally and professionally?

Designated host Yaya Jata Finuse recently spoke with Phil Brewster, an attorney whose specialty is helping clients who have decided to become whistleblowers. They discussed the real-life impacts of these high-stress investigations, which most often involve the personal stakes for the whistleblowers that Hollywood can’t fully convey.

 

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Episode Transcript

Speaker 1 (00:05):
Today's podcast is supported by TRM. TRM enables compliance teams
to accelerate business revenue and deliver actionable intelligence to regulatory
and law enforcement stakeholders with leading attribution of severe risk categories.
Request a free trial today at trmlabs dot com. I'm

(00:36):
Yaya Jata FANUSSI. Have you ever met a corporate whistleblower?
Most of us haven't. They do make the subjects of
great movies, though. There's intrigue, suspense, and high stakes and
usually a happy ending. But what exactly happens in real
life when someone high up in a company privy to
corporate secrets witnesses illicit dealings in their midst How does

(00:59):
that process play out and at what cost personally and professionally.
Today's guest, Phil Brewster, runs his own boutique law firm
out of Chicago, where his specialty is helping clients who
have decided to become whistleblowers. He's seen a lot, he's
heard a lot, and he's helped a lot. I recently

(01:21):
spoke with Phil, who was able to walk me through
one case in particular that shows how these high stress
whistleblower investigations most often involve great personal stakes that Hollywood
can't fully convey. Phil Brewster, are you ready to get designated?

Speaker 2 (01:39):
I generally don't like the sound of that when someone's
talking specifically to me, But for you, yeah, I'll do it.

Speaker 1 (01:45):
Let's go, all right, Welcome Phil. I know you once
said that people come to you after the worst day
of their life. What do you mean, Yeah?

Speaker 2 (02:00):
Yeah, What I mean is this sort of someone's family
member dying. If someone is going to come and call me,
it's because something terrible has happened at work that they
have discovered and have become involved in criminal or regulatory
misconduct that threatens potentially their freedom. They could be confused
as a potential participant in a crime, and they are

(02:23):
nervous and afraid. They've likely talked to somebody at work
about it, and those people have not listened to them.
They have probably been ostracized because of it, potentially fired,
and it's been weighing on them for a lengthy period
of time, likely months, and they are really afraid. They're
really isolated, and frankly, the way I describe it, it's

(02:45):
when you meet me, it's like the end of the
line and you get off the bus and you get
to talk to me about your problems, and I always
tell them that you know, today's going to be the
hardest day, it'll be the worst day, and every day
going forward, as we work in your problem, we'll get better.
And that's been my experience probably with every person that
I've represented in a whistle of a program.

Speaker 1 (03:06):
Well, Phil, why you if the stakes are so high
in these situations, why are they coming to you and
they're not going to the authorities.

Speaker 2 (03:17):
That's a good question. So sometimes they do go to
the authorities and talk to someone. That happens. And I
have found though that on the whole, most of these
people are fairly educated, smart C suite level or you know,
senior vice president level person, and they're gonna think about

(03:42):
really hard and investigate their situation. They're gonna be really anxious.
And I like to think about it like it's the
web MD approach to health problems, Like, if you have
a health problem, you're gonna go on the Internet and
you're gonna do research. You're gonna look into it. And
if you're in a situation like I'm talking about, where
you're at the center of a legal or i listed conduct,

(04:03):
you're going to go and study your problem. That's the
nature of the kind of client that will come and
find me. They'll go to work, they'll figure it out.
They're hardworking people. They've gotten themselves into a problem, they're smart,
and they're going to work to try to find a solution.
So they go on the internet. They learn about the
programs and they study and they realize that a lawyer
can help them. And sometimes they've gone and talked to

(04:23):
the authorities, but then they realize even after that encounter
that they really need a lawyer because the government when
they engage with you, they're very hands off. I mean,
they're trying to figure out who you are. They're trying
to understand who you are as an individual, like what's
your story, and you don't have a lawyer there to
kind of help and guide and prepare for that meeting.
So you know, they'll usually quickly turn around after that

(04:46):
meeting and find a lawyer if they haven't done so before.

Speaker 1 (04:49):
So these whistleblowers, the people that you interact with, I
mean you said that they're usually folks professionally who are
at a high level. Is there anything else that make
them different that disting distinguishes them from other executives.

Speaker 2 (05:06):
Yeah, I think there really is a distinction of someone
that's willing to do this. It's a very difficult process.
So I have found characteristics in my clients that tend
to be universal. One. I find them to be very thoughtful,
very principal, and they have very developed, keen moral compasses,
and they also have a belief in the system. They

(05:27):
have a belief in the rule of law, and they
are willing to stand up for that. And I think
that's what differentiates them from other employees that encounter problems
and they're not really willing to dig into it, and
there becomes sort of a cognitive dissidence that develops where
they rationalize the problem away. And that happens commonly. I mean,

(05:49):
companies regularly get in trouble. Very sophisticated companies get in
trouble for situations that in retrospect look like how could
that ever happen? The consulting firm McKenzie recently just settled
over a half billion dollars to their involvement with the
opioid crisis, and one thinks, how does the world's greatest
consulting firm get involved in something like that? And I

(06:11):
don't know anything about that case. But I'm talking about
the kind of group think that takes place, the sort
of rationalize in way of problems. The individuals I'm talking
about don't do that. They confront and grapple with difficult issues.
They're not afraid to and it's mainly because they have
a belief in the system. They have a good moral
compass and that's what drives them to raise their hand
up and usually a sea of many people to be

(06:34):
maybe the only one who says, hey, we got a
problem there. So that's what I would think distinguishes the
people that I've worked with. And I can't speak for
every whistleblower lawyer out there that has had clients. You know,
my experiences, you know, based on the cases and controversies
that I've been involved in. But that's the pure set
that I've encountered, and those are the characteristics I've found.

Speaker 1 (06:53):
And you've dealt with a lot of cases of whistleblowers.
Can you walk us through you know one, you know,
an exemplar case that that you can talk about, walk
us through what happened?

Speaker 2 (07:07):
Sure, So the case that I can talk about and
my client is authorized to talk about involves Morgan Stanley
and Interactive Brokers. And if you've recently read the Wall
Street Journal, you will have discovered that Morgan Stanley's under
investigation from AML deficiencies. And I think a good starting point,

(07:28):
you know, to this and is to understand a little
bit about, you know, what the money at issue was
involved in, what country was involved. And I think, yeah,
if we could just lay out a little bit of
backgrounds we get to where my client like jumps into
this will make a lot more sense to people that
aren't AMLS experts that give some color to the like

(07:52):
the country, the money that people involved. So this involves
and my client's disclosure to the government about money launering
involves Venezuela. And I don't know if you find this,
but every time we talk about the worst countries in
the world, the most corrupt, it seems like, you know, Russia, China,

(08:13):
North Korea, Somalia, you name it, Venezuela is always there.
It's like always always there. And just to give you
your viewers a sense, last year the most corrupt countries
in the world, the worst was smaller, it was dead last.
There's three at the bottom tied for second, and that
was Venezuela, South Sudan in Syria. To give you a sense,

(08:36):
that means that Russia, China and other countries you may
think of as corrupt are actually doing a little bit
better than Venezuela. Venezuela over the last twenty years has
turned into a kryptocracy and the country is effectively bankrupt
and defunct. And that happened because an oil company named
Petavasa Venezuela. And this may surprised people listening right now. Everybody,

(09:01):
if I ask folks like, where's the largest oil reserve
in the world, everybody would say Saudia, right built like
instantaneously that would be the country. It's actually wrong. The
largest proven reserves in the world are in Venezuela. When
you're adding conventional reserves and the oil and the Orinoco
River Valley, which is a heavier, more sulfur driven product,

(09:22):
Venezuela's on top in the Western hemisphere. It's number one
and conventional oil more than the United States. And so
what happened was that was all nationalized and then through absolute,
you know, unapologetically socialist political regime, they started providing social programs.

(09:45):
But the problem was Petavasi of the National Oil Company
of Venezuela, so also became a political arm of the
Venezuelan regime, run by cronies of the government. Let's just
say they didn't do a very good job running the company.
Oil plummeted in terms of production, and then the social
welfare programs that relied on it faltered, and then it

(10:06):
turned into a failed state effectively. And at the same time,
the government officials stole roughly and there's no known number now,
but about three hundred billion dollars, and that's a number
that I've heard, and I just want to give you
a sense of like how much kleyptocracy was going on.
Just like a flavor for how bad Venezuela it was.

(10:28):
They took Russian freighter planes and put seven tons of
gold and flew it to Uganda and basically smelted it,
rebranded it non Venezuelan treasury bars and sold it and
no one can find that money. And then that gold
came from actually World War two, when the US was
buying oil from Venezuela for the war. Afternoon, the Venezuelan's

(10:50):
demanded gold. It was the only thing they would accept,
and they stored those in the National in the treasury
there and during the time of Nicholas Muduro, the current president,
that was all stolen. That's how bad it is in Venezuela.
The president himself, Nicholas Maduro, he has been charged as
a narco terrorist by the United States government in twenty
twenty for helping the FARC produce cocaine. So it's an

(11:14):
absolute field state. Now, how do we get from my client,
an American citizen going to the government and talking about that. Well,
there was a guy named Luis Rodriguez. He worked for
two ministers of the Venezuelan government, and one was the
head of Petavesa, that's the Venezuelan oil company, and one

(11:35):
was actually the ambassador to the UN. And what he
did was he wandered about two billion dollars to a
small bank and endure. Now, Indoorra is a tiny country
most people have never heard of. I won't lie. I
had to go look on the map. I'm going to
I'm not going to say that. You know, yeah that
I didn't. It's between France and Spain, and it's tiny.

(11:56):
You could drive through it, your ride through in your
bicycle probably in a half, that's how small it is.
And he moved all that money there, and eventually, because
they were living very lavishly, this this gentleman Luis Verriguez,
they were in Paris spending insane amount of money, staying
at the jorsin the Ritz Carlson and the best, the
best hotel in maybe potentially the world, spending you know,

(12:19):
half million dollars on hotels. Eventually, French intelligence and other
intelligence agency as law enforcement for trying to figure out
who these people were and what they were doing, and
eventually they would seize all that money and in Andorra,
But before that happened, they bribed one of the bankers
there to release money, and they released two hundred million dollars. Then,
just to give you a little context, US Treasury Department

(12:42):
deemed Banka, Pravada and Dora that was the bank and
a primary money laundering risk under section three to eleven
of the Patriot Back and it basically finished the bank off.
But by that time this money had moved and it
was moved uh and and moved into the United States.
And so we're almost there to where my clients sto

(13:04):
the things. It will make sense, I promise when we
get through this, this this, this, this, this line of explanation,
it will make sense.

Speaker 1 (13:11):
I'm following the line. I'm following it. It's good.

Speaker 2 (13:14):
So there's there's a company in Barbados called Energy Risk
condemnedy LO and behold. Luis Rodriguez happens to be the shareholder.
The fancy word for it is he is the ultimate
beneficial owner. He's the UBI and anybody in the industry
knows exactly what I'm talking about. He's the shareholder. I
have the documents that can prove that he's the shareholder.

(13:35):
I have his passport, I have all the I have
all those bits from my client. That money moved for
the benefit of URI to Morgan Stanley through Mexico. How
do I know this? Morgan Stanley filed a SAR, a
Suspicious Activity report, explaining all of this. So I'm not
saying anything that Morgan Stanley didn't tell the government to

(13:56):
this point. So that money moved into the United States
between October twenty fourteen and October twenty fifteen, and Morgan
Stanely eventually reported to the government in two thousand and sixteen.
Now and then into seventeen, the money remained at the
bank and would ultimately move to another company another bag

(14:19):
called Interactive Brokers, which is a US brokerage firm, very large,
one one of the largest electronic brokerage firms in the world.
So the money is was at Morgan Stanley. There was
a sorry issued. The money is moving, it's moving out
and it's going to go to Interactive with Brokers. Now,
my client joined the firm in twenty eighteen. At that

(14:42):
time the money that was at Morgan Stanley, that Morgan
Stanley filed a SAR and explained to the government about
their risk and its connections to Banka Pravada and Dora
and its ties to two of the most well known
kleptocrats in Venezuela. They let that money go when it
goes to Interactive broker and my client joins a firm
who's advising that money. He didn't know any of this

(15:04):
when he joined the firm. He joined as the chief
compliance officer. So does this make sense. I'm trying to
give you kind of the sense of like where this
money came from, how radioactive it is, how the money moved,
and how it ends up in the United States. And
now my client is the chief clients officer at an
investment advisory firm in the United States, and he's doing

(15:25):
his homework over accounts. That's his job.

Speaker 1 (15:28):
And if I can step in here at this point,
right that your chief compliance officer, So you know, I
assume this his role is to you know, assess that
all the procedures are being followed, so that if there
is anything questionable, risky, you know that it's dealt with
in a certain manner, that there's due diligence that's done,
that certain things are reported. Because he knows, especially his

(15:49):
chief compliance officer, right, he's responsible and so so this
person should know when something's wrong.

Speaker 2 (15:56):
He's liable with something. In fact, to give you an example,
the chief compliant that the AML chief compliance officer had
a regulatory action against him at Interactive Brokers, the very
firm we're talking about, because of a failure on his
part to oversee the AML program. So my client had
personal liability, he had skin in the game, and he

(16:18):
took his job seriously because he's a he's a reputable
human being. Going back to what I talked about earlier
about the type of person, hard working, They follow the rules,
you know, they've done the they put in the work
to rise the ranks. The members of their community. They
are not troublemakers. They're there to earn a living and.

Speaker 1 (16:35):
To do their job. He's chief compliance officer. He's noticing
something seems to drift. He's evaluating the documents, and so
what happens.

Speaker 2 (16:44):
Like any good chief compliance officer, you start to go
through all your client files, and I think what any
compliance officer would do is start at the largest ones
and the big ones that have the biggest influence and
present the greatest risk to the firm. You know, and
that risk is doing business with the firm. It also
could be that you have a client that has leverage
over the firm if they do something wrong, So you

(17:06):
need to be careful. It's not just like facilitating bad conduct.
You don't want to be in a situation where your
largest client has leverage over you. So, you know, compliance
has kind of a multifaceted aspect to it that you
have to be really careful with who you're dealing with
because they both containt you and have leverage over you,
and you don't want to get into those situations. You
want to avoid that from ever ever happening. So we

(17:26):
started to research the largest client, started to look into it.
The background where it came from, the history of the money.
He had all the files, the entire history, and he
started looking through it and realizing who these people were.
That in fact, the members of the board of directors
of RI were PEPs themselves, and PEPs are politically exposed people.

(17:48):
So the members of the board of directors, excluding the
gentlemen Luis Roriguez, were also people that were very suspicious
from a PEP standpoint, that they presented risk of potential corruption, yes,
because they were tied to and affiliated with government officials.

(18:09):
So you have that. He noticed that he was looking
into Luis Arbriguez, He's looking at Venezuelan passports, and he's
looking at the history of you know, what's happening in Venezuela,
and he's deeply concerned. So he raises these concerns at
the firm and he gets pushed back. At this very
same time, the firm is also moving to liquidate the account.

(18:30):
The account is going to disappear, it's going away, and
the money is going to go off shore. My client
at this point has figured it out. He's deeply concerned
and he is worried that the firm is not operating
in normal fashion. It's not doing with this very large count,
which was what you would do. You would sit down
and you would you would plan, you'd have meetings, you'd

(18:52):
have in person time with people, and none that was occurring.

Speaker 1 (18:55):
Phill What was the pushback that he received he raised
these concerns and what he.

Speaker 2 (19:00):
Told He was told that there was nothing to see,
that this was all legitimate, that the individuals that he
was talking about and the concerns he raised were figments
of his imagination, that they were not real, that he
had it wrong, that he didn't understand things, and that
was it. And also what I found in whistle blowing,

(19:21):
there's a tendency to demonize the whistleblower, to make the
whistleblow a doubt oneself, to make oneself think I'm just
having crazy thoughts, effectively, you know, to undercut the sort
of credibility and the mental state of the person that
you're talking about, to make them feel like I'm doubting myself.
Maybe they're right, I'm wrong, I need to back off

(19:41):
of this, and that sort of campaign that he felt
very intensely, and like what I was saying earlier about
the characteristics of the clients I work with He eventually
turned around and said, no, I'm not going to do that,
and he called Interactive Brokens himself and he said, I
have real concerns about this count. He called, he called
the bank. He said, hey, you need to you need

(20:02):
to look at this. And at that point he had
sort of crossed the rubicon. Once you do that as
an compliance officer, you're going to be looking for another job.
But because this money was going to move offshore and
he was certain about its illicit origins, he did what
needed to be done. And he also made another very
bold step in my mind, is he called the sec
by himself, and he called a regional office and they

(20:25):
took the call, they spoke with him. They called him
right back, and they sat down and had a long
conversation with him, and he provided all the information that
he had in his position at that time. And then
he lost his shot. As you could imagine that would
happen very quickly. He moved to basically lock the account
and that didn't go over very well, and he lost

(20:46):
his job. He's fired, and he was very traumatized by
that whole experience. He had had a long career in
the investment world. He had never had any prior incidents
of this conduct or anything that you would find. I mean,
most of the clients I ever ideal with had never
had contact with law enforcement or a regulatory issue. You know,
for them, it's this is the first time, and it

(21:08):
was very much in his case what he encountered.

Speaker 1 (21:11):
So he lost his job and so and this is
after he went to the SEC. So things really have
fallen apart for him personally. How does walk us through
then what happens and actually how he ended up with you.

Speaker 2 (21:26):
People get really nervous when they if they reach out
by themselves at the government and they talk to someone
and then the government doesn't call them back. That I
think is probably probably more nerve wracking than anything else
than you've gone and talked to somebody and now they're
not talking to you and you don't understand why. And
that I think for a lot of people who are
uninitiated and to this is gut wrenching. That's what he encountered.

(21:48):
It's not unnatural. I wouldn't say there's anything, I wouldn't
read anything into that. I actually think that's standard playbook
for the government. And so he reached out to for
counsel and I got involved and I started investigating the case.
You know, I do a standard interview. I sit down
with people. I get kind of assessed, like, you know,

(22:09):
what if this is real? Most of the time I
say no, I mean yeah, yeah, to be frank, I
mean most cases, they're not really meritorious. I mean, most
of what I'm doing is filtering through lots of calls
from people that think they have something and they don't.
I mean, they're nice people, but it's not worthy. You know,
there's not the they don't have the start to finish
story that the government's going to be interested in. And

(22:29):
so in a way, I do the government of favor
because I sit down and I spend a lot of
time that they otherwise would have to spend with people,
and then I filtered through. But this story was absolutely
rock solid from the moment that I that I talked
with the client and I actually tried to trip the
client up. You know, I use some like basic interviewing
techniques to see if like, you know, is this am

(22:50):
I getting spoofed or is it, you know, as this puffery,
Like everybody wants to have a great case, Like no,
I couldn't, and I couldn't move them one inch. And
I realized that he was a very tough guy, and
he was a smart guy, and that he wasn't lying.
And he had a stack of documents. He had all
the account records, he had all the internal documents from
the Company of Barbados, he had the passports. I mean,

(23:13):
it was the full complete picture. You don't usually get that,
getting internal board meeting minutes of companies, I mean are
very rare, especially you know when you go into the
Caribbean Caribbean Reinsurance I mean those sorts of like Caman BBI,
you're just not going to get your hands on that.
He had it all because he had the files. He
was he was the chief compliance officer, and he diligently kept.

Speaker 1 (23:35):
It off and reading between the lines. I mean, I
don't know if you can say this or not, but
I'm reading between the lines. At this point, he's fot
he has been fired, he's no longer with the company,
but he still has evidence within his possession which would
be needed for, you know, for to take this case forward.

Speaker 2 (23:53):
Yeah, he walked out with the information that he with
the documents within his control. He left with the whistleblower
laws allow you to do that. Now that's a complicated topic.
You're not allowed to You're not allowed to keep everything,
and you know you can't. You can't work at a
big company and you know, copy the entire server and leave.
That's that's actually the risk factor. I you know, if

(24:14):
we want to talk about risk factors, that's something not
to do. But yes, he had the documents, he kept them.
He was smart about it, and it mainly to protect himself.
I mean, I think in the beginning, it's fair to
say that the client didn't want to get confused as
a target of an investigation, and so the best to
do is keep the evidence proved that you're not the
bad guy and so, but we had the evidence, and
then from there you start an investigation. And I use

(24:35):
the mosaic method. That's just how I how I look
at things. And I don't mean there is a mosaic
method used in like criminal threat assessment. I don't mean
it like that. I mean it in a very simple way.
I think of it as I'm looking at a picture
and I only have a few bits of what I
can see. I know behind all the dust that there's
a full image, and what I want to do is

(24:56):
start to you know, where I can uncover certain parts
of it to start to develop a picture, and I'll
never get the full picture. And I don't get that.
I don't have the resources that you had when you
work at the government. I don't have those databases and
I don't have those resources. But using open source, given
what the client has and open source technologies, you're able

(25:16):
to kind of peel back what's there, and we did that. Eventually,
you work and you create what looks like a court filing,
the detailed brief with all the evidence, and you file
it in this case with the SEC and that started
the process, gets the client on the clock and the program,
and that's how you formally become a whistleblower. And so

(25:38):
that's like the next step in the process. You work
very closely with the client. This is a very intense
part of the process where they help you figure out
what happened. You Now you tell a story. You try
to craft a story that if you're a government enforcement official,
you want to tell a story that's interesting that with
your limited resources, we can't look at everything. That's the
job as the lawyers to help lay that out. It's
also the job of the lawyer to explain who the

(25:59):
person and explain the background to the person, because my
experience has been the first person who gets investigated in
a whistle blower case is the whistle blower by the government.
They want to know who this person is. Can we
trust this person? If there are going to be a source,
we need to know that they are not going to layer,
you know, just be a grenade that goes off and
destroys the case. So we're working on that. We're trying
to build up the credibility of the whistleblower. We're trying

(26:22):
to present to the government a witness and a story
that they can be interested in, believe in, and tell
them that, hey, like, you know, look it ups and that's.

Speaker 1 (26:31):
What happened, and I want to hear you know then
what you all did. I mean, you're compiling the story
and the facts and putting everything together. But earlier you
mentioned that it's standard procedure for the government to not
follow up. And why is it Because they're looking into
this person as a possible part of the government.

Speaker 2 (26:52):
So I would I would clarify this. I think the
government will follow up. I just think that clients expected
to be like instantaneous, and I just I think that
their timeline is not reasonable. They just don't appreciate what's happening.
So I think when when you file, the government's going
to they're going to do an initial investigation before they
would ever call you. And most of the time they

(27:13):
would look at they look at it and they decide, yeah,
we don't need to do something here. This just doesn't
rise to our attention level. And in a program that
like a whistleblower program, whether it's not court filings like
in some of the other whistleblower programs, they don't have
any duty to do so to respond to you. You're
not a party in a proceeding like in some of
the other cases and types of whistleblowing, you know, you
may not hear a response. But here they will call

(27:35):
you back. And they did call us back, and interestingly,
the pandemic struck. And what I thought was so interesting
in all of this is that we filed this in
December twenty nineteen, the pandemic struck in March, and the
government was interested. They called back to say, hey, we
want to talk to you, and now we did. One
other thing is that in this case is that we

(27:56):
brought it to the Department of Justice. So we went
to the SEC we filed there, and then we gave
the entire briefing to the Department of Justice, and we said, hey,
you should look at this and you should take this
very seriously, and they did, and even in the middle
of the pandemic. I remember this very vividly. Yeah, Yeah,
I flew someplace when no one was supposed to fly anywhere,

(28:18):
and I was at O'Hare by myself. I was like
alone at the airport. And if you've ever been to O'Hare,
that's a really strange experience.

Speaker 1 (28:25):
Yeah, I kind of missed those days of not a
lot of people in the airport, but yeah, it's not
like that now.

Speaker 2 (28:31):
I remember going. There was no one in the security
pne at O'Hare, which is like crazy. And I got
on the plane. I flew to this location and at
this time there was a lot of civil unrass This
was a major metropolitan area. It was really not safe
to be on the streets at night. I mean, it
just was a really wild time. And we briefed the client.
We spent a lot of time with the client, you know,

(28:52):
sitting down kind of like where we are here talking
about things, how to answer questions like what do you do?
And then we went to the government, and you know,
no one's doing in person, no one's doing anything. And
we went into the press room of the government of
the US Attorney's office, and they have little desks like
separated out if you remember that that time period, and

(29:12):
one desk was the FBI, one desk was Homeland Security,
one desk is the US Attorney and then you know,
the SEC. And we're all in this room and we're talking,
and I'm thinking to myself, this is a very important case.
If we're doing this, you know, if we're here in person,
you know, our clients here, and we're doing this. And
so that's that's how that case progressed. And you know,
there's a long interview. And from there we continued to

(29:35):
do a lot of research and started supplementing our filings
with the government with information that we found, kept developing
the case using that moment mosaic method kind of peeling
things back, using you know, there's software technologies that you
can use or that our open source to help you
find connect relationships. We started peel all of that back,
and this was a tremendously large network and we fed

(29:57):
all that information to the government.

Speaker 1 (30:00):
So you're feeding this and and and bring us bring
us back to even connecting this, connecting the line to
where you started with with Morgan Stanley, because that's sort
of in the background. So what so, so what is
it that you're piecing together as it relates to Morgan
Stanley at this point and then what what starts happening?

Speaker 2 (30:18):
Yeah, so, I mean, fund the fundamental premise of our
referral to the government was that both at Morgan Stanley
and Interactive Brokers, they had accepted funds from a from
A from clepocrats that they that their A m L
programs were deficient. And our allegations are that that that
that happened. And so that's the focus of everything we're

(30:42):
working on. It's feeding to explaining the how these people
pulled this off. And if you're going to allege that
bad people brought bad money to a bank, you need
to explain why they are bad people, Why why is
this illicit funds? These are not easy standards to meet.
These are these are very serious charges. And so to

(31:05):
explain that to the government, to give them the background
to show them how bad this is and that in fact,
it is what we say it is. That's what we're
trying to give to them, because then they have the
resources and the power to look at things and ways
that we simply cannot. And at the time I didn't
know about that SAR. That SAR came from the Finnsin files,
which was a leak that you were probably familiar with.

(31:27):
It was someone who worked a treasury and left with
an immense amount of sarw She went to jail for that.
Actually she actually went to prison for disclosing all that information.
But in that stack that she left was the SAR,
was the intelligence report of Finsen that proved what we
were saying was true. I didn't know that at the time.
I mean, we're working and trying to prove this is true,

(31:49):
and then I read the SAAR later on, going like, okay,
we hit the nail on the ad here. You know,
this is great, but that's fundamentally what we're driving at.
Your question was, you know, we're trying to show and
we're trying to prove that bad money went to a
bank where it shouldn't have gone.

Speaker 1 (32:05):
And so what was the end result I mean, with
with your client, with the whistleblower and then you know,
how did you you know, how did you all bring
this to a final result?

Speaker 2 (32:14):
Oh, it's not final. It's not final at all. So
to give you a sense of what's happened. So we
did all that work with the government, and then we
felt that the case was very important. The client felt
the case was very important. And this is not something
that I regularly do, but has become a larger part

(32:34):
of my practice, and it's not something I do it
very very few of my cases. This case with that
was particularly important and had a particular public resonance to it,
and so we contacted the Wall Street Journal and an
individual named Ian Tally. Ian Tally was the illicit finance
reporter at the Wall Street Journal, and we did that
in January twenty twenty one. So we had been working

(32:58):
for a long time with the government and then we
made a decision to move and talk to the media,
which was not lightly taken by any means. And then
Ian Tally was fascinated, was what we had to say.
He had been following this for a very long time.
He had written a story actually about the Venezuelan gold
smuggling that I mentioned, and all the other kind of
kleptocracy that the Venezuela was involved in, So we gave

(33:19):
him the information of our case. He was fascinated by it.
But yeah, yeah, it was a long road with the
Wall Street Journal to get that published. As I mentioned,
we went there in January twenty twenty one. It took
until the fall of that year to get it published,
and I felt like it was probably one of the
hardest things I've done professionally to get that across the
finish line. The standards at the journal were very high editorially.

(33:42):
The allegations were very serious, and they were they were
not going to make those allegations without stone cold confidence
that that was true. And Ian Talley got it done,
and that story broke and it continued and Ian Tally,
in fact, he actually left the journal. He's no along
with the journal. He started his own company now uh

(34:04):
And we we talked to another journalist there named Anna
Maria Andreotis, and she was not an all listed finance
reporter at all. She was actually a consumer reporter, like
consumer finance was her specialty. And she got moved to
the desk of Morgan Stanley and Goldman Sachs in the
fall of twenty twenty three, and we reached out to her,
asked for the talk toor We said, we have something

(34:26):
very interesting you should talk about and you should talk
to Ian Saley.

Speaker 1 (34:29):
And moved to the desk. Moved to the desk meeting.
Now she covers Morgan Stanley four for the journal. Okay,
for the journal.

Speaker 2 (34:38):
So she's covering Morgan Stanley and Golden Sacks. That's all
she covers. And so that's you know, we reach out
to her, we make contact and we say, hey, can
we just talk with you and show you what we have?
You know, this is you're on the desk and so
this is you know, we think a big issue. And
went to the Wall Street Journal headquarters, New York in

(34:58):
presentation and and she was not a money laundering expert,
you know, I will say that was not her you
know her background. But she is a very diligent reporter.
And she was able to uncover by November of twenty
twenty three that the Federal Reserve was investigating Morgan Stanley

(35:19):
for AML deficiencies. She would follow up with reporting in
April of twenty twenty four about further investigations by SEC
the Office of the Comptroller of the currency FINCE in Fincon,
which is the US Treasury's enforcement arm, and what was
going on there, and how long and protracted the problems
were starting in twenty twenty up to and including twenty

(35:41):
twenty twenty two to twenty three to twenty four and
the great efforts that you know, Morgan Stanley was making
with the government to address but in many ways not
meeting it. That all culminated actually a yeah, with a
very long article that was published in November of this
year excuse me, December of this year or just recently,
and it was on the sort of the front of

(36:02):
the mast about you know, the global issues that Morgan
Stanley was having in its AML problems, and so the
issues that we discovered way back in twenty nineteen, and
we started then slowly boiled to the surface through a
lot of persistence and a lot of dedication and commitment
on the part of the client to follow this through

(36:24):
to the bitter end. And you know, some of the
problems that I can just give you just like a
sense of something, and this is for reporting from the
Wall Street journaline just restating the work of Ana Maria.
You know that that something like forty six thousand of
their international wealth accounts redeemed high risk or high risk

(36:44):
plus over half of the counts in twenty twenty three
had errors and missing documents, and twenty twenty three they
had an account which they ended up closing, but they
allowed the account to open for a gentleman that was
actually indicted for lying in a terrorism investigation involving Al

(37:05):
Qaeda and the bombings in Africa, and that he actually
had an account at Morgan Stanley, one of the subsidious
e trade and they shut that down. But the fact
that those sorts of things were slippig through it was
the fact that they didn't have Spanish speakers in a
global wealth management firm that was expanding into Latin America.

(37:27):
They didn't. They were using Google Translate to translate documents
to understand what those were. They were hiring attempts to
read documents. They didn't have, at least in my opinion,
in the reading the cultural staff that they needed to
really understand the business that they were doing. Spanish speakers,
people were familiar with doing business in Latin America. They

(37:49):
were in a growth phase. Morgan Stanley after the Great
Financial Crisis, really focused on wealth management as a steady
business and it's a supercharge their growth, their earnings. And
I think what happened was along the way, and this
is just my opinion, they didn't put in the proper
foundation to manage the risk of having a global wealth
management firm, for example, not meeting clients in Latin America,

(38:13):
simply opening accounts with ever meeting a person. I mean
to me, I think that that speaks volumes to the
sort of risk assessment, the risk holans they were willing
to sort of live with, and I think that, you know,
was very dangerous and it has now caught up with them.

Speaker 1 (38:26):
So I want to just ask about your client, because
what you just described is almost it seems like you
all planned to see that others were able to follow
because the government was starting to look at it. The
media was uncovering things that maybe you all didn't even
know about. So now things as the years have gone on,

(38:48):
things are now in the public. So how does your
client feel or how did did your clients start feeling
when this became uncovered.

Speaker 2 (38:57):
I think my client felt vindicated. I think, going back
to what I said earlier about the nature of the clients,
I think that his struggle was proven worth the effort.
It proved that he was right and that he stopped

(39:17):
conduct that threatened the US financial system, that he was
able to make a difference. And I think that's what
a lot of my clients have. I mean, they look
at the world, they have a and somebody's a richer
understanding of like what it means to be an American
when we're a country has tremendous liberties. We have, you know,

(39:37):
some of the best individual rights and the ability to
live those out pretty much anywhere in the world, thinking
of just the expansiveives of our First Amendment. And I
think that this client particularly saw on the other side
of that the obligations that come along and living in
that system, that if we're going to have a system
like that, that we have to tend it, we have

(39:58):
to take care of it, and that what he was
doing was stepping up to make sure that the system
would still function. And I think it was a very
brave act. I think it's something very very special. Not
many people are willing to do it, but I think
that that's really where it came from. That he felt
in the end that the effort that he gave and
the suffering and the name calling and the bad words

(40:19):
that were said about him and the smear campaign that
it just didn't stick and he was able to make
a difference. And I think that that's fundamentally an American thing.
I mean, yeah, if you look at whistler programs in Europe,
they're very weak, anemic, they're not very functional. Most people
that have a good claim come to America to bring
that claim because usually the jurisdiction here, I mean, we
just have a very strong whistle or you know, sort

(40:41):
of I guess spirit here. And I think it speaks
to who we are as Americans, as individuals that feel
like we can talk to our government.

Speaker 1 (40:49):
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(41:12):
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(41:33):
people even know much about whistleblower programs and that there's
actually a potential reward if you successfully bring forth a
whistleblower case. Tell us about that, tell us about the
potential reward.

Speaker 2 (41:47):
Yeah, sure, so I look at it. I kind of
divide the world in whistle blowing in America into two buckets.
The first one is fraud in the federal government, and
that's called the False Claims Act, and that it comes
from the Civil War. It's called Lincoln's Law and it
was to prevent fraud on the US military and its acquisition.
That's the big program that's been around for a very
long time. You actually file a lawsuit, you have to

(42:09):
be a party in litigation, and you can't talk about it.
It's under what we call seal and those go on
for a very long time. But you have to have
fraud in the government, and it's very particular. You have
to plead it in a very particular way. It's a
very technical statute and you have to have a lawyer
to do it. You're not allowed to just bring a
case like that on your own. Because you're bringing a
case on behalf of the United States government, you need

(42:31):
a lawyer that you can't represent another person, So you
have to have a lawyer to essentially bring the case
on behalf of the US government, and you stand in
the shoes of the government in those cases. Those cases
have a success rate of about twenty percent. Okay, it's
not bad, but there's a lot of filtering that goes
on with the lawyers to think about which case that
they'll take, that they're going to engage in. Now, on

(42:51):
the other hand, there's a whole slew of other programs.
The big one I think is the SEC program. It's
been around since god frank so about twenty eleven, twenty twelve,
and it's been it's been a very successful program. I'll
give you a statistic. I'm not you know this is
this These are some estimates, but since twenty eleven, about

(43:12):
one point nine billion dollars haven't paid out to whistlebowers,
to about four hundred individuals. It makes out an award
of about four point seventy five million. Now, some people
you can go after my math on that. It's a
rough estimate. I'm telling you you know, I'm a lawyer,
not an accountant. That's based on but here's the thing
that's based on about eighty thousand tips. So the success

(43:34):
rate when you figure out four hundred people made it
through to get to a reward, that that's less than
one percent. So the success rate is very low. You
are signing up for, you know, I mean, terrible odds.
The other programs are out there, you know, you have
the IRS program, you have the Commodities Future Commandi's Futures

(43:55):
and Tradings Commissions program as well, that's very similar. Treasuries
come up with a new program. It's only been around
for about a couple of years. It's very new. These
programs take a long time to kind of stand up.
And then this summer actually the Department of Justice came
out with a very similar Whistlebulver program with rewards and
it's kind of to fill in where uh, there may

(44:16):
not be a program for some of the joints. So
for example, like foreign corruption, this comes very much to
the kind of audience that you're you're talking to. The
Foreign Corrupt Practice Act, which gives the SEC jurisdiction over
a foreign foreign foreign bad conduct of a US accounting
or someone that's a registerrant in the United States, Well,
if that's not at play, it's kind of hard to
find jurisdiction to where you may be able to join

(44:37):
a program. They've set it up so you can now
have that jurisdiction. If it's a private company and it's
foreign you can now fit into a program. So those
are the kind of programs that you have out there,
you know generally, so you think of like fraud in
the government, that's gonna be the False Claims Act, and
then you have fraud and private individuals or revolving you know,
social securities fraud, you know, commodities fraud, and mar manipulation,

(45:01):
tax fraud, and that you sort of catch all with
the Department of Justice. It's also money hounering with the
AML problem. That's it. So you know, I deemphasize the
rewards on these. I just gave you the odds. It's
not great. You know, you really got to think about
doing this because it's the right thing to do, and
you really want to do it for the right reasons,
and you're motivated to do it for a very long

(45:21):
period of time. Like the case study we're talking about
that we're sticking to here, I mean five years in
and we're still going. And they go for a very
long period of time because I mean for a company
like Morgan Stanley or Interact broke us to settle a matter,
I mean that takes years to the government to investigate
and resolve and then you have to apply for the award.
So it's just a long haul. And I don't think
people should really get excited about that. I think you

(45:43):
really got to think about doing it for the right reasons,
because you care about what the issue is, that you
know that you're passionate about it, because that's the thing
you're gonna be living with.

Speaker 1 (45:51):
And phil even if you are considering if someone is
considering the whistle blower whistle blower route, what should they
what could go wrong? Like, what things should they be
thinking about? Maybe that might make them not want to
go that route.

Speaker 2 (46:09):
Yeah, I think that's a really fair question. And I
think that when you think about getting into a program
like the reasons you know, like not to do it,
I think maybe that you, in fact are the orchestrator
of the crime. I think that that would be a
bad idea. Okay, let's just say that if you set up, Yeah,

(46:29):
you're the one doing it. Let's not go to the government.
And I point that out. You should go to the
government and talk to them, but that would be with
the defense lawyer, and you'd be proffering your conduct for
credit for volunteering that. So okay, let's not be the
organizer of the crime. I don't think Luis Rodriguez would
be a good person to apply for a reward that
we're talking about, So I think that I think. I

(46:52):
think one of the things that I think is people
that don't have firsthand information. There's a whole sphere out
there people that sort of data mine information for fraud.
My experience and this is just my experience, accept in
the sort of very technical market manipulation cases, the government
wants first hand information. They want you to know what happened.

(47:12):
So they want you to know about the fraudulent conduct
and be able to speak about it and be a witness.
And what they want to be able to do there
is make sure that it's actual fraudulent conduct and it's
just not a mistake an error. So it's really important
that that you have first hand information. If you don't,
you've got to really think through that whole process. You know.
Some of the other things that would would cause me

(47:33):
to kind of shy away from it too, would be personal.
And I think any good.

Speaker 1 (47:37):
Lawyer is going to do this.

Speaker 2 (47:40):
If you if you, if you've had potentially and I
sit down clients talk to this all the time, like
what's your mental state? Like how do you feel? Have
you had problems in the past, Like have you had
mental health problems? Have you had a substance abuse problem?

Speaker 1 (47:53):
You know?

Speaker 2 (47:53):
Are you are you maybe potentially on the brink of
divorce with your spouse? You know? Are you the old breadwinner?
Do you take care of your mother? Like if you're
you know, you take care of your mother and you're
the person in her life who you know comes over
every day and you you're buying groceries and you're taking
Maybe this is not a good idea for you because

(48:14):
this is going to be so stressful for you that
it's going to disrupt your life and harm either you
or people around you, and maybe it's not worth it.
So you really have to kind of assess like where
you are personally, and I think a good lawyer is
going to do that because you know, my starting point
I is do no harm. I don't want any bad
things to happen to my clients. I don't want my
clients to become destitute or you know, end up on

(48:35):
you know, in just a you know, in a terrible
position in life that they weren't in before that was
caused by the very thing that we're doing, and that
was foreseeable. So I think that's healthy. It's kind of
like gut check about who you are, like what are
you ready for? You know, I would describe it like this.
I mean, the way I think about these cases is
that you have to think about it as as a trip,
a journey, and you're going to leave one place and

(48:57):
you're not going to have it. You're going to go
to another place, and during the course of that trip
you're gonna have You're gonna reach a point where you're
not gonna able to turn back. You're gonna You're on
this journey that is, you're either gonna get there or sink.
And you really have to have the mindset to do
that because it's real. I mean, this is this is
no joke, and this is not a video game, this
is not true crime TV. This is you know, this

(49:19):
is the real, the real story so I think that
the other thing I would just say, like I would
just say, make sure you're getting into whistle program. I
mentioned that the woman at Treasury who went to jail,
she gave out information the federal government does have a
whistle blower program for employees. She didn't use that. She
gave it to a journalist. They were very sensitive documents.
I used it in my case. I'll be frank on that.

(49:40):
I at that point it was a public document. But yeah,
you gotta make sure you're fitting into a program. So
those are kind of the things that I think you
need to to think about going into it. And each
person's gonna have a different risk tolerance. Everybody. Everybody's different.
I mean some people, some people can manage a lot
of risk and some people are very conservative.

Speaker 1 (49:57):
If someone is in a situation now they have witnessed wrongdoing,
they're pretty sure it's not a mistake. What are the steps?
What do you advise them to do right now?

Speaker 2 (50:11):
First thing I would tell you is go talk to
an attorney. That would be the first thing I'll do.
The second thing I would say is don't wait. The
programs we're talking about are seeking actionable intelligence. They don't
want old information. They want new information that they can
act on right away. Information that's three, four or five
six years old. They don't care. I mean, they have
other pressing issues that are right in front of them,

(50:33):
So you have to go quick. I think that you
shouldn't download information if you're still employed, don't do anything.
Go and talk to your lawyer. There are ways to
deal with things. And I will just warn people out
there that are watching this. Companies have very sophisticated software
to know if you're doing a document, if you're downloading
a lot of information, the software in the computer in
the system will warn about that. So there's ways to

(50:56):
manage around that and gather of the information you need.
And everybody has a self right now. Your your phone
is a beautiful camera, you know, and you can take
pictures of things and and not you know, have to
have to, you know, move to fiscal media. A lot
of laptops now obviously at companies they don't even have
like you can't even slide you know, uh, you know,
electronic media. And I would say that I don't be

(51:17):
your own pr person, don't talk to the media, don't
do those things. I've seen that it is not good
you you you're not you've not done this before likely
and you're putting yourself with a lot of risk. And
then you know, again, I'm one attorney. I mean, like
if people are out there, they're in that position or
like listening to this. There's the Anti Fraud Coalition. I'm
a member. There's a there's a whole uh list of

(51:39):
lawyers there that you can go to, uh the any
fraud Coalition that's you plain off side only lawyers, no
defense lawyers, and even go there and check it out.
You know, there are lawyers you can go and talk
to and yeah, we're there. I mean the people that
do this kind of work or you know they're they're
they'll pick up the phone, we'll talk to you. They'll
still give you some time. So that's what I would.

Speaker 1 (51:57):
Say, Phil, I wonder if you can flag for US
issues on the horizon. Where are you seeing areas of
either corrupt corruption or illicit business practices that should be
on folks radar?

Speaker 2 (52:09):
Yeah, so I see a lot. I'm not a policy
person by any means, but I do see common themes.
And what I would say, there's three things that I
that I think are going to kind of come around one.
I think that tiff fraud with the new administration is
going to be a big deal, that that is going

(52:30):
to be a really hot topic. And when you think
of tariff fraud, you're thinking, like, what does that have
to do with, like, you know, illicit finance and money laundering. Well,
tari fraud, what you're generally doing is hiding the origins
of something. So in this case, we deal with Chinese products,
and what you do is basically transship them, so you
send them to a second country and then obscure its

(52:52):
origins and then ship it to the United States as
that product. Now that sounds a lot like layering, doesn't it.
It sounds like money laundering, And we know in money
wandering that trade launder is a real thing. Trade launder
is a big, very very big area that goes on.
So I think that that's going to be a really
hot area given the administration's interest in terrors. Now, what
happens is if you don't pay terrors, you've you've omitted

(53:14):
a payment. We call it a reverse false claim. You've
kept money that you should have given to the government.
And depending on the rate it's twenty five percent, that
adds up very quickly. So you have a twenty five
percent fine that wasn't paid that you owe to the government,
Plus if it's not marked properly, you can add another
ten percent onto it. So effectively, for every you know,

(53:35):
million dollars that is imported to the United States, three
hundred and fifty thousand dollars wasn't paid. That was that's
owed to customs. And if you know about that, and
it goes on for a long period of time, that
adds up to a lot of money. And the way
the program works there, it's triple damages and then the
relater gets fifteen to twenty percent of that as a

(53:55):
reward for bringing the claim. So I think that's going
to be a big area. I think it's going to
be a really hot topic. The other topic I think
is going to be big is we've talked a lot
about these offshore companies. I think that the rating agencies
that great offshore companies should pay keen attention to the
companies that they're rating. I think that they give a

(54:18):
seal of approval to companies that allows them to do business.
And I think that given the enhanced focus on money
laundering and stopping it and rooting it out that companies
that are rating. Companies that get caught doing this, I

(54:39):
think are going to get in a lot of trouble.
And I think that's going to be an area that grows.
And finally, I think this is close to your heart
is in the crypto world. I think that we're going
to see less of these big policy debates about crypto.
I think with the change of administration, I think it's gonna
be less about, you know, the legal structure of crypto.
I think it's gonna be a lot more about enforcement.

(55:00):
I think that's where we're going to see. I think
we're gonna see a lot more for AWD enforcement. I
think the resources that have been spent on these policy debates,
and they've been very vigorous, I think are going to
turn more to enforcement. I mean, my view to crypto
is very straightforward. I mean, it's here, it's not going away.
We can't run or hide from it. If the crypto
is going to exist in the world and it's going

(55:20):
to be a financial product, America should be the best
at it and we should be at the forefront of
it because it's not something we can evade in a
global world. So, you know, and I think that the
you know, there's there. You know, I was talking to
you earlier before we were thinking about doing the show.
You know, I investigated a case, and this is the
kind of stuff that I think that the government's going
to be more interested in. I was looking at a

(55:41):
crypto firm that was offering to take your physical gold
and give you crypto and then you could take that
crypto and give it to anybody else and get gold
in return. And as you know X the United States
and Europe, gold is a huge currency for illicted the

(56:02):
illicit markets. I mean, we don't think about that here.
I know you you're well aware about how important gold
is to the world. You know, when it comes to
a listed finance and it's a very important payment, uh means.
But I think that that's going to be more important.
We're going to be kind of coming to the forefront.
I think crypto is going to see more enforcement on
fraud and and that's going to be kind of the

(56:23):
development that I see and that you know, yeah, and
I frankly my view is that you know that you know,
crypto's kind of interesting. If I was to be a launderer,
I wouldn't like crypto because of the blockchain. I mean,
I think that that's the thing that you know, sort of,
I think there's a lot of things that are very
anti a m L associated with with crypto and blockchain

(56:44):
that can actually thwart you know, people from from engaging
in you know, illicit conduct and there. I think there's
a lot of other ways if you're really trying to
move money, you know, when you really want to do
it in a way that it's anonymous. There there are
a lot of more traditional ways to do it. They're
a lot easier. And I'm no expert in crypto. It's
just you know, sort of what I see and what

(57:04):
i've sort of been, you know, looking at the trends and.

Speaker 1 (57:09):
Yeah, thank you, Phil, You've been doing this for a while.
I'm wondering if you could tell us, you know, why
do you do this work? How did you get to it?

Speaker 2 (57:20):
Yeah? You know, you know, like I started my career.
I worked in big law, big international law firms. I
was in house council at a public company. I was
North American counsul for European company. I started my own firm,
and you know, when I was in law school, I
was in a program the Department of Justice in the
Criminal Division, where I worked in an international office, an

(57:42):
international criminal assistance office, and I was exposed at a
very young age to the world of legal finance and
the rule of law. And in fact, I even went
to your old employer at the CIA as part of
like the whole sort of summer recruitment program that they ran,
and you know, I was I really thought it was
truly fascinating and very interesting, and I thought I would

(58:04):
always come back to it, you know, oftentimes that life.
I think we think our careers are not linear, you know,
we're always sort of bouncing around, but there tends to
be a theme and a trend. You know, we sort
of go back to what motivates us in the beginning.
And that's been the case for me. You know, I've
kind of come back to what I did my first
year in law school. I find it very interesting. I

(58:24):
think it makes a difference. And I'll tell you, frankly,
for me, like, you know, why do I keep doing it?
And it's a fair question. It's difficult. You don't make
a lot of friends along the way, you make a
lot of enemies. I have a very really special job
because I get to watch people commit acts of courage.
I watch people walk into federal buildings voluntarily after being

(58:47):
told the odds. I tell them every bad possible outcome.
That's my job. I don't want to get sued from malpractice.
I tell them everything. And also because I care, and
I tell them like, this is what likely to happen.
This is you know the things we discussed today. And
they look at you and they say, sure, let's go,
and they walk right in and you see them tell
the truth and you see them believe in the system.

(59:10):
And I find it to be a very profound experience, frankly.
I mean it's deeply moving to watch people live out
you know, their values, the values of America. You know
what makes this country great That people kids look, they
believe that they can go and talk to their government
and tell them what's going on. And I have the
opportunity to be there and make a difference. And you know,

(59:31):
I wouldn't trade it for anything in the world. You know,
the ups and downs, the long delays, it's par for
the course. But when you know that that is what
people are doing and you get to help them, I
think it's rewarding in and of itself, and I keep
doing it till you know I retire or you know,
do something else in this world. But I don't suspect
that I will, and I'll continue on this path until

(59:52):
you know, you know I'm finish this career.

Speaker 1 (59:55):
When it comes to whistleblowers, as celebrated as they are
in movies or covered in the press, not everyone is
built for blowing the whistle. It takes not just intestinal
fortitude and a great deal of patience, but also an
unfailing moral compass to persevere through the grueling experience where
those you expose often do their best to make you
doubt yourself. I shouldn't call what Phil does is work. Clearly,

(01:00:20):
he sees it as a mission, and although he doesn't
work for a government agency or wear a badge, he
most definitely still is a financial crime fighter. Only Phil
fights with a legal brief. So if you're ever going
to step out and take a huge risk to do
the right thing, don't do it alone. Call Phil. I'm

(01:00:42):
yaya jata FINUSI. And this is designated on the Illicit
Edge Network