December 31, 2024 • 50 mins
Money launderers use creative schemes to go undetected while moving illicit funds. But what happens when the person fighting launderers is someone with firsthand knowledge of these tactics, honed through real world life experience and unique cultural insights? Enter Lourdes Miranda, a former CIA Officer and FBI Analyst who now consults in the private sector in Crypto Investigations, Blockchain Analysis, Financial Crime investigations, Fraud investigation and Compliance. Lourdes spoke with Designated host Yaya Jata Fanusie about her unconventional background and how it helped develop the needed expertise she employed to think like a money launderer.
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Episode Transcript
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Speaker 1 (00:00):
Today's program is supported by K two Integrity. K two
is the premiere global risk advisory firm. In an ever
changing world filled with uncertainties and risk. K two helps
clients with better insights, better solutions, and better decisions. K
two Integrity believe in better on Yaya Jata Finussi. Money
(00:34):
launderers use creative schemes to go undetected while moving illicit funds.
But what happens when the person fighting launderers is someone
with firsthand knowledge of these tactics, honed through real world
life experience and unique cultural insights. Enter Lordis Miranda. She
began her journey into the world of fighting financial crime
(00:56):
by witnessing its impact firsthand as a child. This early
exposure would ultimately shape her fascinating career path, which included
stints at both the CIA and FBI. Her expertise is
as unconventional as her story, and she proves that cultural
knowledge and intestinal fortitude are important compliments to technical skill. Today,
(01:21):
Lordas has expanded her fight against financial crime into the
private sector, advising corporations, startups, and fintech companies on anti
money laundering strategies. She share some of those strategies and
helps us figure out how to think like a money launderer.
(01:42):
It's time to get designated with lordas Miranda on the
Illicit Edge Network. I know that you are a financial
crime fighter, but let's go back to your roots. How
did you first get exposed to the world of money launder.
Speaker 2 (02:03):
Living in Upstate New York with a lot of time
between New York City and Upstate New York. My family
and was my brother, my late brother. He unfortunately became
a drug money launderer back in the seventies in the eighties,
and he would come home with duffel bags full of cash,
and my family and I lived in a small apartment
(02:23):
on the third floor. We had no idea what it was,
but I was curious and open up his duffel bag.
I was eight years old and I started playing with
the money. So my brother saw that I was enjoying
playing with the money, and he asked me to place
the dollars that he picked up in the streets to
put him in denominational order. And I decided to play bank.
(02:45):
And that's where my interest came is I was playing
with actually drug money and not even knowing it.
Speaker 1 (02:52):
So what happened with your brother and that drug money life.
Speaker 2 (03:00):
Other unfortunately got caught, did some time in state prison.
He did ten years, got out. He decided that that
world was no longer for him, and he decided to
volunteer his time and work at a prisoner release program
(03:21):
and he was in charge of helping prisoners who were released,
felons who were released, to go back into society. And
that's what he did for the rest of his life.
Speaker 1 (03:30):
So how did this impact you, and maybe even that,
let's back up, how did you discover that something wrong
was happening? I mean, you were playing with the money,
and then obviously your brother got locked up. But how
did you discover something was wrong?
Speaker 2 (03:49):
Well, first, my father bought me a little cashier bank,
which I still have a little bank, a cash register,
I should say, And I realized that I spent I
shouldn't say I, but my other siblings and my cousins
spent our entire childhood visiting penitentiaries, visiting the court system.
We were always at a law enforcement center or always
(04:12):
in court, and we just put two and two together
that this was not normal. And I remember one time
we were playing baseball outside and we had no idea.
This was nineteen eighty two, and we had no idea
that the people that the guys that were playing baseball
were with us were DEA agents undercover. I mean they
(04:34):
had lunch with us and everything, and I remember the
DEA agent says, Oh, do you want my pickles from
his hamburger? And I was like yes, And next thing
you know it, he got up and told my parents
in Spanish, get the kids outside. I had no idea why.
And then we saw my brother and a couple of
cousins being handcuffed and escorted downstairs and outside into patrol cars.
And so this day I can't have pickles because I
(04:55):
remember that it was horrifying, and I remember the horror,
horror look on my parents face. They were mortified because
it was a public arrest. I mean, the whole neighborhood
was outside. So that's what I realized. That's what really
hit me that this is not going to be my life.
Speaker 1 (05:15):
And I mean, just to clarify there, I mean you're
saying that the DA agents they were like young guys.
Speaker 2 (05:23):
Yes, being a kid, everybody looked like an adult to me,
and they were undercover. They had NYPD undercovered, and it
was a big drug bust my brother was the drug
money launder. That's when I really truly realized he was
a bad person, and it really broke my parents' hearts.
On top of visiting him, we spent our childhood visiting
(05:43):
him in penitentiaries where there was a county jail, state penitentiary.
It was ridiculous, and we were always in out of
court trying to come up with cash for his bail,
and I was in charge of the money even til
he was incarcerated. My parents would have me hold the money.
I would have thousands of dollars in cash in my
(06:04):
coat pocket walking the streets in New York, walking into
the courthouse or a jail to bail my brother out.
Speaker 1 (06:15):
So while you're seeing this happen, and you know your
brother goes in that direction, I assume growing up and
you're in high school, how did you decide that you
would go into a profession that would lead to what
you do today.
Speaker 2 (06:31):
It's funny. It was actually college. I mean I always
liked numbers. I was always good with numbers, and I
excelled in math. And then when I was in decided
to attend college. I decided to major in criminal justice
in finance. I should have majored in accounting, but I
didn't know that in nineteen eighty five. So I just
(06:54):
combined both finance and the criminal justice system into one
major and that's what I did. So but you know,
I talked to my brother about that, and my brother
and I had a lot of conversations one on one,
and he told me how they laundered money. I'm like,
how did you do it? And he would share all
his methodologies. He even had back in the day they
(07:17):
had those green, heavy ledger books, and I remember he
would assign me to calculate the math in the ledger books.
So I was playing accounting with I didn't even realizing
what I was doing. And you know, he told me
how he did it. He shared a lot of information
with mem.
Speaker 1 (07:35):
So what were some of the things that he did
that you that he shared?
Speaker 2 (07:39):
Oh, one thing, he used children like me, my sister,
and my cousins to go structure money, make deposits and
banks throughout New York and back in the seventies and
the eighties, they I don't even remember the bank tellers
ever asking for ID or you know, identifying his source
of fun. Why all this cash? It always brought children
(08:02):
with him. I guess it made him less vulnerable to
bring kids around. So yes, he used us. So that
was one method how he structured money, how he laundered
money into he placed money into the financial institutions. And
he also used us as couriers. I remember my sister
and I would jump on our bikes and our cousins
would jump on our bikes make deliveries without even realizing
(08:23):
what they were.
Speaker 1 (08:25):
So you had that very real experience. You go to
college and you you know you're learning finance, you're learning
criminal justice. I'm going to jump ahead and you can
fill in the blanks because you end up at the CIA.
So so how did that happen and what were you
doing at the CIA?
Speaker 2 (08:46):
I never thought I would end up at the CIA
in a million years. I moved from New York after
graduation to Washington, d C. And I got hired at
a private law firm that specialized in white collar crimes.
And they were the They weren't the defenders, they were
(09:06):
the ones that were hired by corporations. So I did
a lot of corporate fraud cases, a lot of identity
theft cases with corporations, and then nine to eleven happened,
and I became a nine to eleven applicant because I
was here in Northern Virginia working at a law firm
as a criminal investigators and a lot of people don't
(09:27):
realize a lot of law firms hire criminal investigators with
a finance background because we had to do forensic accounting.
So long story short, nine to eleven happened and had
two recruiters coming into our office and asked our boss.
The partner of the firm said, Hey, we're looking for
(09:48):
people who can follow the money and meet a group
of people, join a conversation, and I joined the CIA
six months later. It helps that you don't have anything
in your background to dismiss you from the security application.
In six months I was at CIA. I had no idea.
Never in a million years I thought it would be
(10:09):
at CIA, because I thought at CIA you had to
have a PhD. Or a law degree, or fluent in
Arabic or Chinese or some critical language. Yes, I spent
ten years.
Speaker 1 (10:22):
I have a question. I mean, I hope this is
not too sensitive for me to ask, because I know
what that process is like at the agency, going through
the whole recruitment, the security and you whatever you want
to share, you can in that conversation where you're talking
to the investigator or the poligrapher, did they talk about
(10:42):
did you talk about the stuff from childhood? Or was
that just too far, too far off?
Speaker 2 (10:48):
No, that's a great question, because, as you know, it's
very painful process. They break you across the coals. And
it was actually the psychologist because you have to go
through a psycho logical profiling, and the psychologist was asking me
all these questions about my family, thinking, Okay, how does
(11:08):
she turn out the way she did with all these issues?
And then security came and security was asking, put it
this way, My polygraph took two full days because they
were trying to figure out, with her family history, how
does she get either got away with it or she's lying. Literally,
my polygraph took two full days because they were trying
(11:30):
to figure out how I became this person considering my
family background, my family history, because it just wasn't my brother,
It was cousins and uncles and aunts who were fraudsters
and drug traffickers, etc.
Speaker 1 (11:45):
So I wonder, I mean once, because they do break
you through the colds. That's it. That's the perfect metaphor.
Any torture that you can think of. That's the great
metaphor for the CIA recruitment process. But I'm wondering when
they saw that you were legit, that you were, you know,
smart and capable, do you think that sort of was
(12:06):
maybe was in your your favor because you had been
through so much and had overcome.
Speaker 2 (12:12):
Yes. Actually, I'm glad you brought that up, because after
the psychological profile, they realized that a lot of things
don't bother me. You could throw a picture of a
dead person in front of me, I'm like, okay, I've
seem worse. So I was like desensitized based on my childhood.
So it did benefit me. I was street smart. A
(12:36):
lot of graphic information did not bother me. I could
sit with assets on handcuffed, I followed terrorists didn't bother
me at all. Of course, there's some fear. It's always
good to have fear because fear keeps you sharp. But
I was it didn't. It was strange. I would desensitized
to the threat because I grew up with the threat.
Speaker 1 (12:58):
So and so talk us through what you actually did
at the CIA.
Speaker 2 (13:06):
I was a targeter, And what a targeter is, It's operational,
it's actual intelligence. We work with case officers in the field.
Where I use this metaphor, the case officers a driver
of a vehicle. I'm in the passenger seat, navigating the
case officer where to go, what door to break down to,
who to speak with, who to recruit. Also, my job
(13:30):
was to fuse intelligence gaps, develop leads, and since with
my finance background and my financial crimes as a criminal
investigator background, I knew how bankers thought. I knew how
they moved money. I knew how they laundered money. Of course,
thanks to my brother, all those different methodologies and also
(13:50):
cultural they leverage my cultural background, my language background, and
the fact that I grew up in the streets the
streets around helped a lot.
Speaker 1 (14:01):
So give us an example of how your expertise was
utilized in some of these cases.
Speaker 2 (14:10):
Since we were targeting drug traffickers and transnational criminal organizations
drug trafficking organizations, I was happening to I was listening
to some tapes, some recordings of surveillance, audio surveillance and
physical surveillance, and I was taking notes because as a targeter,
my job was to fuse intelligence gaps, develop leads, and
(14:33):
so forth, and I was listening to the drug traffickers
and I realized, being Puerto Rican from New York, there's
some slang. And I realized that they were using the
term chawo. Chawo in Puerto Rican Spanish means money. So
I realized, wait a minute, we're not targeting Colombian drug
(14:55):
traffickers as we thought we were. These are actually Puerto Ricans.
And I brought it to my leader, my chief, my
group chief, and he goes explained more to me, and
I was like, I'm Puerto Rican from New York. We
say chawo. When somebody said showo, I know automatically they're
Puerto Rican. You know, these guys are saying chowo. You know,
in Latin America the term for currency is either baso,
(15:18):
dino plata and so forth. They're saying chowo. And sure enough,
long story short, we did more intelligence gathering and they
were Puerto Ricans but living in Colombia, and they were
moving trafficking from Colombia to Puerto Rico. And I said, now,
these guys are Puerto Rican. And that's how my upbringing
(15:39):
and my background, my cultural background as well, helped the case.
Speaker 1 (15:44):
And so you know, so you spent time at the
agency as we call the CIA, but I know you
you also worked with other organizations, So how did you
transfer to other agencies?
Speaker 2 (15:58):
I decided to make a change because at CIA, you
travel a lot outside the US and I was exhausted.
I wanted to reconnect with my family because there were
some deaths in my family. So joining the FBI, it
was more domestic mission. It was more likely to stay
within the US. I can spend more time with my family.
(16:18):
And then at the FBI, I was assigned to the
white Collar Crime Squad, and with my background, I was
assigned to the New Jersey slash New York offices, and
I was specializing in trade based money laundering because there's
a lot of New Jersey, New York ports, shipping ports
and airports, so that was my line of work as
(16:39):
an analyst there, and I worked with the FBIS. So
with the FBI, we were notified a credible threat a
target was flying in to JFK was reliable threat, reliable intelligence,
credible intelligence from a reliable source. But when we did
(17:00):
our investigations at FBI, They're like, no, they can't be
the same person. I'm like no, if we're targeting a
Latin American person, I know for a fact, culturally speaking,
I learned just from my own personal experience in my
culture living in New York. Also to Cia. A lot
of Latin American countries, men use the maternal surname that's
(17:23):
legal and culturally acceptable. Because, for example, I know Chappo
from Colombia used his mother's name totally legal and culturally
acceptable's on their legal documents and their birth certificates. I'm like,
let's do a search on this target using his maternal parents,
maternal mother and grandparents, and sure enough, there was a hit.
(17:46):
He was using both his mother's name as his last
name and his father's name is his middle name. And
the United States and our culture, we just assume that
when people get married or they have children, that they
had take their father's last name. That's not true in
a lot of the Latin American countries, not even in
Puerto Rico, because my mother used her last name and
(18:07):
my father used his name. So it's funny because every
time we knew my father was mad at my mother,
he called her missus Miranda. So that's funny. Anyway, I digress.
I digressed, So I did some quick searches on travel
with using the target's maternal mother's name and maternal grandmother,
(18:28):
and sure enough, he was using him. It was on
his passport. He purchased his flight using both names, and
he was using his mother's last name as his surname.
And they were targeting him and following him using his
father's last name. There was a hit, and I taught them,
I said, don't assume if a target is a man,
(18:48):
he's using his father's last name. That's not true. And
a lot of cultures and a lot of countries, so
I taught.
Speaker 1 (18:54):
Them that, right, right. And so you were dealing with
a lot of movement over the border. Like you said,
there's plane travel. You mentioned ports. You also mentioned something
you said trade based money laundry. Many in our audience
know what that is, but some people don't.
Speaker 2 (19:13):
What is that is when you're using commodities goods to
launder money. For example, a bad actor overseas can make
could buy a thousand cars have them shipped to the
US as rather than as a source to sell it.
The is a source of payment for the bad actors.
Rather than paying a bad actor in cash, you paid
(19:34):
the bad actor with a.
Speaker 1 (19:35):
Carm and so did you see those sorts of cases,
you know, come up across across the ports. How did
you interact with that type of crime.
Speaker 2 (19:48):
We collaborated with other agencies that also own that mission
as well, and we just we collaborated with other agencies,
and again they used my expertise because of lot of
documents were in Spanish, A lot of targets that we
interviewed spoke Spanish, and I've learned very quickly, and a
(20:09):
lot of cultures. If our targets are male, I would
bring an agent or somebody a linguist who is male
to speak with a target, and I just sit in
the background. So then you have to remember when you're
interviewing targets or following a target, you know, you have
to remember culture. A lot of men and a lot
of cultures won't speak to women. So I was made
(20:30):
sure I had a male who spoke Spanish, or an
agent who spoke Spanish, a male agent.
Speaker 1 (20:35):
So you could kind of sounds like you could sit
in the background. You're probably the wiser, sharper analyst in
the room, and you just bring you bring in some
guy who looks the part right as an agent or
something and the suspect is talking to him while you're
just taking mental notes.
Speaker 2 (20:52):
No, I was actually taking notes. They thought I was
a secretary, and I was okay with that because more
comfortable they are, the more they talk. That's our goal,
are you, kitty. I even serve lunching coffee.
Speaker 1 (21:06):
For some Okay, right, So you mean while you're while
there's a target or suspect.
Speaker 2 (21:12):
Correct, If we found a source, a target, an asset,
depending on the agency identifies that term. Uh, sometimes we
sit with them, whether it's in an office, in a hotel,
or a restaurant. Use this in the back, use it.
I don't speak, and sometimes if we're in a hotel,
(21:32):
I'll bring them lunch. I'll even clean up for them.
And I'm the one that's actually collecting the intelligence or
feeding the agent or whatever who was there information? Like,
ask him this question because my job as a target
and also as an analyst the FBI is to supply
questions to the agent and also to the case officer.
(21:54):
I'm like, ask him this because they leverage my background
in finance, background in you know, financial crimes investigations. So
that's what I did.
Speaker 1 (22:04):
So, I mean, so we're talking about your career, which
has spanned twenty twenty plus years in the financial crime space.
But I know you've moved on, You've done some different things.
What are some of the challenges of working in that
intense environment? The bureau, the CIA.
Speaker 2 (22:27):
Long hours, really long hours. A lot of people think,
because you work for the federal government, you're nine to five.
That is not true. Bad actors will end at five pm.
They actually start sometimes at nine pm. Long hours, working
weekends away from your family, working holidays away from your
family was a challenge. And a lot of people think
(22:47):
because you're doing surveillance, you're working CIA, it could be dangerous.
I mean people can with the social media and take
today's technology, people can find out your true identity and
it could be a threat. It has happened. A lot
of us have been targeted personally. So that's a challenge
to maintain your uh, your privacy is difficult because bad
(23:10):
actors can find a lot about you.
Speaker 1 (23:12):
How do they target uh, not you or but others
that who have been targeted in what way?
Speaker 2 (23:18):
Oh, they'll send you mail, sometimes they'll call you if
they find out your phone number and if and if
you buy a house, you're the fact that you purchased
a house. It's public information. They can find out where
you live. They show up at your door, they put
notes on your car. They've I know an agent who
worked on the borders in Arizona and they were target
(23:42):
practicing with their kids playground set. You can see bullets
in the playground set. It happens. You just don't hear
about it. It happens. We can be targeted. So that's
one challenge. The other challenges lack of privacy. You when
you have a security clariance, you have no expectation of privacy.
(24:04):
That's a challenge. Another challenge is keeping up with the trade.
A lot of bad actors. They have deep pockets, lots
of money, a lot of access to resources. Is keeping
up how they engage in criminal activity. That's definitely a challenge,
especially when they cross borders. And once they cross borders,
who has jurisdiction that's another challenge. Then we have to
(24:27):
determine which border they cross, which country, who to contact.
Then we have to collaborate with other agencies, other international agencies.
If they cross borders and who has jurisdiction, You know
you have geographical jurisdiction, you have jurisdiction to either interview them.
(24:47):
That is the number one challenge is when bad actors
cross borders and they're advancing technology, because they have the
resources to buy technology, they move faster than we can
keep up with them. Sometime technology helps them get lost,
so that's another challenge. So geographical cross bording of bad
(25:09):
actors is definitely number one challenge.
Speaker 1 (25:11):
Yeah, and there are a lot of people who see
this life and think it's glamorous and want to want
to pursue it. Right, But I mean you mentioned even
the privacy issue. A lot of people don't realize it, right.
They see that security clearance. I think that's their ticket.
What are the privacy challenges?
Speaker 2 (25:30):
You have to tell me your whole life story, Like
my family, I was hesitant when I was completing my
security application and I'm like, oh my god, I got
to put down my brothers, I got to put down
my sister. What they did it was like a manifesto.
I had to do a dendums. So that was challenging
(25:53):
because to me that was private and I didn't want
them to judge me. And again, two days of two
full days of being polygraphed because they're trying to determine
is she either good, lied or got away with it
or what? Why is she so different than her immediate
family and her extended family because they have to know everything,
I mean literally everything about you, because if you don't
(26:17):
put down and document what you've done, because not everybody's perfect,
they're going to find out about it anyway and challenge
you on it.
Speaker 1 (26:24):
M Well, speaking of privacy, I know that you've done
some private investigative work. We don't meet private investigators. I
mean when I first learned that about you, I'm thinking, Oh, lord,
is is sitting sitting in the sitting in an office
with their feet on. She's got a fedora cap and
you know, she's waiting for some She's waiting for a
(26:45):
dame to walk in with a cigarette.
Speaker 2 (26:47):
You know.
Speaker 1 (26:48):
So is that what the you know tell me about
you becoming a private investigator.
Speaker 2 (26:53):
It's funny because once I left the government, I joined
the private sector. And one of the things in the
private sector that I learned, especially with corporations, is that
they have a lot of internal investigations that's not disclosed
to the public because they don't want to have a
reputational risk that their corporation company was exploited or was vulnerable.
(27:15):
So they hire a lot of people with my background.
So when I got hired, one of the criteria was
I needed a private investigation credential. I'm like what, because
I always thought being a private investigator was surveilling people
who were committing infidelity heaven affairs. That's not true. A
(27:36):
lot of corporations in the United States, as well as
outside the US, hire people with my background because I
came from CIA and FBI to conduct internal investigations. You know,
there's always an insider threat, I don't care where you are,
and a lot of corporations hire people like me to
create a threat matrix to identify the companies and corporations
(27:58):
vulnerabilities and help them fuse those vulnerabilities and actually conduct
investigations and speak with employees that were under suspicion for
embezzlement or fraud timekeeping. Fraud is a thing even when
a lot of people are working remote now, so a
lot of bezzlement cases a lot, So that's why they
(28:21):
hire people. But in a lot of states like Virginia
require a private investigator credential. And I remember when I
went to the six week class, They're like why are
you here, said, I have a client that requires the credential.
Plus with this credential, I have access to a lot
of public documents that the average citizen can't have because
(28:44):
I have this credential. And of course this credential requires
a background check, fingerprint check, even a credit check on
you to make sure you're legitimate.
Speaker 1 (28:55):
And so when you're doing private investigative work, I'm assuming
not all of it is from behind a keyboard. I mean,
I'm sure there's a lot of records you can access,
But are you actually doing stuff walking into places investigating?
Speaker 2 (29:10):
Yes and no, because a lot of these corporations hire
a group of us and I do more of the
forensic analysis I've had worked. I have walked into facilities
like stores, department stores, hospitals. You'd be surprised there's a
lot of theft in hospitals. Yes, department obviously department stores.
(29:32):
But I was shocked how much there's a lot of
theft in hospitals. So yes, I walked not by myself,
but I actually walked in with other private investigators who
were hired by the corporation.
Speaker 1 (29:45):
What would you be doing walking into a facility as
an investigator?
Speaker 2 (29:49):
Oh, a plane close. You know, we don't walk around
like perfect example, when we were investigating in a hospital,
we walked in. We found out that when somebody in
the corpor someone was actually hospitalized, so we asked for
their name to go visit them. That helps, you have
to have a backstory. And we were surprised how easy
(30:13):
walking through this hospital was at the time. And as
we were visiting this person, we just happened to, you know,
go to the cafeteria, walk around, roam around and conducted
our investigation. It was also really easy to even go
into the kitchen at the hospital without and plus the
way I look. Majority of the people, I hate to say,
(30:34):
our Latinos who are cleaners or help and I just
dressed down with jeans sinkers and walked in as if
I work there.
Speaker 1 (30:42):
So I'm trying to picture this. I know you can't
give up all the trade secrets and the trade craft,
and obviously you know we will be very sensitive to that.
But in this investigation, is it that you're supposed to
observe if someone is committing the fraud, if they're doing something,
(31:03):
so you have to just basically kind of do surveillance
in their job location, correct.
Speaker 2 (31:10):
We had a target at one hospital who first of all,
was not clocked in on the day. We've identified that
person in the hospital. They were not supposed to work
that day, but they used their credential to get through places.
They met with someone at the cafeteria. Information and also
to be careful because of privacy with US citizens. So
(31:34):
you know, we just observed their activity and just reported
it and that's all I can disclose. And of course
privacy is an issue. We have to be very careful.
That's why we're required to have this credential. Not anyone
can just walk into a hospital. It conducts surveillance on
someone without invading their privacy.
Speaker 1 (31:53):
Okay, And that's a good disclaimer for designated and we
don't want to designate anyone to write to designate it
saying that you don't try this at home is what
we're speaking. You are not trade unless you have that credential.
Do not go and start doing surveillance on your employees.
Today's program is supported by K two Integrity, the premiere
(32:16):
global risk advisory firm. In today's world, threats can arise anywhere,
at any time. Threats to your organization's operations, financial stability,
or reputation. K two offers a better way to counter
the threats facing your organization and provides critical intelligence and
actionable strategies to uncover the truth, make decisions, and reduce risk.
(32:40):
K two helps you face critical challenges with an experienced
team and the ability to navigate the most complex issues
to arrive at better outcomes. That's why clients partner with
K two to help them thrive in an ever changing
world filled with uncertainties and risk by providing better INSIGHTSS
(33:00):
and better decisions K to integrity believe in better. I mean,
let's be real. You said something about people may have
certain assumptions about you. Tell us more about that.
Speaker 2 (33:15):
Oh yes, it helps with your appearance. So one of
the reasons why this corporation hired me is because obviously
they saw my website. It's like, we need somebody that
looks like her. You know, I'm five feet two, I'm Latna,
and unfortunately, a lot of in this area where I live,
(33:35):
there's a lot of people who look like me who
are actually the help. The workers, the cleaners, they pick
up the garbage, the painters, they work very hard. And
I just blend right in and I speak Spanish, and
as a matter of fact, I remember we were going
to court and I had to dress up to testify.
I walked into a bathroom in one organization and I
(33:57):
had a suit on, and the woman who was in
ask me in Spanish. She goes, are you the boss?
And I'm like, I didn't want to get into details
with her. I said yes, I'm a manager, and she goes, oh,
I'm surprised. And I knew what she was saying, as
I was Puerto Rican five foot two and I was
in a position of authority. So it helps your parents' helps,
(34:18):
It really does. It really does help. So you don't
want to send in a tall, blonde hair male Caucasian
mail to do some investigations in Hel's kitchen in New York,
for example. You mean, somebody look like me.
Speaker 1 (34:33):
But in all these places, you know, often there's security,
right and I think about airports, I think about other
public places there's more security. I mean, how can you
you know, how do you deal with that sort of
level of surveillance on you?
Speaker 2 (34:47):
Depending on the location, we have relationships with security at
that location. We communicate with security. They know who I am,
so when they see me, they just let me through
doors that are locked. I'm like hello, and they'll just
swipe their badge. So, yes, there is some corporate cooperation
among the security and some facilities, some organizations, some companies. Yes,
(35:13):
somebody has to know because I can get arrested for trespassing.
Speaker 1 (35:17):
Right, You're right, that's a good that's a good warning.
Speaker 2 (35:21):
You know.
Speaker 1 (35:22):
Lord is one thing that I really admire from your
background is you've done so much and on our show
we've talked to people who've dealt with compliance at major banks.
You've worked in the compliance anti money laundering compliance space
for a while. Can you tell us a little bit
about the difference between compliance at a big bank and
(35:47):
a small company. What experiences have you had or observations
about small companies and anti money laundering.
Speaker 2 (35:55):
When I joined private sector, you know, I left the
government joined the private sector. I establish my company, the
Fintech Advisory Group, and I basically pitch myself to support
small companies and especially in the crypto space. And I
know this is a discussion is about crypto, but a
lot of startups, FinTechs, they contact me, and a lot
(36:19):
of them are based out of the US, and they
want to provide products and services in the US. So
the challenges with the small companies who are based outside
the US that want to provide products and service in
the United States is registration. You know, they need a
lawyer in the US. So their challenge is first of all,
(36:39):
language cultural barriers. Which US bank they need to open
an account with? Who, which US regulator? They need to
register their corporation where it's a little startup with. So
that's when I come in and help them. And you know,
a startup is very challenging when building a compliance program
because I have to help them register, I have to
(37:00):
help them find a US bank, I have to help
them find a US attorney. So a lot of startups
have those challenges. Corporations already established. They're bigger, they're more financed,
they have bigger compliance departments, they're mostly established. We're startups
and FinTechs. It's me that starts the compliance program. It's
(37:24):
just me, and then I have to bring in compliance
officers and investigators. So that's one challenge. Is resources.
Speaker 1 (37:31):
And so if a company is a small company with
limited resources, I imagine it would be a target for
people who say, you know, criminals that are like, okay,
let's use that you know, so you know, what's help
me think like a money launder. If I'm a money
launder and I'm looking for a good platform to launder
my money, what would I do?
Speaker 2 (37:54):
You know, it's funny you say that because I've only
been in compliance for four and a half years. I
spent over twenty five years combating financial crimes and terrorst financing.
So a friend of mine who worked at Treasury Department
when I was at CIA, she was at Treasury and
she contacted me. She worked at a startup she retired
from Treasury called. He said, lord, is I know you're
(38:15):
in the private sector. Now I need you to join
our little startup and help me build a compliance program.
And I said to her, I said, I'm not a
compliance officer. I don't even know where you begin. And
she said, no, I need you to teach my compliance
officers how to think like a criminal, how you know,
teach them what you learned out in the field. So
(38:38):
then I coined the phrase you know the other KYC.
We all know KYC stands for know your customer. I
coined a phrase, the other KYC, know your criminal. So
she brought me on board and I tell her compliance
officers how to think like a criminal before they on
board a bad actor. This is how criminals think. This
is how they move their money, this is how they talk,
(39:00):
this is how they established their organizations. This is some
things you need to consider when you're onboarding. Conducting compliance,
conducting due diligence, conducting enhanced due diligence, and personal profiles
as well as business profiles. So that's what I did.
I helped them think like a criminal. And I'll give
you a perfect example. I had one fintech hire me
(39:21):
as as a fintech advisor, and I said to him,
when they brought me on board, the first thing I
did was look at their website. One of the things
that bad actors look for is they look at people's websites.
That's where they usually go because they want to see
how long the website has been established. Because a lot
(39:43):
of platforms, you can find out how long the company's website,
how long it's been active. Can really find that out.
A lot of bad actors find when the website was established,
when the company was established. You know, I tell a
lot of fintech firms, don't put your copyright on your website.
(40:06):
At a firm that put their copyright twenty twenty three.
That tells bad actors your brand new, brand new means
you're small, your startup, you have limited funds. You you
may not even have a compliance program. Your easy target.
They'll check out your website, they see your copyright, they
(40:26):
see you're not registered as an nmsl LS. You know
that's the money transmitting license. They don't see your register
with a money service business. Because when you're when a
company is registered with a money service business, all you
got to go is go to Finnsend's website, type in
that company's name to see if they're registers of money
service business. Bad actors know that, and when they can't
(40:49):
find your web your name on finn Send's website is
a registered money service business, they know you're not a
register MSB. That's another vulnerability that you have because it
tells you a bad actor they don't have their act together.
This is easy, let's open an account with them. Another
thing that I see on fintech websites. A lot of
(41:10):
these startups, because most of us work remote, they use
their home address as their business address. Any bad actor
can google that address and find out that's not your
business address. That's another vulnerability that company has. And then
on the website there's a phone number that's the CEO's
personal cell. You don't want that. Again tells a bad
(41:32):
actor is a small company, and a bad actor is
a small company. Again, they may not have a compliance department.
They may not have investigators to vet me when I
open an account. This is easy prey. Another thing, a
lot of companies don't have a lot of startups that
I tell you must have a link, you know, when
(41:54):
you scroll down at the end, you must have a
link you know, for any questions or queries click here,
email us. A lot of these startups don't have that.
And I said, and you don't have a law enforcement information.
A lot of startups need a law enforcement link. Like
if you go to my website, you click on law enforcement.
That's a link where law enforcement can reach out to
(42:16):
me if there's an issue with one of my clients
or one of my customers. A lot of these startups
don't have those links. Because a lot of these startups
they can email the CEO directly. That's not a good idea.
And a lot of websites don't list the countries that
they offer their products and services to. You know, a
lot of bad actors like, oh, they only offer they
(42:39):
don't have a list of countries, so we can open
an account in any country our bad actors are located.
That's what bad actors look for when they click on
a startups website is how vulnerable is this website? Another
thing bad actors do when they find a company, a
startup that they want to open an account with, they'll
actually go to LinkedIn and check out that company's LinkedIn profile.
(43:03):
And I always tell my clients, if you've got to
have a LinkedIn account, you got to list all your
don't list just two people at this company, because again
that tells a bad actor. You're a small company. This
is easy prey, So be careful with that your LinkedIn profiles.
And again yeah, I always tell startups, you know, tell
(43:26):
them you establish for many years. Let bad actors know
that you have your act together. Another thing is you
got to have an attorney. A lot of these startups
the hire attorneys once they get established. You got to
have legal counsel employee full time always. You got to
have a compliance officer chief compliance officer full time always.
(43:49):
And you have to have your registration number when you
register with federal agencies, regulators. I mean, all those things
tell a bad actor this company is very small, limited funds,
easy target. And number one that bad actors do is
they call and do a complaint. They want to see
(44:10):
how many how knowledgeable your customer service representatives are. They
want to see how many customer representatives you have and
how knowledgeable you have they are of the company's products
and services. And sadly, you be surprised how many customer
service reps don't understand the products and services of the
company that employs them. And a lot of bad actors catch that,
(44:30):
so they exploit the customer service replying to the rep saying, oh,
we accidentally sent funds, could you refund me? And commit
all sorts of fraud. And the number one goal for
customer service reps is to keep the customer happy, so
they'll comply with all these lies. And another thing bad
(44:51):
actors do they exploit social media and they complain about
their startup and a lot of regulators and law enforcement
monitor these social media sites to see all the complaints
by customers about this company, and those complaints tells us
a lot to regulars and law enforcement that this company
(45:11):
doesn't have their act together. Why there's so many complaints
and a lot of bad actors lie. They complain on
social media about a company that didn't do anything. You
just want to make that company vulnerable.
Speaker 1 (45:24):
So it sounds like a smaller company. And you have
to be careful if you're moving fast and breaking things thinking,
you may fake it till you make it. When it
comes to finance and money, that can be very dangerous.
Speaker 2 (45:38):
Very dangerous. You've got to let the bad actors know
you have to act together. A lot of bad actors
also read the terms of use. You've been surprised a
lot of starters or didn't have a terms of use.
The terms of use tells a lot about the company.
You know, whether they have a legal team, they have
a compliance team, to have investigative team. Yes, you'd be
(45:58):
surprised a lot of these even have that.
Speaker 1 (46:02):
Lords you with all of your experience, now, I'm wondering
if there's any advice, whether it's career or otherwise, that
you would give to lordis Miranda twenty years earlier now
that you could look back.
Speaker 2 (46:17):
If somebody told me twenty years ago what to do,
that makes me even a stronger analyst slash criminal investigator
is to major in a county finance international relations because
financial crime, investigations, cases, whatever you want to call it,
(46:40):
it's global. And pick up a foreign language. You know
majority of the people now know Spanish. Pick up a
critical language. You'd be surprised how many federal agencies hire
people who majored in French, who in critical languages, Arabic, Chinese,
(47:02):
you name it. Get a law degree. You don't have
to practice law, but law degrees teach you analytical skills.
You have to have strong analytical and critical skills to
be a great investigator. Let's see, you have to be
a perfectionist. That's a must. That's because nothing drives me
(47:24):
crazy when I have a case. I'm looking at a
case from an analyst or a criminal investigator because it's
very sloppy. You got to be organized. You have to
be a perfectionist. And you know today in this age,
a lot of people speak in acronyms. One thing, if
anybody can take one thing away from this whole discussion
(47:45):
is don't write and don't think in acronyms, because acronyms
can mess up a case. It can pitch a case,
it can compromise a case. It can get somebody killed
and hurt. I'll give you a perfect example. I was
in my office. I had a junior an investigator come
over to me and was speaking to me. Hey, I
found a source, because you know you were at CIA.
(48:06):
It's all about your source. How credible is the sources? Right?
I'm like, who's your source? He said the IG And
I looked him the Inspector General's office. He said, he
goes Instagram.
Speaker 1 (48:20):
So this was maybe a gen Z or millennial. Maybe
I'm not going to go.
Speaker 2 (48:24):
There, Okay, in my mind, his head exploded. He saw
the look on my face. He literally ran out my office.
I went after him. I said, what did I say
about speaking in acronyms to me? Because that can break
a case, that can get somebody killed. I remember being
out in the field. We didn't speak in acronyms. I mean,
we spoke in code, but everybody understood the code. If
(48:46):
we said IG out in the field, everybody in that
mission knew what IG meant. So don't speak thinking right
and acronyms. So that's one thing I like to share
with the audience. Other believe it or not, psychology degrees
who knew because human intelligence and artificial intelligence work together
(49:10):
every day. You'd be surprised how many psychology psychologists that
we work with. I don't care what agency you're with
a lot because a lot of psychologists, when we bring
them intelligence or briefing, they usually give us a profile.
A lot of psychologists come out to the field with
us and they don't say anything in the meetings, but
(49:31):
they just analyze the behavior. So yeah, psychology degrees, accounting degrees,
finance degrees, International relations degree because we're global.
Speaker 1 (49:44):
Speaking with lord Is reveals the power of adaptability, cultural insight,
and perseverance and tackling bad actors who are constantly evolving
their schemes, whether working undercover in the field or helping
corporations develop strong compliance works. Lordas has dedicated her career
to staying one step ahead of the criminals. Her advice
(50:07):
resonates beyond the world of law enforcement. Think critically, know
your adversary, and always aim to understand the systems at play.
As financial crime fighters like Lordus continue to clean up
the murky world of illicit finance, her work proves that
even the most complex schemes can be dismantled with the
(50:28):
right tools and perspective. I'm Yaya Jata Finussi and this
is designated on the Illicit Edge Network
Today's program is supported by K two Integrity. K two
is the premiere global risk advisory firm. In an ever
changing world filled with uncertainties and risk. K two helps
clients with better insights, better solutions, and better decisions. K
two Integrity believe in better on Yaya Jata Finussi. Money
(00:34):
launderers use creative schemes to go undetected while moving illicit funds.
But what happens when the person fighting launderers is someone
with firsthand knowledge of these tactics, honed through real world
life experience and unique cultural insights. Enter Lordis Miranda. She
began her journey into the world of fighting financial crime
(00:56):
by witnessing its impact firsthand as a child. This early
exposure would ultimately shape her fascinating career path, which included
stints at both the CIA and FBI. Her expertise is
as unconventional as her story, and she proves that cultural
knowledge and intestinal fortitude are important compliments to technical skill. Today,
(01:21):
Lordas has expanded her fight against financial crime into the
private sector, advising corporations, startups, and fintech companies on anti
money laundering strategies. She share some of those strategies and
helps us figure out how to think like a money launderer.
(01:42):
It's time to get designated with lordas Miranda on the
Illicit Edge Network. I know that you are a financial
crime fighter, but let's go back to your roots. How
did you first get exposed to the world of money launder.
Speaker 2 (02:03):
Living in Upstate New York with a lot of time
between New York City and Upstate New York. My family
and was my brother, my late brother. He unfortunately became
a drug money launderer back in the seventies in the eighties,
and he would come home with duffel bags full of cash,
and my family and I lived in a small apartment
(02:23):
on the third floor. We had no idea what it was,
but I was curious and open up his duffel bag.
I was eight years old and I started playing with
the money. So my brother saw that I was enjoying
playing with the money, and he asked me to place
the dollars that he picked up in the streets to
put him in denominational order. And I decided to play bank.
(02:45):
And that's where my interest came is I was playing
with actually drug money and not even knowing it.
Speaker 1 (02:52):
So what happened with your brother and that drug money life.
Speaker 2 (03:00):
Other unfortunately got caught, did some time in state prison.
He did ten years, got out. He decided that that
world was no longer for him, and he decided to
volunteer his time and work at a prisoner release program
(03:21):
and he was in charge of helping prisoners who were released,
felons who were released, to go back into society. And
that's what he did for the rest of his life.
Speaker 1 (03:30):
So how did this impact you, and maybe even that,
let's back up, how did you discover that something wrong
was happening? I mean, you were playing with the money,
and then obviously your brother got locked up. But how
did you discover something was wrong?
Speaker 2 (03:49):
Well, first, my father bought me a little cashier bank,
which I still have a little bank, a cash register,
I should say, And I realized that I spent I
shouldn't say I, but my other siblings and my cousins
spent our entire childhood visiting penitentiaries, visiting the court system.
We were always at a law enforcement center or always
(04:12):
in court, and we just put two and two together
that this was not normal. And I remember one time
we were playing baseball outside and we had no idea.
This was nineteen eighty two, and we had no idea
that the people that the guys that were playing baseball
were with us were DEA agents undercover. I mean they
(04:34):
had lunch with us and everything, and I remember the
DEA agent says, Oh, do you want my pickles from
his hamburger? And I was like yes, And next thing
you know it, he got up and told my parents
in Spanish, get the kids outside. I had no idea why.
And then we saw my brother and a couple of
cousins being handcuffed and escorted downstairs and outside into patrol cars.
And so this day I can't have pickles because I
(04:55):
remember that it was horrifying, and I remember the horror,
horror look on my parents face. They were mortified because
it was a public arrest. I mean, the whole neighborhood
was outside. So that's what I realized. That's what really
hit me that this is not going to be my life.
Speaker 1 (05:15):
And I mean, just to clarify there, I mean you're
saying that the DA agents they were like young guys.
Speaker 2 (05:23):
Yes, being a kid, everybody looked like an adult to me,
and they were undercover. They had NYPD undercovered, and it
was a big drug bust my brother was the drug
money launder. That's when I really truly realized he was
a bad person, and it really broke my parents' hearts.
On top of visiting him, we spent our childhood visiting
(05:43):
him in penitentiaries where there was a county jail, state penitentiary.
It was ridiculous, and we were always in out of
court trying to come up with cash for his bail,
and I was in charge of the money even til
he was incarcerated. My parents would have me hold the money.
I would have thousands of dollars in cash in my
(06:04):
coat pocket walking the streets in New York, walking into
the courthouse or a jail to bail my brother out.
Speaker 1 (06:15):
So while you're seeing this happen, and you know your
brother goes in that direction, I assume growing up and
you're in high school, how did you decide that you
would go into a profession that would lead to what
you do today.
Speaker 2 (06:31):
It's funny. It was actually college. I mean I always
liked numbers. I was always good with numbers, and I
excelled in math. And then when I was in decided
to attend college. I decided to major in criminal justice
in finance. I should have majored in accounting, but I
didn't know that in nineteen eighty five. So I just
(06:54):
combined both finance and the criminal justice system into one
major and that's what I did. So but you know,
I talked to my brother about that, and my brother
and I had a lot of conversations one on one,
and he told me how they laundered money. I'm like,
how did you do it? And he would share all
his methodologies. He even had back in the day they
(07:17):
had those green, heavy ledger books, and I remember he
would assign me to calculate the math in the ledger books.
So I was playing accounting with I didn't even realizing
what I was doing. And you know, he told me
how he did it. He shared a lot of information
with mem.
Speaker 1 (07:35):
So what were some of the things that he did
that you that he shared?
Speaker 2 (07:39):
Oh, one thing, he used children like me, my sister,
and my cousins to go structure money, make deposits and
banks throughout New York and back in the seventies and
the eighties, they I don't even remember the bank tellers
ever asking for ID or you know, identifying his source
of fun. Why all this cash? It always brought children
(08:02):
with him. I guess it made him less vulnerable to
bring kids around. So yes, he used us. So that
was one method how he structured money, how he laundered
money into he placed money into the financial institutions. And
he also used us as couriers. I remember my sister
and I would jump on our bikes and our cousins
would jump on our bikes make deliveries without even realizing
(08:23):
what they were.
Speaker 1 (08:25):
So you had that very real experience. You go to
college and you you know you're learning finance, you're learning
criminal justice. I'm going to jump ahead and you can
fill in the blanks because you end up at the CIA.
So so how did that happen and what were you
doing at the CIA?
Speaker 2 (08:46):
I never thought I would end up at the CIA
in a million years. I moved from New York after
graduation to Washington, d C. And I got hired at
a private law firm that specialized in white collar crimes.
And they were the They weren't the defenders, they were
(09:06):
the ones that were hired by corporations. So I did
a lot of corporate fraud cases, a lot of identity
theft cases with corporations, and then nine to eleven happened,
and I became a nine to eleven applicant because I
was here in Northern Virginia working at a law firm
as a criminal investigators and a lot of people don't
(09:27):
realize a lot of law firms hire criminal investigators with
a finance background because we had to do forensic accounting.
So long story short, nine to eleven happened and had
two recruiters coming into our office and asked our boss.
The partner of the firm said, Hey, we're looking for
(09:48):
people who can follow the money and meet a group
of people, join a conversation, and I joined the CIA
six months later. It helps that you don't have anything
in your background to dismiss you from the security application.
In six months I was at CIA. I had no idea.
Never in a million years I thought it would be
(10:09):
at CIA, because I thought at CIA you had to
have a PhD. Or a law degree, or fluent in
Arabic or Chinese or some critical language. Yes, I spent
ten years.
Speaker 1 (10:22):
I have a question. I mean, I hope this is
not too sensitive for me to ask, because I know
what that process is like at the agency, going through
the whole recruitment, the security and you whatever you want
to share, you can in that conversation where you're talking
to the investigator or the poligrapher, did they talk about
(10:42):
did you talk about the stuff from childhood? Or was
that just too far, too far off?
Speaker 2 (10:48):
No, that's a great question, because, as you know, it's
very painful process. They break you across the coals. And
it was actually the psychologist because you have to go
through a psycho logical profiling, and the psychologist was asking me
all these questions about my family, thinking, Okay, how does
(11:08):
she turn out the way she did with all these issues?
And then security came and security was asking, put it
this way, My polygraph took two full days because they
were trying to figure out, with her family history, how
does she get either got away with it or she's lying. Literally,
my polygraph took two full days because they were trying
(11:30):
to figure out how I became this person considering my
family background, my family history, because it just wasn't my brother,
It was cousins and uncles and aunts who were fraudsters
and drug traffickers, etc.
Speaker 1 (11:45):
So I wonder, I mean once, because they do break
you through the colds. That's it. That's the perfect metaphor.
Any torture that you can think of. That's the great
metaphor for the CIA recruitment process. But I'm wondering when
they saw that you were legit, that you were, you know,
smart and capable, do you think that sort of was
(12:06):
maybe was in your your favor because you had been
through so much and had overcome.
Speaker 2 (12:12):
Yes. Actually, I'm glad you brought that up, because after
the psychological profile, they realized that a lot of things
don't bother me. You could throw a picture of a
dead person in front of me, I'm like, okay, I've
seem worse. So I was like desensitized based on my childhood.
So it did benefit me. I was street smart. A
(12:36):
lot of graphic information did not bother me. I could
sit with assets on handcuffed, I followed terrorists didn't bother
me at all. Of course, there's some fear. It's always
good to have fear because fear keeps you sharp. But
I was it didn't. It was strange. I would desensitized
to the threat because I grew up with the threat.
Speaker 1 (12:58):
So and so talk us through what you actually did
at the CIA.
Speaker 2 (13:06):
I was a targeter, And what a targeter is, It's operational,
it's actual intelligence. We work with case officers in the field.
Where I use this metaphor, the case officers a driver
of a vehicle. I'm in the passenger seat, navigating the
case officer where to go, what door to break down to,
who to speak with, who to recruit. Also, my job
(13:30):
was to fuse intelligence gaps, develop leads, and since with
my finance background and my financial crimes as a criminal
investigator background, I knew how bankers thought. I knew how
they moved money. I knew how they laundered money. Of course,
thanks to my brother, all those different methodologies and also
(13:50):
cultural they leverage my cultural background, my language background, and
the fact that I grew up in the streets the
streets around helped a lot.
Speaker 1 (14:01):
So give us an example of how your expertise was
utilized in some of these cases.
Speaker 2 (14:10):
Since we were targeting drug traffickers and transnational criminal organizations
drug trafficking organizations, I was happening to I was listening
to some tapes, some recordings of surveillance, audio surveillance and
physical surveillance, and I was taking notes because as a targeter,
my job was to fuse intelligence gaps, develop leads, and
(14:33):
so forth, and I was listening to the drug traffickers
and I realized, being Puerto Rican from New York, there's
some slang. And I realized that they were using the
term chawo. Chawo in Puerto Rican Spanish means money. So
I realized, wait a minute, we're not targeting Colombian drug
(14:55):
traffickers as we thought we were. These are actually Puerto Ricans.
And I brought it to my leader, my chief, my
group chief, and he goes explained more to me, and
I was like, I'm Puerto Rican from New York. We
say chawo. When somebody said showo, I know automatically they're
Puerto Rican. You know, these guys are saying chowo. You know,
in Latin America the term for currency is either baso,
(15:18):
dino plata and so forth. They're saying chowo. And sure enough,
long story short, we did more intelligence gathering and they
were Puerto Ricans but living in Colombia, and they were
moving trafficking from Colombia to Puerto Rico. And I said, now,
these guys are Puerto Rican. And that's how my upbringing
(15:39):
and my background, my cultural background as well, helped the case.
Speaker 1 (15:44):
And so you know, so you spent time at the
agency as we call the CIA, but I know you
you also worked with other organizations, So how did you
transfer to other agencies?
Speaker 2 (15:58):
I decided to make a change because at CIA, you
travel a lot outside the US and I was exhausted.
I wanted to reconnect with my family because there were
some deaths in my family. So joining the FBI, it
was more domestic mission. It was more likely to stay
within the US. I can spend more time with my family.
(16:18):
And then at the FBI, I was assigned to the
white Collar Crime Squad, and with my background, I was
assigned to the New Jersey slash New York offices, and
I was specializing in trade based money laundering because there's
a lot of New Jersey, New York ports, shipping ports
and airports, so that was my line of work as
(16:39):
an analyst there, and I worked with the FBIS. So
with the FBI, we were notified a credible threat a
target was flying in to JFK was reliable threat, reliable intelligence,
credible intelligence from a reliable source. But when we did
(17:00):
our investigations at FBI, They're like, no, they can't be
the same person. I'm like no, if we're targeting a
Latin American person, I know for a fact, culturally speaking,
I learned just from my own personal experience in my
culture living in New York. Also to Cia. A lot
of Latin American countries, men use the maternal surname that's
(17:23):
legal and culturally acceptable. Because, for example, I know Chappo
from Colombia used his mother's name totally legal and culturally
acceptable's on their legal documents and their birth certificates. I'm like,
let's do a search on this target using his maternal parents,
maternal mother and grandparents, and sure enough, there was a hit.
(17:46):
He was using both his mother's name as his last
name and his father's name is his middle name. And
the United States and our culture, we just assume that
when people get married or they have children, that they
had take their father's last name. That's not true in
a lot of the Latin American countries, not even in
Puerto Rico, because my mother used her last name and
(18:07):
my father used his name. So it's funny because every
time we knew my father was mad at my mother,
he called her missus Miranda. So that's funny. Anyway, I digress.
I digressed, So I did some quick searches on travel
with using the target's maternal mother's name and maternal grandmother,
(18:28):
and sure enough, he was using him. It was on
his passport. He purchased his flight using both names, and
he was using his mother's last name as his surname.
And they were targeting him and following him using his
father's last name. There was a hit, and I taught them,
I said, don't assume if a target is a man,
(18:48):
he's using his father's last name. That's not true. And
a lot of cultures and a lot of countries, so
I taught.
Speaker 1 (18:54):
Them that, right, right. And so you were dealing with
a lot of movement over the border. Like you said,
there's plane travel. You mentioned ports. You also mentioned something
you said trade based money laundry. Many in our audience
know what that is, but some people don't.
Speaker 2 (19:13):
What is that is when you're using commodities goods to
launder money. For example, a bad actor overseas can make
could buy a thousand cars have them shipped to the
US as rather than as a source to sell it.
The is a source of payment for the bad actors.
Rather than paying a bad actor in cash, you paid
(19:34):
the bad actor with a.
Speaker 1 (19:35):
Carm and so did you see those sorts of cases,
you know, come up across across the ports. How did
you interact with that type of crime.
Speaker 2 (19:48):
We collaborated with other agencies that also own that mission
as well, and we just we collaborated with other agencies,
and again they used my expertise because of lot of
documents were in Spanish, A lot of targets that we
interviewed spoke Spanish, and I've learned very quickly, and a
(20:09):
lot of cultures. If our targets are male, I would
bring an agent or somebody a linguist who is male
to speak with a target, and I just sit in
the background. So then you have to remember when you're
interviewing targets or following a target, you know, you have
to remember culture. A lot of men and a lot
of cultures won't speak to women. So I was made
(20:30):
sure I had a male who spoke Spanish, or an
agent who spoke Spanish, a male agent.
Speaker 1 (20:35):
So you could kind of sounds like you could sit
in the background. You're probably the wiser, sharper analyst in
the room, and you just bring you bring in some
guy who looks the part right as an agent or
something and the suspect is talking to him while you're
just taking mental notes.
Speaker 2 (20:52):
No, I was actually taking notes. They thought I was
a secretary, and I was okay with that because more
comfortable they are, the more they talk. That's our goal,
are you, kitty. I even serve lunching coffee.
Speaker 1 (21:06):
For some Okay, right, So you mean while you're while
there's a target or suspect.
Speaker 2 (21:12):
Correct, If we found a source, a target, an asset,
depending on the agency identifies that term. Uh, sometimes we
sit with them, whether it's in an office, in a hotel,
or a restaurant. Use this in the back, use it.
I don't speak, and sometimes if we're in a hotel,
(21:32):
I'll bring them lunch. I'll even clean up for them.
And I'm the one that's actually collecting the intelligence or
feeding the agent or whatever who was there information? Like,
ask him this question because my job as a target
and also as an analyst the FBI is to supply
questions to the agent and also to the case officer.
(21:54):
I'm like, ask him this because they leverage my background
in finance, background in you know, financial crimes investigations. So
that's what I did.
Speaker 1 (22:04):
So, I mean, so we're talking about your career, which
has spanned twenty twenty plus years in the financial crime space.
But I know you've moved on, You've done some different things.
What are some of the challenges of working in that
intense environment? The bureau, the CIA.
Speaker 2 (22:27):
Long hours, really long hours. A lot of people think,
because you work for the federal government, you're nine to five.
That is not true. Bad actors will end at five pm.
They actually start sometimes at nine pm. Long hours, working
weekends away from your family, working holidays away from your
family was a challenge. And a lot of people think
(22:47):
because you're doing surveillance, you're working CIA, it could be dangerous.
I mean people can with the social media and take
today's technology, people can find out your true identity and
it could be a threat. It has happened. A lot
of us have been targeted personally. So that's a challenge
to maintain your uh, your privacy is difficult because bad
(23:10):
actors can find a lot about you.
Speaker 1 (23:12):
How do they target uh, not you or but others
that who have been targeted in what way?
Speaker 2 (23:18):
Oh, they'll send you mail, sometimes they'll call you if
they find out your phone number and if and if
you buy a house, you're the fact that you purchased
a house. It's public information. They can find out where
you live. They show up at your door, they put
notes on your car. They've I know an agent who
worked on the borders in Arizona and they were target
(23:42):
practicing with their kids playground set. You can see bullets
in the playground set. It happens. You just don't hear
about it. It happens. We can be targeted. So that's
one challenge. The other challenges lack of privacy. You when
you have a security clariance, you have no expectation of privacy.
(24:04):
That's a challenge. Another challenge is keeping up with the trade.
A lot of bad actors. They have deep pockets, lots
of money, a lot of access to resources. Is keeping
up how they engage in criminal activity. That's definitely a challenge,
especially when they cross borders. And once they cross borders,
who has jurisdiction that's another challenge. Then we have to
(24:27):
determine which border they cross, which country, who to contact.
Then we have to collaborate with other agencies, other international agencies.
If they cross borders and who has jurisdiction, You know
you have geographical jurisdiction, you have jurisdiction to either interview them.
(24:47):
That is the number one challenge is when bad actors
cross borders and they're advancing technology, because they have the
resources to buy technology, they move faster than we can
keep up with them. Sometime technology helps them get lost,
so that's another challenge. So geographical cross bording of bad
(25:09):
actors is definitely number one challenge.
Speaker 1 (25:11):
Yeah, and there are a lot of people who see
this life and think it's glamorous and want to want
to pursue it. Right, But I mean you mentioned even
the privacy issue. A lot of people don't realize it, right.
They see that security clearance. I think that's their ticket.
What are the privacy challenges?
Speaker 2 (25:30):
You have to tell me your whole life story, Like
my family, I was hesitant when I was completing my
security application and I'm like, oh my god, I got
to put down my brothers, I got to put down
my sister. What they did it was like a manifesto.
I had to do a dendums. So that was challenging
(25:53):
because to me that was private and I didn't want
them to judge me. And again, two days of two
full days of being polygraphed because they're trying to determine
is she either good, lied or got away with it
or what? Why is she so different than her immediate
family and her extended family because they have to know everything,
I mean literally everything about you, because if you don't
(26:17):
put down and document what you've done, because not everybody's perfect,
they're going to find out about it anyway and challenge
you on it.
Speaker 1 (26:24):
M Well, speaking of privacy, I know that you've done
some private investigative work. We don't meet private investigators. I
mean when I first learned that about you, I'm thinking, Oh, lord,
is is sitting sitting in the sitting in an office
with their feet on. She's got a fedora cap and
you know, she's waiting for some She's waiting for a
(26:45):
dame to walk in with a cigarette.
Speaker 2 (26:47):
You know.
Speaker 1 (26:48):
So is that what the you know tell me about
you becoming a private investigator.
Speaker 2 (26:53):
It's funny because once I left the government, I joined
the private sector. And one of the things in the
private sector that I learned, especially with corporations, is that
they have a lot of internal investigations that's not disclosed
to the public because they don't want to have a
reputational risk that their corporation company was exploited or was vulnerable.
(27:15):
So they hire a lot of people with my background.
So when I got hired, one of the criteria was
I needed a private investigation credential. I'm like what, because
I always thought being a private investigator was surveilling people
who were committing infidelity heaven affairs. That's not true. A
(27:36):
lot of corporations in the United States, as well as
outside the US, hire people with my background because I
came from CIA and FBI to conduct internal investigations. You know,
there's always an insider threat, I don't care where you are,
and a lot of corporations hire people like me to
create a threat matrix to identify the companies and corporations
(27:58):
vulnerabilities and help them fuse those vulnerabilities and actually conduct
investigations and speak with employees that were under suspicion for
embezzlement or fraud timekeeping. Fraud is a thing even when
a lot of people are working remote now, so a
lot of bezzlement cases a lot, So that's why they
(28:21):
hire people. But in a lot of states like Virginia
require a private investigator credential. And I remember when I
went to the six week class, They're like why are
you here, said, I have a client that requires the credential.
Plus with this credential, I have access to a lot
of public documents that the average citizen can't have because
(28:44):
I have this credential. And of course this credential requires
a background check, fingerprint check, even a credit check on
you to make sure you're legitimate.
Speaker 1 (28:55):
And so when you're doing private investigative work, I'm assuming
not all of it is from behind a keyboard. I mean,
I'm sure there's a lot of records you can access,
But are you actually doing stuff walking into places investigating?
Speaker 2 (29:10):
Yes and no, because a lot of these corporations hire
a group of us and I do more of the
forensic analysis I've had worked. I have walked into facilities
like stores, department stores, hospitals. You'd be surprised there's a
lot of theft in hospitals. Yes, department obviously department stores.
(29:32):
But I was shocked how much there's a lot of
theft in hospitals. So yes, I walked not by myself,
but I actually walked in with other private investigators who
were hired by the corporation.
Speaker 1 (29:45):
What would you be doing walking into a facility as
an investigator?
Speaker 2 (29:49):
Oh, a plane close. You know, we don't walk around
like perfect example, when we were investigating in a hospital,
we walked in. We found out that when somebody in
the corpor someone was actually hospitalized, so we asked for
their name to go visit them. That helps, you have
to have a backstory. And we were surprised how easy
(30:13):
walking through this hospital was at the time. And as
we were visiting this person, we just happened to, you know,
go to the cafeteria, walk around, roam around and conducted
our investigation. It was also really easy to even go
into the kitchen at the hospital without and plus the
way I look. Majority of the people, I hate to say,
(30:34):
our Latinos who are cleaners or help and I just
dressed down with jeans sinkers and walked in as if
I work there.
Speaker 1 (30:42):
So I'm trying to picture this. I know you can't
give up all the trade secrets and the trade craft,
and obviously you know we will be very sensitive to that.
But in this investigation, is it that you're supposed to
observe if someone is committing the fraud, if they're doing something,
(31:03):
so you have to just basically kind of do surveillance
in their job location, correct.
Speaker 2 (31:10):
We had a target at one hospital who first of all,
was not clocked in on the day. We've identified that
person in the hospital. They were not supposed to work
that day, but they used their credential to get through places.
They met with someone at the cafeteria. Information and also
to be careful because of privacy with US citizens. So
(31:34):
you know, we just observed their activity and just reported
it and that's all I can disclose. And of course
privacy is an issue. We have to be very careful.
That's why we're required to have this credential. Not anyone
can just walk into a hospital. It conducts surveillance on
someone without invading their privacy.
Speaker 1 (31:53):
Okay, And that's a good disclaimer for designated and we
don't want to designate anyone to write to designate it
saying that you don't try this at home is what
we're speaking. You are not trade unless you have that credential.
Do not go and start doing surveillance on your employees.
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(32:16):
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(33:00):
and better decisions K to integrity believe in better. I mean,
let's be real. You said something about people may have
certain assumptions about you. Tell us more about that.
Speaker 2 (33:15):
Oh yes, it helps with your appearance. So one of
the reasons why this corporation hired me is because obviously
they saw my website. It's like, we need somebody that
looks like her. You know, I'm five feet two, I'm Latna,
and unfortunately, a lot of in this area where I live,
(33:35):
there's a lot of people who look like me who
are actually the help. The workers, the cleaners, they pick
up the garbage, the painters, they work very hard. And
I just blend right in and I speak Spanish, and
as a matter of fact, I remember we were going
to court and I had to dress up to testify.
I walked into a bathroom in one organization and I
(33:57):
had a suit on, and the woman who was in
ask me in Spanish. She goes, are you the boss?
And I'm like, I didn't want to get into details
with her. I said yes, I'm a manager, and she goes, oh,
I'm surprised. And I knew what she was saying, as
I was Puerto Rican five foot two and I was
in a position of authority. So it helps your parents' helps,
(34:18):
It really does. It really does help. So you don't
want to send in a tall, blonde hair male Caucasian
mail to do some investigations in Hel's kitchen in New York,
for example. You mean, somebody look like me.
Speaker 1 (34:33):
But in all these places, you know, often there's security,
right and I think about airports, I think about other
public places there's more security. I mean, how can you
you know, how do you deal with that sort of
level of surveillance on you?
Speaker 2 (34:47):
Depending on the location, we have relationships with security at
that location. We communicate with security. They know who I am,
so when they see me, they just let me through
doors that are locked. I'm like hello, and they'll just
swipe their badge. So, yes, there is some corporate cooperation
among the security and some facilities, some organizations, some companies. Yes,
(35:13):
somebody has to know because I can get arrested for trespassing.
Speaker 1 (35:17):
Right, You're right, that's a good that's a good warning.
Speaker 2 (35:21):
You know.
Speaker 1 (35:22):
Lord is one thing that I really admire from your
background is you've done so much and on our show
we've talked to people who've dealt with compliance at major banks.
You've worked in the compliance anti money laundering compliance space
for a while. Can you tell us a little bit
about the difference between compliance at a big bank and
(35:47):
a small company. What experiences have you had or observations
about small companies and anti money laundering.
Speaker 2 (35:55):
When I joined private sector, you know, I left the
government joined the private sector. I establish my company, the
Fintech Advisory Group, and I basically pitch myself to support
small companies and especially in the crypto space. And I
know this is a discussion is about crypto, but a
lot of startups, FinTechs, they contact me, and a lot
(36:19):
of them are based out of the US, and they
want to provide products and services in the US. So
the challenges with the small companies who are based outside
the US that want to provide products and service in
the United States is registration. You know, they need a
lawyer in the US. So their challenge is first of all,
(36:39):
language cultural barriers. Which US bank they need to open
an account with? Who, which US regulator? They need to
register their corporation where it's a little startup with. So
that's when I come in and help them. And you know,
a startup is very challenging when building a compliance program
because I have to help them register, I have to
(37:00):
help them find a US bank, I have to help
them find a US attorney. So a lot of startups
have those challenges. Corporations already established. They're bigger, they're more financed,
they have bigger compliance departments, they're mostly established. We're startups
and FinTechs. It's me that starts the compliance program. It's
(37:24):
just me, and then I have to bring in compliance
officers and investigators. So that's one challenge. Is resources.
Speaker 1 (37:31):
And so if a company is a small company with
limited resources, I imagine it would be a target for
people who say, you know, criminals that are like, okay,
let's use that you know, so you know, what's help
me think like a money launder. If I'm a money
launder and I'm looking for a good platform to launder
my money, what would I do?
Speaker 2 (37:54):
You know, it's funny you say that because I've only
been in compliance for four and a half years. I
spent over twenty five years combating financial crimes and terrorst financing.
So a friend of mine who worked at Treasury Department
when I was at CIA, she was at Treasury and
she contacted me. She worked at a startup she retired
from Treasury called. He said, lord, is I know you're
(38:15):
in the private sector. Now I need you to join
our little startup and help me build a compliance program.
And I said to her, I said, I'm not a
compliance officer. I don't even know where you begin. And
she said, no, I need you to teach my compliance
officers how to think like a criminal, how you know,
teach them what you learned out in the field. So
(38:38):
then I coined the phrase you know the other KYC.
We all know KYC stands for know your customer. I
coined a phrase, the other KYC, know your criminal. So
she brought me on board and I tell her compliance
officers how to think like a criminal before they on
board a bad actor. This is how criminals think. This
is how they move their money, this is how they talk,
(39:00):
this is how they established their organizations. This is some
things you need to consider when you're onboarding. Conducting compliance,
conducting due diligence, conducting enhanced due diligence, and personal profiles
as well as business profiles. So that's what I did.
I helped them think like a criminal. And I'll give
you a perfect example. I had one fintech hire me
(39:21):
as as a fintech advisor, and I said to him,
when they brought me on board, the first thing I
did was look at their website. One of the things
that bad actors look for is they look at people's websites.
That's where they usually go because they want to see
how long the website has been established. Because a lot
(39:43):
of platforms, you can find out how long the company's website,
how long it's been active. Can really find that out.
A lot of bad actors find when the website was established,
when the company was established. You know, I tell a
lot of fintech firms, don't put your copyright on your website.
(40:06):
At a firm that put their copyright twenty twenty three.
That tells bad actors your brand new, brand new means
you're small, your startup, you have limited funds. You you
may not even have a compliance program. Your easy target.
They'll check out your website, they see your copyright, they
(40:26):
see you're not registered as an nmsl LS. You know
that's the money transmitting license. They don't see your register
with a money service business. Because when you're when a
company is registered with a money service business, all you
got to go is go to Finnsend's website, type in
that company's name to see if they're registers of money
service business. Bad actors know that, and when they can't
(40:49):
find your web your name on finn Send's website is
a registered money service business, they know you're not a
register MSB. That's another vulnerability that you have because it
tells you a bad actor they don't have their act together.
This is easy, let's open an account with them. Another
thing that I see on fintech websites. A lot of
(41:10):
these startups, because most of us work remote, they use
their home address as their business address. Any bad actor
can google that address and find out that's not your
business address. That's another vulnerability that company has. And then
on the website there's a phone number that's the CEO's
personal cell. You don't want that. Again tells a bad
(41:32):
actor is a small company, and a bad actor is
a small company. Again, they may not have a compliance department.
They may not have investigators to vet me when I
open an account. This is easy prey. Another thing, a
lot of companies don't have a lot of startups that
I tell you must have a link, you know, when
(41:54):
you scroll down at the end, you must have a
link you know, for any questions or queries click here,
email us. A lot of these startups don't have that.
And I said, and you don't have a law enforcement information.
A lot of startups need a law enforcement link. Like
if you go to my website, you click on law enforcement.
That's a link where law enforcement can reach out to
(42:16):
me if there's an issue with one of my clients
or one of my customers. A lot of these startups
don't have those links. Because a lot of these startups
they can email the CEO directly. That's not a good idea.
And a lot of websites don't list the countries that
they offer their products and services to. You know, a
lot of bad actors like, oh, they only offer they
(42:39):
don't have a list of countries, so we can open
an account in any country our bad actors are located.
That's what bad actors look for when they click on
a startups website is how vulnerable is this website? Another
thing bad actors do when they find a company, a
startup that they want to open an account with, they'll
actually go to LinkedIn and check out that company's LinkedIn profile.
(43:03):
And I always tell my clients, if you've got to
have a LinkedIn account, you got to list all your
don't list just two people at this company, because again
that tells a bad actor. You're a small company. This
is easy prey, So be careful with that your LinkedIn profiles.
And again yeah, I always tell startups, you know, tell
(43:26):
them you establish for many years. Let bad actors know
that you have your act together. Another thing is you
got to have an attorney. A lot of these startups
the hire attorneys once they get established. You got to
have legal counsel employee full time always. You got to
have a compliance officer chief compliance officer full time always.
(43:49):
And you have to have your registration number when you
register with federal agencies, regulators. I mean, all those things
tell a bad actor this company is very small, limited funds,
easy target. And number one that bad actors do is
they call and do a complaint. They want to see
(44:10):
how many how knowledgeable your customer service representatives are. They
want to see how many customer representatives you have and
how knowledgeable you have they are of the company's products
and services. And sadly, you be surprised how many customer
service reps don't understand the products and services of the
company that employs them. And a lot of bad actors catch that,
(44:30):
so they exploit the customer service replying to the rep saying, oh,
we accidentally sent funds, could you refund me? And commit
all sorts of fraud. And the number one goal for
customer service reps is to keep the customer happy, so
they'll comply with all these lies. And another thing bad
(44:51):
actors do they exploit social media and they complain about
their startup and a lot of regulators and law enforcement
monitor these social media sites to see all the complaints
by customers about this company, and those complaints tells us
a lot to regulars and law enforcement that this company
(45:11):
doesn't have their act together. Why there's so many complaints
and a lot of bad actors lie. They complain on
social media about a company that didn't do anything. You
just want to make that company vulnerable.
Speaker 1 (45:24):
So it sounds like a smaller company. And you have
to be careful if you're moving fast and breaking things thinking,
you may fake it till you make it. When it
comes to finance and money, that can be very dangerous.
Speaker 2 (45:38):
Very dangerous. You've got to let the bad actors know
you have to act together. A lot of bad actors
also read the terms of use. You've been surprised a
lot of starters or didn't have a terms of use.
The terms of use tells a lot about the company.
You know, whether they have a legal team, they have
a compliance team, to have investigative team. Yes, you'd be
(45:58):
surprised a lot of these even have that.
Speaker 1 (46:02):
Lords you with all of your experience, now, I'm wondering
if there's any advice, whether it's career or otherwise, that
you would give to lordis Miranda twenty years earlier now
that you could look back.
Speaker 2 (46:17):
If somebody told me twenty years ago what to do,
that makes me even a stronger analyst slash criminal investigator
is to major in a county finance international relations because
financial crime, investigations, cases, whatever you want to call it,
(46:40):
it's global. And pick up a foreign language. You know
majority of the people now know Spanish. Pick up a
critical language. You'd be surprised how many federal agencies hire
people who majored in French, who in critical languages, Arabic, Chinese,
(47:02):
you name it. Get a law degree. You don't have
to practice law, but law degrees teach you analytical skills.
You have to have strong analytical and critical skills to
be a great investigator. Let's see, you have to be
a perfectionist. That's a must. That's because nothing drives me
(47:24):
crazy when I have a case. I'm looking at a
case from an analyst or a criminal investigator because it's
very sloppy. You got to be organized. You have to
be a perfectionist. And you know today in this age,
a lot of people speak in acronyms. One thing, if
anybody can take one thing away from this whole discussion
(47:45):
is don't write and don't think in acronyms, because acronyms
can mess up a case. It can pitch a case,
it can compromise a case. It can get somebody killed
and hurt. I'll give you a perfect example. I was
in my office. I had a junior an investigator come
over to me and was speaking to me. Hey, I
found a source, because you know you were at CIA.
(48:06):
It's all about your source. How credible is the sources? Right?
I'm like, who's your source? He said the IG And
I looked him the Inspector General's office. He said, he
goes Instagram.
Speaker 1 (48:20):
So this was maybe a gen Z or millennial. Maybe
I'm not going to go.
Speaker 2 (48:24):
There, Okay, in my mind, his head exploded. He saw
the look on my face. He literally ran out my office.
I went after him. I said, what did I say
about speaking in acronyms to me? Because that can break
a case, that can get somebody killed. I remember being
out in the field. We didn't speak in acronyms. I mean,
we spoke in code, but everybody understood the code. If
(48:46):
we said IG out in the field, everybody in that
mission knew what IG meant. So don't speak thinking right
and acronyms. So that's one thing I like to share
with the audience. Other believe it or not, psychology degrees
who knew because human intelligence and artificial intelligence work together
(49:10):
every day. You'd be surprised how many psychology psychologists that
we work with. I don't care what agency you're with
a lot because a lot of psychologists, when we bring
them intelligence or briefing, they usually give us a profile.
A lot of psychologists come out to the field with
us and they don't say anything in the meetings, but
(49:31):
they just analyze the behavior. So yeah, psychology degrees, accounting degrees,
finance degrees, International relations degree because we're global.
Speaker 1 (49:44):
Speaking with lord Is reveals the power of adaptability, cultural insight,
and perseverance and tackling bad actors who are constantly evolving
their schemes, whether working undercover in the field or helping
corporations develop strong compliance works. Lordas has dedicated her career
to staying one step ahead of the criminals. Her advice
(50:07):
resonates beyond the world of law enforcement. Think critically, know
your adversary, and always aim to understand the systems at play.
As financial crime fighters like Lordus continue to clean up
the murky world of illicit finance, her work proves that
even the most complex schemes can be dismantled with the
(50:28):
right tools and perspective. I'm Yaya Jata Finussi and this
is designated on the Illicit Edge Network
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