The Compliance Word

S1E1: Women In Compliance: Amy Storer

March 01, 2021 RAW Compliance Season 1 Episode 1
The Compliance Word
S1E1: Women In Compliance: Amy Storer
Chapters
0:00
Intro
3:11
Trafficking Crisis
6:23
Child Exploitation
14:58
How Compliance Helps Identify Human Trafficking
23:03
Oonagh and Amy Get To Know Each Other
25:39
RAW Compliance
32:14
How We Can Make Real Change
42:10
Knock On Effect Of Human Trafficking
44:45
Labour Trafficking
52:18
Tracking Phone Bills
56:58
Outro
The Compliance Word
S1E1: Women In Compliance: Amy Storer
Mar 01, 2021 Season 1 Episode 1
RAW Compliance

Amy Storer joins us to discuss how we can work together to combat human trafficking, modern day slavery and child Exploitation. Amy Storer is a professor, homeland security specialist and child exploitation expert. Hosted by Oonagh Van Den Berg and edited by Luke McCann.

Show Notes Transcript Chapter Markers

Amy Storer joins us to discuss how we can work together to combat human trafficking, modern day slavery and child Exploitation. Amy Storer is a professor, homeland security specialist and child exploitation expert. Hosted by Oonagh Van Den Berg and edited by Luke McCann.

Intro:

Welcome to the RAW Compliance podcast. Each week on the compliance word host Oonagh van den Berg will meet with practitioners from across the industry, public, private, and FinTech reg tech providers. They will honestly and rawly discuss topics impacting risk mitigation in financial services, financial crime, and how we can build sustainable and credible compliance culture. Our aim is to empower our listeners with the knowledge and skills to tackle these problems, and promote positive change to the global compliance community. And now your host Oonagh van den Berg.

Oonagh van den Berg:

Today on the compliance word we're joined by Amy Storer. Amy is a national security analyst, professor human slavery and child exploitation investigation officer. She currently works with the US Department of Homeland Security and she's a graduate of Harvard University. Amy, thank you so much for joining us today. My t shirts cool it says girls just want to have fundamental human rights.

Amy Storer:

There you go. I love that. Oh, good for you. You are, I was so excited to talk to you. I love all your posts. And I can't believe how you you live overseas. And you're like, just doing this, you're just the most courageous person. And you're brilliant with all the money laundering. And I mean, you're just a trailblazer. And I just I just wish I could be swimming inside your brain to learn all that, you know, with, with everything.

Oonagh van den Berg:

Actually funny you say that because I feel exactly the same way about you. Your posts, you literally, you have the finger on the pulse. And I love it when I see your post coming through. And you're talking about like just things that are happening day to day. And one of the things that worries me a lot about human trafficking, and modern day slavery is we talk about it a lot. But unfortunately, when you work in the big financial institutions, the visibility on the realities of what it does, it doesn't really translate. And what your posts do is make it real. It's like this is the real victim. This is really what happens. And you know, we need to make a difference. We need to lobby for changes and legislation. Amy, I think what the work that you're doing the posts that you're doing, especially on LinkedIn, they are inspirational and you're getting a very significant following because of the authenticity as well, around them.

Unknown:

Wow, that makes me, y ou just gave me the goosebumps. It's an honor hearing you say that because I swear I mean, I just get so mad about this stuff that I and I just tell it like it is because I feel like there's so many people in my industry that it's almost like they want to downplay it or I don't know what but they it's worded in such a way that it's I don't know, I think people need to know that this is an absolute crisis. I mean, the levels of child exploitation it's risen 98% during the COVID that's a direct.. we can't keep up it's terrible. 98% The showed online sex crimes has risen since the lockdown and and it's it's really scary. I don't have children myself, but I tell parents, man, keep your kids offline. And we need to we need to put the fear of God into into society because it's not going to change. It's not going anywhere anytime soon. And I'm worried that every single year the the trafficking rates grows and grows and grows and the child exploitation rate grows and grows and grows. And it doesn't seem to matter how much money the government is dumping into these issues or they're trying to bring awareness or whatever the facts are the facts and my concern is if it continues at this level, what's going to happen in 10 years are every single one of these kids is going to be at risk. You know, I feel like right now one in four children are victims of child sexual abuse. And you wonder why we have so many mental disorders and problems with children in this country and school shootings and people that are who knows. I mean, I think we have a lot of...just it breaks my heart to see what these and it's not just the it's also the violence that goes with it. You know, and, and I think and you guys are on the front lines, I tell you what, as we're speaking I'm reading a SAR that is extremely well done here involving a child sex trafficking target and the banks are our friends. You guys are the greatest the greatest people. I just the level of detail that you're able to do and, and detect in the SARS is is really phenomenal. And I just, I'm just so grateful that, you know, it's like I feel like the world is kind of against us. And I hate to say that. But when you think about people don't realize how hard it is to get a search warrant to get you know, I really admire Australia that if it's a child exploitation situation, there is no need to establish probable cause for the law enforcement officials to enter the residence. In America that we have to have a mountain of evidence, by the time it's very reactive. I mean, by the time we're able to get in the door, that child has been victimized, who knows how many times right, and it's like, you know, I feel like we need a change. I saw on Tuesday that the two, the two agents have been gunned down, trying to enter a building for you know, for serving a warrant with regards to an issue with regards to protecting a child. And when I went on to read the work that both of these agents have been doing in this field, basically rescue children from forcred labour from, you know, unfortunately, sexual acts and sexual slavery. And then to be gunned down on the doorstep, it's... You know, it's just it's so hard. And we're feeling it, you know, that was right down the street from our office. And a lot of our agents work with those FBI agents on these cases. But we're feeling it because, you know, we're getting more cases now. Because they're dead, right? I mean, we're taking on more and more and it's so sad to lose these incredible people that were trying to save children. And it really is so widespread. To me, that's the biggest problem. And that's what scares me because the dark web, for example, I actually emailed this to my boss because in the wake of these two murders of these agents, we have to do something different here, we have to shake things up. We have to, you know, because I don't think people realize that the the drive for these child predators is not so much children, but it's also violence. I'm doing a lot of dark web investigations and things of that nature. And the number one thing that these people are asking for these child predators are asking for is live murder videos of children. In other words, they're asking to kill a child. Now, about five years ago, when I first started doing this, I would see a lot of requests for a live rape videos of children, which are bad enough, but now they're wanting live murder videos. Now, that's not enough. They want violence that is what sexually arouses them, apparently. And so I think we underestimate how violent these people can be. And I mean, they're really like terrorists. I mean, they really get off by inflicting very much harm. Mutilating children's genitals, they really get off on that. That is what... I don't know how that's even possible. It is just so disgusting. But it's also the internet that I mean, the internet is also helpful for us to solve crimes for the same time, the internet perpetuates crimes at much faster rates, and we're able to solve them. And part of the reason is, unfortunately, child predators have existed since the stands of time as as we know, but, but there's a big crossover between the child exploitation and trafficking. One of the very first child exploitation cases that I worked. This disgusting man was molesting his disabled son, and the girlfriend was also participating in that, as disturbing as that is. And I, I had a new contact at moneygram. I was really excited about this contact, and I just thought, Well, I'm just gonna send his name over. Just to check you know, this particular name, I just want to see the money and just make sure that he's not trafficking. Well, my heart sank when I got those records back and there were, you know, a whole page of $20 transactions for and they were coming from all these different men to our main target, right, and you know what's going on, he's selling his child for the grand total of $20. To all of these creeps, many of which were actually sex offenders, registered sex offenders. So now we have a child trafficking case. But gender exploitation has evolved very quickly in a child trafficking because they have if you want to have sex, With a clown, and if you lived in 1950 in in America, you wouldn't have anyone to talk to you about that you would keep that shit to yourself. But now we have these online communities of people that are not only into sex with clowns, but they're telling you where to find it and how to do it and how to facilitate that. And I think with child exploitation, there are a whole communities on how to kidnap a child, there are people that are giving tutorials on how to traffic children. So it's very easy to build an enterprise of nefarious things, instantly, with a click of a button. There's literally 20 million questions I have from everything you have been saying. I am actually going to ask you questions on the statistics that you give, because what you rightly said is, the unfortunate side of things is these heinous crimes have existed throughout the times. But people, as you rightly said, if somebody wants to have you know, interactions with a client, they can keep it to themselves. And unfortunately, because of the Internet, and because especially with the dark web, people are beginning to find that their little dark secrets are actually little dark secrets of other people. And their much more 'oh, we can talk about it, we can share it'. But when you talk about COVID, and as we have seen a 98% increase in child exploitation. My question is the things that you're talking about, you know, and inflicting mutilations in rapes, murders. There, there are things that would never in a million years cross my mind. And I'm trying to understand what percentage of society are we talking about? So you've seen a 98% increase during COVID. But, you know, what percentage of people do you actually think are involved in these types of activities as a normal kind of societal spectrum? Yeah, you know, and that question haunts me, really, because one in four children are our child sexually abused. And it just blows me away. Because I think it's probably higher. I think, personally, it so common that I think people have no idea I think, kpeople would lose their mind if they saw wh at we saw and for example, it's crazy because I worked a child sex torture chamber case with Interpol. And it was horrible. One of the worst things I've ever seen and my job and a monkey could have done what I did. My only role was to take screenshots as quickly as possible, before the evidence would disappear on the screen. It was like, one of those rooms where they go in and they're like, a red room or whatever, where they're going in and they're doing their thing and sharing it amongst each other. But I want to capture that evidence. So we can try to find the kid and the bad guys. So, I remember it was November 1st, I could not keep up with the volume. I couldn't, it was unbelievable. It was like Armageddon. It was absolutely horrible. And I remember like, feeling sick to my stomach, because I couldn't click fast enough and I was missing it. I remember leaving work that day thinking why was it so much higher this day, and I remember realizing, and I had a pit in my stomach, and I realized it was Halloween. It was the day after Halloween in the United States. And so all of these creeps were aroused by seeing children in their Halloween costumes. And that's what drove the mass volume I believe on the darknet that day.

Oonagh van den Berg:

I think that we're obviously talking about quite a sensitive subject because for some reason my zoom video keeps automatically turning itself on. So I think I think that the at least I'm happy to see that the zoom is actually monitoring these types of discussions on their platform, because we've obviously said some words that have caused by my videos to pop up.

Amy Storer:

I've seen and you look at how many people were involved in that and one of the quotes that the victim in that case. She said something like, it wasn't just the hard part was it was also the hairdressers and the pilots and the doctors and she said the list goes on of people that were involved and clearly saw that these were children and they did nothing about it and that's the scary part to me. For anyone listening if you see something and it doesn't look right, it probably isn't. That's why we need we need more people to come out and report these crimes.

Oonagh van den Berg:

Absolutely! I'm glad that you brought up Fincen and the SARS. I've actually got a call letter with a very old friend of mine. He worked for the US government for a very long time and one of his jobs in particular, he worked with the narcotics teams down in Miami. We're talking like the 80s and 90s. So the days that the real kind of El Chapo and all of those issues were going on. Basically, one of the things he talked about was when... and this is actually quite interesting whenever ACAMS was first formed, and they they actually came up with the SAR, which I wish I wasn't aware of because they were sitting together and they were talking about the fact that the only way they were going to stop money laundering and these types of fences being going through the banks was for the banks to begin to detect them and to understand why they actually exist. My biggest challenge over the years has been I have trained FIU's. And one of the first questions I get asked by them is, what should we be looking for? And if that is an FAQ, and you know, individual asking me that question, I'm concerned, because I'm like, well, you should have the data analytic capabilities you should be filtering through. And the problem with fincen with every other FIFA globally is that they're receiving, you know, we talked recently about the fincen leak. Let's be honest, the fincen leak approximate was approximately 0.2% of the SARS they've received over a 20 year period. And we're going to be that specific about pulling out some little SARS that you think are telling of a bigger issue but in fact, not looking at the bigger population, it's a little bit distorted. I believe financial institutions do a good job with SAR submissions. I do believe there still is a lot of (CYA) cover your ass happening. Because, you know, they continue with the client account but they submit the SAR just to be safe. I am of the opinion, if you've taken a step to submit a SAR, you need to seriously ask whether you're going to continue with that client relationship. Not just specific to child exploitation and human trafficking but all different types of whether it's fraud, tax evasion, etc. On the quality of the SARS, that you're seeing, obviously, the quantity is there. And I don't believe the quality. Quality versus quantity is my concern, you know, we need to get much more specific and precise in terms of what we're submitting. But you're looking at some SARS, and you said the detail is good?

Amy Storer:

Yes you know, I completely understand what your perspective is with that. And it does make sense to me because I do see some that are better than others. But on the other hand, what I will say is, personally, just in my line of work, every SAR helps if there is a suspicious money flow that particular representative felt was something, or whatever the case may be. I say to air on the side of filing it. And I'll say that for a reason, for example; there have been times in my career and I can't go into specifics, obviously, but I'll give you an example where I had a phone number of a potential victim, I had a child victim or something, right. And, you know, we couldn't identify or we couldn't find her, or maybe it was an address, these are many different instances where this has happened. And I search, looking for any activity, any financial activity that might be suspicious pertaining to that address, or phone number, or whatever the case may be. And that actually, in many cases, led me to the victim and it gave me enough evidence to say 'wow, okay, something is going on here'. We do have a lot of money. And now some of those SARS might not have been like, you know, on an average day, if I was reading that SAR without knowing anything else, I would probably think 'Well, okay, so what this is no big deal'. This guy is structuring or whatever. But the fact is that we also use that data in combination with information that we already know where somebody is reporting on a child exploitation situation going on at this address you know what I mean? I think it's kind of up to whatever the the banker or the analyst feels. But I understand because obviously you guys are super busy there's plenty and plenty of suspicious things going on and and these filings I'm sure take take a lot of time. Or maybe they're automated, I don't know what I know there's, the FinTech has a lot more technology going on.

Oonagh van den Berg:

It's definitely not automated. Each one of them will be manually investigated by an investigator within the bank before it's submitted. And that kind of gives you a true indication of just how much work goes into it. One of the key questions I had for you is the unfortunate side, especially for child exploitation is it's happening across all sectors of our society and all different types, whether you've mentioned hairdresser, pilot doctors, even kindergarten teachers, God forbid but it does happen. The question here is, whenever you're talking about the payments, the payments are small amounts to $20 here or there, you know, the payments are low. And I think that's actually something that's incredibly important from our discussion.

Amy Storer:

Yeah.

Oonagh van den Berg:

I think when we look at transaction monitoring scenarios, obviously there is you know, the usual kind of, you know, we look at scenarios over X amount of money, or we look at scenarios over X amount accumulated over x period of time. But these are such small amounts that if you had them in a day to day retail account for example a deposit account, our normal banking account, they wouldn't, and especially with all of the likes of like, pay me and FPS nowadays, you know, we go out for dinner, and, you know, people share the cost of the meal. These things will be h ppening, of course, but I hink what's going to help u to detect much better is where he payments are coming from in erms of geographic, we're g ing to be able to geographically pin them because it's not going o be always people in their lo ality. And you're most li ely not going to be doing this i your local community unless ou've got some way serious ssues going on.

Amy Storer:

Absolutely, yeah. I mean, this is such an important discussion. Human trafficking is probably the easiest one to detect because you're going to have high peer to peer transactions, but it's going to be all male buyers. There's not too many females out there buying sex from other females. I don't think. I think the air is kind of dry here.

Oonagh van den Berg:

I creeked my neck getting out of bed this morning. It's so it's so painful. And my husband said 'are you ok?' and I said 'I feel like I've been in a car crash!'

Amy Storer:

Oh no! No, I love your accent. You have the cutest accent. So you're from originally Where you from?

Oonagh van den Berg:

And so this is kind of what how we would normally start. I actually have written it down. Amy where are you from? What do you do? So I personally, I'm from Northern Ireland. So I'm Northern Irish, born and bred. And I was born in Belfast, and I grew up near kind of the Glens of Antrim. I don't know if you know, Northern Ireland, but um, did you ever watch Game of Thrones?

Amy Storer:

Yeah.

Oonagh van den Berg:

So a lot of the Game of Thrones was actually filmed around near where I live, so it's really it's actually really lovely for me to watch it because I'm watching it and I'm like, 'Hey, wait a second. Isn't that behind my house?' I grew up in the middle of the country, I think my closest neighbor was about, you know, probably about half a mile away. You know, I just it was such a beautiful childhood. You know, it's in the middle of the country but overlooking the Irish Sea. And only now I really appreciated it and I I'm very lucky. I lived in Northern Ireland. I've lived in Finland. I've lived in the Netherlands, Germany, the UK and Singapore and now Hong Kong.

Amy Storer:

That's why I was asking because your accent is a little bit of a mix. It's so cool. I love it.

Oonagh van den Berg:

Thank you. The elocution lessons have paid off. It was worth every penny Mama. No, I had em. When I was younger, I had a pronunciation problem with certain words like shoulder and I still can't say it. And soldier and shoulder. I had to go for like a special like speech therapy to be able to say things.

Amy Storer:

Oh, no way. Oh, are you so cute! Oh, my goodness. Well, I would never know that. I have to introduce you ******. I don't know if you know him. He's from Ireland, but he's like an anti money laundering. He does crypto stuff this guy's incredible. I would love for you to to connect, unless I already connected you I don't think I have. But that's on the back of my mind. Because he is like, you both are like, you blow me out of the water because you're both so high tech. And you guys with the the financial stuff is unbelievable. I think the two of you together would be like, Whoa, dynamite. I mean, I will definitely send an email and introduce you.

Oonagh van den Berg:

Please do! I set up RAW compliance because in my career I found a massive lack of ability. In the UK, there was a there was a lot of roundtables and it was quite an open, you could go to other people, and you could ask them questions. And then when I moved to Singapore, compliance was like 'the first rule of Fight Club is you don't talk about Fight Club.' Also that was the second rule as well, people didn't talk to each other about day to day challenges. I couldn't get my head around, why not. And there seemed to be a real kind of closed door that you had to come into this circle of trust first. And, you know, there was the existing people that had previously been with the regulator, or people that have been to school together, and they all knew each other and they trust each other. But as an outsider, you kind of had to build up a trust. And thankfully, you know, I've been here 11 years, thankfully, I began to build that trust. But it was incredibly challenging to me in the early stages of my career in Singapore. Because that's I didn't know who to ask questions to I didn't know who to speak to.

Amy Storer:

In London was it very difficult as well?

Oonagh van den Berg:

The regulatory environment and actually the regulator's are amazing in Singapore, they're incredibly, they're not enforcement focused, they're hand holding focus, they're going to they're going to say, yes, you made a mistake, and there will be some repercussions behind the scenes but let us work with you to help. Enforcement unfortunately, is no deterrent. And if you want to get it right, you need to work with banks to get it right. And if you see the banks aren't getting it, right, then they have to go and I suppose that was the situation with the whole one MDB. One of the banks involved they had three inspections from the regulator, and three times the regulator said, there are findings and and the next the first time, okay, here's our findings. The second time was okay, we saw that you remediated pacifically our findings last time, but there were knock on effects and you didn't look holistically. So why didn't you fix X,Y and Z? Well, that wasn't specifically pointed out in the report, we'll fix that, but look at the bigger picture. And then the third time they went in on the back of one MDB it was just like, you know what, you guys just, you just aren't taking this seriously. So goodbye, you know. And that's it. You know, to give them credit. They were incredibly smart. And they support across the industry. You know, I've worked, you know, in banks where there have been significant recommendations in, you know, regulatory reports. But they it's not, it's not about penalizing. It's literally about here's the timeframe, can you realistically remediate. And then we're going to look at the remediation to make sure that it is adequate and sufficient, and you don't get that from any regulator. So the regulator is amazing. And the industry is fantastic. The people have, you know, the people want to do the right thing. But there was just this lack of discussion. But we've really moved that along. And we set up RAW Compliance around I'd say we we incorporated in September last year. And we've now today, just over 3100 members, so we're really, really proud of that. And we were asked to put together a free crypto masterclass because people want to understand crypto, what is crypto regulation, and I'm a little bit worried because we did put this together for free and I just checked the numbers this morning and we have over 600 people registered.

Amy Storer:

I have a guy with Digitalment and he is amazing with the crypto and I think it would be actually just very beneficial for you to meet because I subpoena them so

backstory:

This is how the enforcement side because they're Bitcoin cryptocurrency ATMs. And for me that's just like complete money laundering. You're going to an ATM, you're rolling up with a bag of cash. You're dumping it into a Bitcoin and it's going wherever the wind blows and nobody knows there's no oversight. And for me, I thought well, we need to get these records man, we need to get them to work with us. And I actually developed a friend through this and he's become Digitalment they've become o ne of our biggest allies. And he told me, he said, Amy, I'm very concerned. He said, we shut down these these bad crypto wallets where it's, you know, he said, I've got it down to a science, where I can detect immediately that it's fraud, elder exploitation, whatever the case may be, he said, and you would probably understand whatever he has to say, because it's like Chinese to me. But he said he, he wants to tell law enforcement about this. He's developed a metric where, but he said, the thing that just kills them, is the fact that they will shut down that wallet number, right, that crypto. He said, the very next thing that they'll see is that same wallet number, go through somebody else and just make that same transaction. Because a lot of these crypto ATMs are are dirty. They don't even check IDs. And I don't know if you guys have those over there, but I'll connect you. He's very knowledgeable about crypto and stuff. And but that is so cool that you develop this RAW Compliance man, you're a go getter, you are just, you are so young and beautiful. And you did all this. I mean, how? How did you even get the courage to just make this new thing? And your husband must be so proud of you?

Oonagh van den Berg:

Like that, you think that I'm young haha! I'm in my 40s. I feel old. But no. Barry, I have to say I'm very, very lucky. Neither of my grandmother's had wrinkles, and they don't run in our family. And I'm very lucky in that regard.

Amy Storer:

Oh, that's brilliant. They never aged? Wow. I think it's all that brilliance up in the brain. It just takes away your wrinkles in your family, man.

Oonagh van den Berg:

I think I'm just a pure Irish blood. I don't know, maybe that's it, maybe we're just too relaxed. But no, setting up RAW Compliance was just, you know, one of my key focuses is, if we want to be innovative and we want to actually make a difference. W e need to share knowledge and experience because we're all globally at different levels of sophistication and knowledge, whether that's from a regulatory perspective, or from a technology perspective. And yet, we all stay in our lanes we need to broaden it. You know, there are typologies of attacks happening in the US today, which are going to impact Hong Kong tomorrow. Because of the internet, the typologies are happening everywhere. Because it's not as if you know, people are, you know, slowly, kind of registering the sophistication, the sophistication is there. And one of the key things, you know, you've mentioned there as well, but we can't cut the head off the snake if we want to follow the money. And, you know, if we see one bad account, we can close that bad account, because if we do close that bad account that it's just gonna pop up somewhere else. And if we close that account, we've lost all of the connections that we would have got through through watching and monoriting. It's a bit like a stakeout situation. You don't run in and tell the guy oh, you know, we're staking you out, you know? But that was we are doing in the financial institutions, we're closing the accounts, and expect the rest of the people to continue BAU.

Amy Storer:

Well, that's a tough question. Because, you know, these banks, they feel like they're going to be in trouble if they let but at the same time, because they don't want to feel like they're facilitating right and so but we call banks and sometimes we have to write this letter and say, 'Hey, keep that account open. This is somebody we're investigating, you know?' But I understand their point is they don't want that dirty money in their bank. But you're right, it's like they're just going to go somewhere else unless every single person is on the same page and it's going to shut them down which is probably not going to happen in the world.

Oonagh van den Berg:

But there needs to be that support from the regulators. The regulators need to say and I can say the word psychological safety. The regulators need to give the safety to the banks to say, 'We identified it. Yes it happened on in your on your watch, but you've identified it keep it open report it and then we will work with you'. The problem banks have at the moment unfortunately, which continues with SARS. We always laugh about the black abyss of a SAR. We never know what happens with the SAR we just submitted and it disappears into into the abyss. And the question is like what is public private partnerships? So I have I have identified that the banks that are being the most successful in identifying complex network works are the banks that have taken it upon themselves to set up working parties within the industry with other banks. But you know what it shouldn't just be working horizontally across the banks, it needs to be working vertically, it needs to be coming from law enforcement, from regulators from the FNS. And all these typologies. And the thing is, as well, I totally get, we can't be sitting on open forums, such as a podcast talking about what we can do in terms of typology prevention, because it kind of, then, you know, the criminals are always two steps ahead steps ahead of us, you know, they know we're going to be doing. We need to be so much more innovative in how we do this. And that, that's exactly why I set up RAW. And really interesting, I'm working in at the moment with a few Fintechs. And they, you know, from starting level to help them to build their AML and compliance frameworks. But one of the biggest lessons for me was that I kind of went in with a traditional approach. Traditional approaches, well, what are the regulations? Okay, then I write a policy, then I write procedures, and then we operationalize it. And I'm very, very passionate about automation. And the other week I was sitting and I was writing, I was kind of putting together the policy for one of the fintechs. And then I was just kind of playing around kind of with processes and with the procedures and the controls and just kind of writing it down. And suddenly, I am not joking, I suddenly felt physically sick. And the reason why I did that was, I realized that the whole entire infrastructure that needs to be there to support the control framework doesn't exist. Because a startup is five people, it's five people building a tech product. Traditional banks are built from a regulatory perspective, the regulations are there. Tech companies are built from a tech perspective, we need to build the control frameworks from a tech perspective as well, we need to, we need to first think about well, what are the risks in our products? How will we control those risks? How will we automate that to the extent that we can and then build backwards for me. I've realized the policies are worthless, they're literally, you know, they're literally the cherry on top of the cake and interestly. And even the DOJ has recently taken enforcement action. They haven't cared about policies, procedures, they've said your culture is broken. So culture is the bigger issue. But you know, when I was working with these Fintechs, I'm like, we have been doing this the whole wrong way. We're looking at it back to front. But the problem you have, in many, many large institutions is they can't start at the system perspective, because their systems are all over the place. They have different systems for different processes, many of which connect, you have multiple sources of the truth and data, whether it's in Excel or in a system not connected to each other. So how are you expected to trace and track changes? What we're looking for here is changes and topologies, and behaviors. And that's what I keep stressing, we want systems that identify changes and typologies and behaviors, right? I'm not looking to do scenario or threshold based monitoring. I want to know what my clients normal, you know, operation mode is. I want to understand what their normal behaviors are. And I want to know what third parties, what nominal values I should expect to see. And if I begin to see anything outside of the norm, that's a red flag. And then using AI technology, we can begin to weed out the white noise because there will be white noise, initially. We'll use the AI technology to sensibly make a decision that this is this is not making, you know, there's a rationale for this, etc. And then finally, and this will take about six or seven months to build. But finally, after you've done all of that system adjustment, you start to get real noise from your system that is actually of value to the compliance officer for review. So that's what we're working on at the moment.

Amy Storer:

I just got the goosebumps hearing that! That is the coolest. I mean, that is what we've been needing for so long. I mean, this is groundbreaking what you're doing. I was talking to somebody at Fintech and he was saying, you know, exactly as you were saying. The frustration is everybody's doing stuff differently. You know, and it's and the communication is like a problem as well because everybody is closed off and he said you know he tried to offer his services to these banks for free and they don't even want it. But I mean it would be cool because some of the things they can do with this AI is he was telling me and you I mean I want to do all this. It would be like you know you see the account like okay, target A has 58% of all of his money is going to, you know business A or 14 percent of all of his transactions recently are going to this guy, or whatever. And so, I think it would be cool to like, have a breakdown like that where you can really see those patterns and like you said, when it becomes out of the norm, that's when the red flags go up. And, and you're right, we got to be on top of these trends because these people, they're professional money launderers and and we have to figure out, you know, what are the new things that they're doing? One thing I realized, recently I was working on on a child sex trafficking case. I was looking through this SAR, and my head was about to get a headache. I mean, this SAR was how many pages long it just kept going and going. And, and I was getting really confused. Like, what what is this guy doing? And all I knew was that there was child sex trafficking and a guy had been arrested, right? And so, the guy I'm looking at all of this money was going into his account, right? Those are sizable assets, he's somehow involved financially. And so anyway, I was able to find a few more things of concern on this particular person. But it seems to me that what I ended up figuring out, at least I don't know, for sure, but I noticed a common theme and all of these people that are commonly named in the SAR, and they all have a financial background of being a scammer, you know, scamming people. So then I started to realize, and so it was a mixture of scammers with potential traffickers, whether it be narcotic or human traffickers. And so I think what they're doing is a Ponzi scheme to target human traffickers. It's the perfect crime, because they're not likely to report that to police if they're, you know, and they convince these bad guys to invest in their Ponzi scheme. And so that's just something I've seen recently. I don't know if that's trending, but it was something I kind of was thinking that's kind of interesting. It's kind of funny, in a way, but I could be wrong.

Oonagh van den Berg:

We talked initially about child exploitation, some of those people are just unfortunately, dirty old man and woman or young men and woman sitting in a back Oh God. You're right, we don't think about that. room somewhere. Shall we say, they're introverted, they're sitting in their house somewhere, what I would expect them to be like. But then you have the human traffickers who are completely different breed like these are ruthless people, and at the extend of times, killers. They wouldn't think twice, you know, any type of death of any illegal immigrant is basically, you know, for them, it's just an inconvenience, but they're still going to collect the money for families that have paid for those people to be trafficked. Like, you know, in the UK we saw unfortunately last year, a number of I believe it was 26 immigrants killed in a freezer container. You know, what we don't talk about is the fact that the families of those individuals are still paying for the past, for those individuals to go to the UK or to go to Europe. They've had to sell their farms, and they were expecting to receive monies from these individuals. We don't we don't think about it. Then what happens is that somebody else then ends up getting trafficked, because they they need to pay the smugglers back otherwise, somebody's going to get killed. So there are multiple deaths happening on the back of the deaths of these immigrants, which is absolutely tragic. And then obviously narcotics, you've got a very, very different group of people there as well in terms of sophistication, lifestyle choices, etc. You know, the human traffickers, the ones that we saw, they were owners and d ivers for haulage companies. A d then obviously, narcotics an you know, human you know, fo drug laundering. As I said, you're going to see a v ry different typology and a d fferent style and different pu chase. You wouldn't see the e haulage drivers, you know, going out and buying Gucci. I do 't think that child exploitat on guys will do that either, but the narcotics guys will so think as well we need to real y think about the psychology be ind these individuals and what

Amy Storer:

I love it. I love the brainstorming! I didn't even type of styles that the would leave behaviors to I on't know, man, I'm just kin of thinking about this while w are talking. think of what you just said. One thing leads to the next. Unfortunately the labor trafficking in this country is just terrible with anybody that's that does not have the United States Citizenship will be targeted for labor trafficking, those bank accounts are typically not going to have any transactions in the labor trafficking because they're basically being held against their will and not in a stash house and they're forced to work on this farm or they they're being told they'll be deported, which is not true. We will protect them as victims if hey will be willing to testify.

Oonagh van den Berg:

The awareness isn't there, they don't understand. Somebody will take their passport, their travel documents. I remember whenever I first moved to Asia, and one of the things I was quite surprised about was, we're very, very privileged here that we can actually hire domestic helpers. And, you know, it's all done via the government, you have to go through training, etc, to do it. And I was actually aware of a few employers that actually took the passport of their domestic helper. I was really confused. I said, first and foremost, I was kinda like, that's illegal.

Amy Storer:

Yeah!

Oonagh van den Berg:

But they were like, you know it's stops from being a flight risk. And I'm like the minute that you take someone's passport off them, even though this is illegal engagement of employment. You're moving into the territory of slavery. It was a few people, I know that do it, because they think that their helpers will may be a flight risk. So it's to stop them from stealing and then running off and going to, you know, or polling staff using the documents to pawn. When you take someone's passport from them, you're verging into slavery perspective. Yeah, that's why I was like, guys this is fundamentally wrong. But, unfortunately some people didn't seem to think it was wrong.

Amy Storer:

I would report that is definitely a red flag. I mean, that is the number one red flag. I worked a labor trafficking case where these poor Hispanic men, two of them actually died on the farms. They didn't get any water. No, just terrible. And then there's been other cases that I've seen where labor trafficking is also mixed in with sex trafficking, where they're fitting the the labor slaves, sex slaves from Mexico. And they're bringing them in to keep their other slaves happy. And it's just things that you wouldn't even think of like adoption trafficking. My God! There are these people, and I don't even know how this thought gets into somebody's head, or these two hillbilly losers sitting around a bonfire like, hey, how can we make a quick buck? I don't know how this comes into anyone's head. But they decided it was a good idea to go to these really poor countries. They're called the Marshall Islands where this was happening a lot. For some reason the Marshall Islands they were targeting. Probably because of the laws there, which have changed since this became a major problem. But they would go to these poor countries and they would try to find pregnant women who were very much in poverty, and they would convince this woman to give up her baby, and you know, but it was very controversial, because many of them said they felt forced, too many of them were bribed, many of them were threatened, and all kinds of things. So it's just another thing. It's like banks are incredible. Like this one SAR that I read, I was looking trying to find organ trafficking, organ harvesting, anything pertaining to that. Believe it or not, I searched for all kinds of terms in the SARS. If I'm targeting a name of a band, or a name of this guy's alias or whatever, I try everything. I love it. Because it's amazing what the details does. You guys are just doing amazing work. But one of the things that I would search for I was trying to find organ trafficking and it's something I'm very concerned about. I believe it's happening more often than than we realize. And for me, I was very much looking into it. And there were there were quite a few filings more than I expected. Not a whole lot yet but the banks are doing a good job of looking into these particular donors where people can donate organ and money laundering that's affiliated there. They're flagging that as potential organ trafficking, organ harvesting. But one of the best SARS I think I've read in a long time was this particular bank was playing for this woman who was buying just massive loads of baby formula. Why would any woman need to buy this amount of baby formula? Right? So like you mentioned, so weird pattern like who does that? Well, it turns out it's a baby mill right? It's where they import these women from China. And they basically traffic that woman's body for this adoption tracking scheme and force her to have all these babies and she might be saying she's a willing participant who knows I think it's trafficking. But it's where they force them to have these babies and the people that are going to adopt the babies think it's, you know that this woman just want to give up her kid when in fact it's an actual baby mill if you can even imagine. And so it's just unbelievable what people will do. Another thing is like the bank's one thing that you might mention to people that I think is interesting is there was a study, and I don't know who did it, I wish I could remember. But they said human traffickers, their biggest expenditures is obviously hotels but also phone bills. Human traffickers apparently spent about a third of all their expenditures on phone bills. And those are pre pay lines under their main phone line. So when I send a subpoena to the phone companies, we always ask to get those prepaid lines that are underneath. That's how they control the girls, get them to their appointments and control them and know their every move. But, for example, if I'm running a business would I have like 100 phone lines as prepaid lines underneath? Maybe, but it's it's unusual. Especially if a lot of those are women. But the phone companies a lot of times they don't even know the name of those prepaid lines. It's just a bunch of numbers under their main umbrella account. I want to find the biggest pimps in America. And I believe it would be very easy to do this. If we found whoever in this country has the most prepaid lines that happened to be, you know, all females, right. I mean, could that be a legitimate business? Why would all of your employees be female? What they ended up telling me is, it would be impossible to do that, because they don't know. Apparently, they don't track the name of those prepaid lines.

Oonagh van den Berg:

I think this goes back to how easy it is. This was by default, this accidentally happened to me, our phone bill with our phone contract was actually coming up as it was due for renewal. I went to the shop but the shop didn't exist anymore. They actually closed and they were somewhere else. And I didn't have time to I didn't have time basically to go to the other place. There was five or six other phone shops so I went into one of them that looked like it was quite busy. Yes, obviously, that was a good sign to me. That was good. I went in, I said, right. I need a family plan. So I need three SIM cards. And they were like, okay fine. I said, what do you need? Well, we need a copy of your ID and we need your proof of address. And I haven't brought my wallet with me. So I said, I don't have my ID with me but I can show you a picture of it on my telephone. And he said okay. And I said I'm what about proof of address? I said, I can send you that from home. So I walked out of that shop with three brand new SIM cards having showed my telephone, that was it. And I was like, Oh, I'm an honest person here. But yeah, how easy would that have been for a criminal to do that?

Amy Storer:

I think you bring up a really solid point here. Because when I'm working trafficking cases it's the money in the phones thats the big thing. And it doesn't seem like there are very many regulations on these phone companies, it's kind of crazy! Because when I order my subpoenas, and I tell all the agents and analysts, you have to specifically put in there include account notes. Those are like gold because it'll tell you you know, but that's that's really like up to the person if they decided to write a note about that. Right? So, um, you know, and so basically Verizon Wireless or whoever, if let's say the like, the trafficker has the phone line and the person working at the phone shop happens to be a diligent person and put a note in the account that well three different females came in today and pay that account bill off in cash or whatever. And we're just lucky if we get that information if that person happened to write that down or whatever but you bring up an interesting a very interesting point that it's very easy. Apparently you can even change your IMEI number. You can go into the phone store and tell them you want to change that. And these traffickers do this kind of stuff all the time they switch phone numbers non stop. That would be another key indicator somebody that's constantly switching phone numbers. They're trying to lose somebody, they're trying to be off the record. And they're probably either going to be a victim or a trafficker. Traffickers will also change their phone numbers frequently. But the victims are constantly changing phone numbers so that they can't be found. They have new phone numbers on the sex ads all the time. And it's sometimes, it's a major headache for us. And many of those phones are dropped phones that we can't even get records on whatsoever. It's hard to imagine that's even legal. Imagine the victim has this phone number well it's garbage, there's literally nothing we can do. We can't get any records on it whatsoever. Not even subscriber information.

Oonagh van den Berg:

I think this is one of the biggest problems. It's not just an FI problem. It's not just a problem that sits with one person. There's a sectorial issue across multiple sectors. It's a it's an entire awareness program. And unfortunately, criminals will always find another way to increase the complexity of the way that they're doing things to, you know, change the typologies. But, you know, what we want to focus on is awareness training. Unfortunately, human trafficking and modern day slavery happens all around us every single day. And we may not even recognize the red flags because of a lack of awareness or that we just kind of accept it as a normal practice, or we choose to ignore it, because it's not 'our business'. It's been such a pleasure to talk with you today. I said, I've been so excited after seeing all of your posts on LinkedIn and the work that your doing, the education, development of the industry globally is phenomenal. Please keep that up, please don't stop. And I would really love it. If we can get you on one of our webinars in the coming months to talk as well about some of the things we can do. But me I am so so incredibly grateful to you and I just want to say a massive thank you for all of this time.

Amy Storer:

I learned so much. You taught me so much. I feel like I want to take a class from you. I mean, you're so brilliant. And these are the kind of conversations I think we really need to have between the financial sector and law enforcement. Because that's how we share information. We share trends and we share experiences and you are pioneering, you're making big changes in the world and the financial sector. I'm so proud of you, I just think you're the coolest person I've spoken to in ages. And, and I'll introduce you to when we hang up here, I'll send a little message and thank you so much for everything, I really look forward to continuing to collaborate together and keep learning from each other. That's that's most important. Absolutely. And me,

Oonagh van den Berg:

Thank you so much for supporting role compliance. It means the world! You know, if we can change one person or we can see if one person through these messages through this training through this awareness, it has been worth every single sweat, blood and tears that's gone into this. And again I just thank you so much for today. I'm really, really looking forward to meeting *****. But most importantly, I'm so excited and happy to have met you finally and I'm really exc

Amy Storer:

Absolutely. I'm going to spread the word about RAW Compliance everywhere. I'm just gonna, you know, you're just amazing. Thank you so much.

Oonagh van den Berg:

Thank you! Bye!

Intro
Trafficking Crisis
Child Exploitation
How Compliance Helps Identify Human Trafficking
Oonagh and Amy Get To Know Each Other
RAW Compliance
How We Can Make Real Change
Knock On Effect Of Human Trafficking
Labour Trafficking
Tracking Phone Bills
Outro