Episode 89

Diary of a Healthcare Fraud Investigator: Inside the FBI's War on Fraud

Hosted by Matt Adams

“One of the things that surprised me about that case is when we would approach some of these doctors and say … ‘Why, why'd you do it? You know, so you're getting $100 a patient for each patient's blood that you were referring to this lab’…. Their answers were, ‘It was easy, and, and I didn't think anybody was looking, and I don't think anybody would notice.’"

Over the course of 26 years and five presidential administrations, she handled cases worth hundreds of millions of dollars and formed the DOJ’s top healthcare fraud unit.

In this episode, host Matt Adams sits down with Laurie Allen, a former FBI Supervisory Special Agent, corporate lawyer and Air Force veteran with a degree in math. Now a principal at Withum, Laurie reveals how her unconventional background shaped a methodical, step-by-step investigative style that has defined her career.

The conversation goes behind the headlines: from a kickback scheme involving over 50 healthcare providers and $100 million in restitution, to an "evil genius" stock-hacking scheme and the cell-structured "Operation Brace Yourself" telemarketing fraud that kept conspirators insulated from one another.

Laurie also breaks down how modern investigations actually originate — qui tam whistleblower suits, tips from scorned exes, and increasingly, AI-driven data analytics — and why data alone will never replace a human "storyteller" willing to talk to agents.

Whether you're a healthcare executive, compliance officer or defense attorney, this episode offers rare insider perspectives from both sides of the federal enforcement equation.

The views expressed in this podcast are those of the participants and should not be considered the views of Fox Rothschild LLP or its attorneys. This podcast is for informational purposes only, is not legal advice, and does not create an attorney-client relationship.

The views expressed in this podcast are those of the participants and should not be considered the views of Fox Rothschild LLP or its attorneys.

This podcast is for informational purposes only, is not legal advice, and does not create an attorney-client relationship.

Welcome back to "The Presumption of Innocence," a podcast brought to you by the White Collar Criminal Defense and Government Investigations Practice at Fox Rothschild.

What does it really look like inside a decades-long federal investigation into healthcare fraud?

You know, the kind that dismantles billion-dollar schemes, sends doctors and executives to prison potentially, and reshapes an entire industry's compliance landscape.

In this episode, we're going to talk with former FBI Supervisory Special Agent Laurie Allen to take listeners behind the scenes of her 26-year career at the Bureau, where she built the Newark field office's healthcare fraud program into one of the top 1% nationwide within DOJ.

From her early days cutting her teeth on complex white-collar cases to her current work in the private sector advising organizations on how to avoid becoming the next target, Laurie offers some rare perspectives on both sides of the federal enforcement equation.

In a way, we're going to take a look into a diary of a healthcare fraud investigator, and the stories, I'm sure, are going to be as extraordinary as the stakes.

Laurie, welcome to "The Presumption of Innocence." It is so great to have you.

Thanks, Matt.

Great, great to be here.

Thanks for inviting me on.

Really looking forward to this.

I think it's going to be a lot of fun, and you know, hopefully we can educate some of your listeners along the way.

So take us back to the beginning, Laurie.

You have a math degree and a Michigan law degree.

You were practicing corporate law in Detroit.

What made you walk away from your law career and as they say, become a recovering lawyer and, and head to the FBI?

Yeah.

You know, Matt I, I was at a great firm in Detroit practicing law.

I had really everything that any, you know, graduating law student would want.

You know, a great firm, a great career, you know, a great future there.

But unfortunately, I just wasn't happy doing that type of work.

You know, legal work can be tough.

I don't need to tell you or, or your, your colleagues.

And it's not for everybody.

It's a great career, but it just wasn't for me, and I was looking for something different.

I was, had previously been in the United States Air Force.

I liked that.

I liked the discipline and the structure that goes along with that, but I didn't want to wear the uniform every day.

So I was looking for something, you know, along those lines as something I could still use my law degree in you know, and, maybe still do some, some good you know, some public service type work like the military, but something a little different.

And I just kind of, quite honestly, almost by happenstance applied to the FBI almost on a lark.

And it, it, it was, it was kind of one of the greatest things that that I ever did.

It ended up being a, a great career for me and was really blessed to you know, be accepted and, you know, make a career out of it.

So, so let me, let me peel that back a little bit.

Was there a specific moment or a case, you know, you mentioned your military service, and I would be remiss if I didn't thank you for your service.

But was there something that triggered that idea of becoming involved in federal law enforcement from merely just being interesting and, and moved it towards the inevitable for you?

No, I don't think there was one particular, you know, instance or one thing.

You know, I just, I was as a young associate at a law firm, I was, I did litigation.

You know, and as a litigation associate I'm sure you're aware, you spend a lot of time you know, doing the research, writing the briefs, going through the evidence, and not a lot of time in court.

And, and I was looking for more of, of that, of, of courtroom time.

I applied to be an assistant US attorney, because I thought that would be something that I would like.

It, it would give me an opportunity to get on my feet and get into court more, more often.

It, but was not accepted.

And you know, so that, that, that initial foray into applying to be an AUSA kind of made me think, "Well, who do AUSAs work with?"

And then I kind of went from there.

So looking back, your math background and your law degree really became useful, I think, because that combination of quantitative skills and investigative work are really the essence of what healthcare fraud investigations are about.

To put it succinctly, math really matters in these white-collar cases.

How did those, that training, that experience, that education give you a nudge towards the white-collar world, the healthcare fraud, as opposed to the other various sundry of different tracks you could take as a federal agent?

Yeah, you're, you're, you're right, Matt, that math really does matter in these, these white-collar cases, right?

It's, it's, it's always follow the money.

It's, it's adding things up.

But I think even more important than, than the math of, of the investigations is what mathematics taught me, and it's, it's really a step-by-step logical approach to a problem.

You know, given any, you know, complex mathematical problem, you have to break it down, and you have to think about it logically and go step by step.

If you don't do your steps in the right order, you're going to come out with the wrong answer.

And that helped me.

That, that training in, in mathematics helped me not only in law school, because that's very, you know, very much how you have to deal with, you know, with the law school Socratic method, that step-by-step, logical take-things-in-order approach.

But also investigations, right?

It's, it's you, you need to be able to think each step, what you're hoping to get from that step before you move to the next one.

And it really is-- I know in law school they of- often talk about teaching students how to think like a lawyer.

I think I kind of knew that before going to law school because I thought like a mathematician.

And, and I think that thinking like a mathematician, thinking like a lawyer you know, carries over into investigations very well.

So, your formative years you have the, the discipline from the military.

You have a law degree giving you the sort of framework and rubric under which these laws are investigated and prosecuted, and then you have this quantitative analysis background.

I mean, you were a, I, I would dare say, right out of central casting for somebody that needs to go in and work fraud cases.

So let's, let's turn to your career in FBI.

You were there 26 years in the Newark, New Jersey, field office.

You worked healthcare fraud, securities fraud, mortgage fraud, bank fraud, corporate fraud.

You put anything in front of fraud, and you worked it.

Yeah, that's true.

You, you, you, you rose from a special agent to a supervisory special agent and then ultimately were, were leading a full squad.

Your, your experience in, in securities law led you to a, a FINRA mediator appointment.

You were named Investigator of the Year by the Federal Law Enforcement Officers Foundation.

I, I just want our audience to get a flavor for your squad assignments over that 26 years.

How does the d- the Bureau decide where to put this mathematician with a law degree with a military background into these settings where those skills are going to be so valuable?

I mean, how did your career trajectory really unfold?

It, it really starts right when you're in Quantico, and I think you know, when you're, when you're at Quantico getting your, your FBI training, they start assessing you right then and trying to figure out, like, what are you good at?

What are you weak at?

And, and where would you, where would you blossom?

Where would you fit most logically?

And you're right, my background, I'm sure, had a lot to do with with where I ultimately ended up.

You know, but a little bit behind, you know, how the sausage is made is a little bit of a mystery to a lot of people in the Bureau.

Like, how I ended up in Newark versus Chicago, I have no idea, right?

It's, it's just, they say it's the needs of the Bureau, and they needed me there, so that's that's how I ended up there.

But you know, my first assignment out of Quantico was right in, into the Newark field office on a squad you call the New Agent Squad.

And, and basically it's, it's baby special agents who don't know what they're doing yet.

And you spend a couple months on that squad just trying to figure out, like, you know, how do I get to the office?

Where's the coffee pot once I get to the office?

And, and just the basics, you know.

You spend a couple of months doing that, learning the way around the state.

You know, New Jersey was a new state for me.

I grew up and spent my entire life in Michigan so, you know, didn't know the the ways of New Jersey.

You know, the first time I heard somebody give me directions and they told me, "Take a jug handle," I, I, you know, was lost like a deer in the headlights.

But you know, I spent a couple months on that first squad just learning the basics.

And then I went right from there to a, a complex white collar squad working financial fraud.

A lot of market manipulation, insider trading, stock market fraud.

We also did the mortgage fraud, identity theft.

It was a catchall squad that did a lot of, of frauds that didn't go on specialty type squads.

And I really spent a, a good number of years there and honed the skills necessary.

From there, I moved to the healthcare fraud squad and spent, you know, probably the last 10 or

12 years of my career working healthcare fraud.

You know, first as an agent, then, then as a supervisor.

But it, it all kinds of comes together and, and everything that you learn along the way feeds into, you know, what you do next.

Well, you were, you were heavy into the fraud cases.

I almost jokingly said you put anything in front of fraud and, and Laurie Allen worked it.

But those different fraud types from the Bureau's perspective, from a, an agent's perspective, and then ultimately a supervisor's perspective, do those different fraud types require different investigative muscles, or is it largely the same paradigm?

I mean, I o- I often, when I explain what I do on the defense side in terms of my white collar practice, I, I generally say, "You put anything in front of fraud, and I've pretty much handled it."

And I'm making the same observation about your career at the Bureau, but specifically as it relates to an investigator working as a federal law enforcement officer, how do those investigative muscles ebb and flow when you go from securities to healthcare to some other species of fraud?

Yeah.

You know, it, it really is very similar, the different fraud schemes.

You know, we've all heard the phrase, "Follow the money," right?

And, and that's what fraud is.

It's, it's money.

And whether it be a mortgage fraud or a healthcare fraud or a stock fraud, the stock or the mortgage or the healthcare program is just the vehicle by which somebody is stealing the money.

So yeah, you, you do need some different skills for each different area.

Like, you need to know a little bit about mortgages if you work in mortgage fraud, and you need to learn a little bit about healthcare if you're working healthcare fraud.

But a, a lot of the steps, a lot of the process, the the discipline really to, to start and follow the step-by-step process that should be taken is very similar.

Again, you need to become an expert, and, and that's really what the FBI is very good at developing is taking regular folks like me off of the street and saying like, "Okay, we need you to work stock fraud." And I didn't know anything about stock, but now I study it and I become enough of an expert that I can work that investigation.

"Now we need you to work healthcare fraud," and I didn't know anything about healthcare plans and policies and, and procedures.

But you study enough of it so that you can, and you become that expert.

Well, federal healthcare fraud enforcement constitutes one of the most resource-intensive but statistically consequential categories of white-collar criminal prosecution in the United States.

The 2026 National Healthcare Fraud Takedown on June 23, 2026, just a matter of weeks ago, charged 455 defendants across 56 of our federal districts in this country, including 90 licensed medical professionals in schemes exceeding $6.5 billion in alleged false claims.

At the time, DOJ cited, "significant patient harm, including death," as some of the ultimate consequences of this scheme.

Fifty state task forces participated in this investigation.

Some collateral actions ancillary to this criminal prosecution included the CMS suspension of 1,079 providers, $182 million in seized assets, 48 HHS OIG civil monetary payment settlements exceeding $73 million dollars, and 928 DEA administrative actions, and this is all just since October of 2025.

To put it bluntly, healthcare fraud continues to be at the top of the federal government's enforcement priority list This follows other very, very highly publicized multi-defendant takedowns with lots of money, as you might imagine, being seized.

How did healthcare fraud become your primary focus as an agent?

New Jersey's FBI office and US Attorney's Office is notorious for being one of the most successful offices in healthcare frauds prosecutions in the country.

What was your trajectory like to land you at that squad?

And then I want to dig into the work and really peel back the cloak on some of the ways that these cases are built.

Yeah, you, you know, changing my squad from working the stock market and insider trading cases to going over to work healthcare fraud cases was more as a result of the healthcare fraud squad had lost some, some agents recently, and they didn't have a lot of senior agents on it.

So they just needed some senior agent with experience and leadership capability to go over and work cases.

Being honest with you, Matt, I didn't want to be the one, but you know, the boss said-

But your, your boss has told you otherwise, right?

The boss has said, "We need your leadership over there.

This is a good opportunity for you." You know, we always joke in the, in the Bureau when somebody says, "This is a good opportunity for you," it's probably not something you really want to do, but you're going to do it anyhow.

And, and I tell you, it, it was one of the, the you know, best career moves I made, even though I didn't want to do it.

You know, I was comfortable on my squad.

I was comfortable working, you know, what I knew, what I had learned, and now you're asking me to learn a, a different area to you know, study up on healthcare fraud and healthcare regulations and compliance.

You know, that, that wasn't in my plans.

But they needed the leadership, and they said, "Laura, you've got the leadership skills.

You've got the, you know, the investigative background that we think you can do this.

We want you to move over there." So, so I did, and that's how I ended up

Dutifully took the assignment,

Yeah.

… As a, a- as a, as a good airman would right?

And,

That's, that's right.

You know you salute and execute.

You, you, you tell them all the reasons why it's not a good idea, but then if they say, "Yes, you're going to do this," you say, "Yes, sir," and, and you do it.

So you took your law degree, your math background, and your military discipline, and you went and built the Newark field office healthcare fraud program into one of the top 1% Bureau-wide.

New Jersey is one of the most fraud-dense healthcare jurisdictions in the country.

And you kind of alluded to it earlier, New Jersey's not your home.

You don't know… It, it was not native to you.

Michigan's loss was New Jersey's gain, I would argue.

But what is it about the state's healthcare landscape that makes it such a fertile ground for fraud such that we're talking about leading the nation in healthcare fraud prosecutions up there at the top 1% FBI-wide?

Yeah.

You know, when I first started working healthcare fraud, our typical cases were, you know, a doctor in Jersey City billing for services not rendered, or you know, a, a healthcare professional over in Sparta who was, was overbilling or bundling services.

It was kind of these one-offs of a provider doing something they shouldn't be doing.

And right?

And, and New Jersey, listen, it's a dense state, right?

It's, it's a, a very has a, has a, a dense population, so we, we have a high population of medical providers, of medical facilities.

But I'm not sure that if you look at New Jersey, you know, person for person, you know, via population that we would have any more healthcare fraud than any other part of the country.

It's a small state relatively.

It's a small state.

It's a small state, but it's got a lot of people, so it's very well concentrated.

Right?

And, and I don't think you know- we have any more than any other place, except that we have more people.

So, I, I think that's what drives it, and I think we had the interest in addressing it, and that was really what drove, you know, our program at the, the FBI in Newark to become, you know, the Gold Star program, was because we had great agents on the squad, you know, willing to, to jump in and work a case and make something you know, make something work and, and develop what needed to be developed.

And we were paired with a great United States Attorney's office who really had an interest in working healthcare fraud, had an interest in pursuing these cases.

You know, and as you pointed out with those numbers with the, the most recent healthcare fraud takedown, there's a ton of fraud out there.

And, and I believe there's a ton of fraud out there all across the country.

You just got to be willing to really go after it and, and dig in.

And we developed a program, you know, where we would do just that, and we partnered with you know… I was in the FBI, and I sat in the FBI office, but we also had on, sitting on our squad with us, we, we brought in IRS agents.

We brought in agents from the Veterans Affairs.

We brought in agents from Health and Human Services and, and Postal Inspection Service and DCIS, Defense Criminal Investigative Services, so that we could all work together and make the biggest impact.

And I think that, that creating that task force mentality really helped us really jumpstart the healthcare enforcement.

Is that because the multidisciplinary multi-expertises bringing, if expertises is even a word, but

I'll take it.

All, all that expertise kind of coalescing around the goal?

Is that what did it, is that everybody had a unique perspective?

There's often this debate about like diversity of viewpoints.

You want to surround yourself with people that have these divergent views.

Is that what the FBI does when it builds out these task forces?

Is it intentional?

Yes, that's exactly it, and it, and it's intentional.

And, and listen, there are things that an IRS agent can do that an FBI agent couldn't do.

You know, IRS agents can access you know, tax records that, that we were not allowed to access without court orders.

And, and, you know, they can tell us, " Yeah, it might be a good idea to get a court order for this one," where we wouldn't know that otherwise.

Or, "No, don't, don't waste your time getting a court order for this one." You know, an HHS agent has, has access to to grant information, and to funding information, and to Medicare and Medicaid data much more easily than the FBI does.

We could still access it, but it would take us a few extra steps.

And we bring those different perspectives all together, and everybody has something to contribute.

And it really jumpstarted things quickly to the point where you know, near the end of my career, we were really almost co-located with the attorneys also.

Because we wanted to be right there so that if we needed a subpoena, we could just, instead of having to pick up the phone or to send an email, we could just yell over our shoulder, you know, "Hey, we need a subpoena for this." And you know, we, we wanted that working relationship to be that close so that they knew what we were doing, we knew what they were doing, and we were all moving in the same direction all, at all times

And over the course of building a relationship with you, Laurie, I've had occasion to meet some of the people that you worked with that are now out of government or some that are still in it.

And they have, they share the same, the same thing about the way you guys coalesced as a team to make this work.

What does 1% nationally actually mean in bureau metrics?

Is it predicated around case volume, conviction rate, dollar recovery, or all of the above?

I'll tell you, I want, I want to get into the sources and methods and peel back the, the sort of special sauce that the bureau uses to bring these cases.

But your success kind of speaks for itself.

So, so explain that to me.

What does it mean?

Yeah, so the 1% it is something that headquarters you know, they evaluate all the programs each year.

And it is, as you said, all of the above.

It's not only you know, are you using your resources appropriately, but are you making cases?

Because, you know, face it, there are some cases that you may work full time, and it might take three, four, eight years before you even get a, a, a charging document or a conviction.

Now you, you don't want to look like you're doing nothing for those first, you know, several years because you're working your tail off on that case full time, but it takes that long to build a case.

So headquarters, when they're reviewing these things, they, they look at that.

Are you working the complex cases, or is it a one-off doctor in a local town who's, who's billing?

Listen, those cases are important.

You got to work, work those cases.

The FBI has to work those cases too.

But if you have the resources and you have the manpower, you should be working the more complex cases that, that stretch, you know, far and wide.

And you know, and they evaluate all that stuff.

In 26 years of healthcare fraud work, you must have some cases that still keep you up at night, haunt you a little bit, maybe some that you're most proud of, maybe some that you wish turned out differently.

Take us into one or two of those.

What's a, what's a case that really still defines your time with the bureau?

Yeah, so I think one of the biggest cases that I worked on as an agent it was a, it was a kickback case.

Doctors were receiving kickback payments from a, a local blood, you know, an out-of-network blood lab.

You know, 100 bucks here for, for referring their blood to this lab, you know, rather than to the in-network blood labs.

That, that case I inherited that case from another agent who, who worked it up to, to a, a great position.

I took over that case and kind of ran it to the, to the finish line.

But it, it ended up netting over 50 healthcare providers,

You wouldn't say, Laurie, I was involved in that case.

Well, I did not know that you were, you were familiar with that one.

Yeah.

Yeah.

Yeah.

I'll tell you-

So go on, I digress.

There were a lot of de- there were a lot of defense attorneys involved in that one, I'll say.

Yeah.

Half the defense bar in New Jersey was involved in that one.

Yes.

Yes.

Right.

A lot of defense attorneys were involved in that one.

And it was just a great case, and it, and it just started with, with our partners over at an insurance company saying, "Hey, something doesn't look right here.

There's this this small blood lab in northern New Jersey, and they're just doing a ton of volume.

Don't know why, you know.

Maybe it's normal, but, like, maybe take a look at it." Right?

And, and, and that thing just blossomed out into a, you know, 10- or 14-year investigation.

Like I said, over 50 providers, a blood lab, over $100 million in restitution ordered.

You know, and so that really was kind of one of my marquee cases, I think, that really had an impact.

And I, and I think it had a, a good deterrent effect.

You know, providers who you know, are taking kickbacks for referrals, you know, maybe paid attention and said like, "Hey, maybe I shouldn't be doing this."

Yeah, one of the things that surprised me about that case is when we would approach some of these doctors and say like, you know, "Why, why'd you do it?" You know, you know, so you're getting $100 a patient for, for each, patient's blood that you were referring to this lab.

So you'd get, you know, a couple hundred bucks a, a week or something like that.

Their, their answers were, "It, it was easy, and, and I didn't think anybody was looking, and I don't think anybody would notice." And, you know, and some of these numbers then ran up into the, into, into big, big dollars, into the hundreds of thousands of dollars.

And you know, it just started easy.

Like here's $100 now, and, and, you know, a few years down the road we're, we're talking, you know, several hundred thousand dollars for that particular provider.

It, it's, it's funny you should mention this notion of partners at an insurance company.

You know, one of my big beefs is that some of the insurance industry, in New Jersey in particular, funds the, some criminal law enforcement efforts in various state agencies across the Office of the Insurance Fraud Prosecutor and other things.

I think there's some real need for reform there because some of the conflicts of interest that kind of create out of that dynamic where the insurance company's almost using law enforcement like its its own private security force.

How was it partnering with some of the large healthcare companies in New Jersey?

You know, we're, we're chock-full of health systems.

We're chock-full of pharmaceutical companies.

The insurance industry is very prevalent here.

When you call them your partners, was it… What was that relationship like?

Because I would argue that a large number of cases get made just the same way as you've described.

In my career, I've seen it happen time and time again, sometimes under circumstances where the information being fed to the government is not accurate.

I, I have a very substantial case that I was involved in where a major US pharmaceutical company fed information to the government that was flat wrong.

They prosecuted the guys and ultimately had to dismiss the indictment.

What kind of you know, trust but verify type of activities would go on when these private actors were making referrals?

Yeah, Matt, you, took the words right out of my mouth there with your trust but verify, right?

You know, the relationship we had with in- insurance companies, providers pharmaceutical companies, medical device manufacturers, right?

New Jersey's full of those as well, very strong.

And that was something that we intentionally set out to do, is to build those relationships because we wanted those referrals.

My understanding, and I don't know New Jersey law.

Again, I practiced law in Michigan, not New Jersey, but my understanding is that New Jersey law requires New Jersey insurance companies to report certain activity to the, the state to different state agencies.

You know, and it was my feeling at the FBI that it's like that's given the state the first crack at these good cases.

Like, I, I want that case.

Turf war.

Yeah, right?

So we always worked to build the good relationship.

So even though they had to refer it by law, they referred to the state, they would, they would, you know, give us some information as well.

And, and I will say that, that for the most part, we did, we were able to rely on the information they provided us, but we definitely verified.

That's part of building a white-collar investigation, right?

You've got to get your information from other sources, whether it be bank records, billing information, billing claims, claim information from insurance companies, but you've got to be able to verify that and you know, and independently somehow come up with some indicia that it's, it's accurate and, and truthful.

You know, and that might be through, you know, witness testimony, that might be you know, some other corroborating documents.

But we did rely a lot on private industry in my years in that leading up the healthcare fraud program in, in New Jersey.

And that, and that was, that was important for us because that, those were important ties to have.

You know, and, and these different companies, the insurance companies, the pharmaceutical companies, chemical companies, like they wanted to be friendly with us in the FBI because listen, they're the ones who are most frequently victims of healthcare fraud schemes particularly the insurance companies.

So, you know, so we did work together and partner frequently.

You know, this is really a two- twofold question, and I really want to explore this as sort of the precursor to some of the inside baseball sources and methods kind of stuff.

But while we're on this topic of some of the major cases and how they were built and these partnerships between government and private industry that helped to build them, you know I think I'm distilling from your remarks here today that the sophistication of healthcare fraud in particular sort of increased over time.

Yes.

It went from these ones and twos to a more sophisticated approach.

What's the most sophisticated scheme that you ever encountered?

You know, the one where you thought, "These people are genuinely brilliant and had they used this for the right reasons, they could be very successful and wealthy.

But my, my job here is to, to dismantle this scheme." Talk, talk to us about, about that, where you… The, the, the one or two instances where you thought there was just evil genius going on because of how sophisticated the scheme was.

Yeah, the, the one that comes most quickly to mind isn't a healthcare example, but it was a, a market manipulation case where instead of doing a traditional pump-and-dump scheme, the bad actors were hacking into online brokerage accounts and doing what we, we termed a hack and dump.

They would hack into Matt Adams' online you know, Fidelity or, or, or brokerage account, sell off all your blue-chip stock, and buy up some bogus, worthless penny stock, which they happened to own a lot of.

Once they would buy up, use your account to buy up the, the stock the, the penny stock, of course the stock price would go up.

They would then sell off their stock in you know, various covert accounts.

But the, the, the the coordination it took to pull off this scheme, you know, the, the timing and the way they were able to hide the, not only their hacks, but also hide their trades so that it was difficult to trace it back to them really was evil genius, as you say.

They used different things like botnets and, and you know, different complex online tools to, to, you know, to execute this scheme was, really was, as you say, evil genius.

I think, I think one of the you know, a, a healthcare scheme that was, I don't know if I'd say genius, but was complex in its in, in its execution, was the one that a few years ago, you probably heard about it, with the, the nationwide takedown.

It was, it was something that was called Operation Brace Yourself.

There were-

Another one I'm involved in, Laura.

Another one.

Another one I'm involved in.

I think my career helped helped to fuel your career, Matt.

Yeah.

Yeah.

I, I know the case well.

Right?

So just for your listeners who aren't as familiar with it.

You know, there would be individuals who would telephone senior citizens who were on Medicare and say like, "Hey, does your knee hurt, or does your back hurt, or does anything hurt?"

And when, you know, you know, listen.

And we all reach a certain age, everybody has something that hurts, and then the person would inev- inevitably say like, "Oh, my wrist, or my ankle, or knee," or whatever it is.

And they would sign them up to receive a, a knee brace or whatever part of the body they they needed or, or they told the, the caller that was, was hurting.

And, and there was a whole bank of, of these callers who would do this, this type of calling, outreach to, to seniors to, to, you know, convince them to get, get various braces for their knees or ankles or whatever.

And these, these banks of callers, these telemarketers if you will, had no connection to the rest of the scheme, right?

So they were a very tight little cell.

They did what they did and didn't know what everybody else was doing.

And what everybody else was doing is there would be a doctor who would then sign the scripts authorizing a knee brace or an ankle brace or a you know, whatever whatever brace or support was needed.

And that doctor didn't know the callers and didn't know the, the further upline people.

It was a, it was a complex scheme that wasn't you know, it wa- it wasn't difficult in its execution, but the fact that they were able to keep themselves in individual cells so that when you broke into one cell, and law enforcement was able to maybe flip or turn people and get them to cooperate, a lot of them didn't know who, who else was involved.

So, so that was kind of the genius part of that scheme is that they really kept themselves insulated from the potential that somebody else is going to turn state's evidence on them.

So I want, I want to change into now this we're, we're really peeling back the layers of the onion here.

I want to go into this in inside baseball that I've been predicting for our audience.

DOJ's healthcare fraud strike force model today dates back to 2007.

There are now nine strike forces nationally.

The National Rapid Response Strike Force handles the largest national case.

A new West Coast strike force was announced in April of 2026.

DOJ's Data Fusion Center and Financial Intelligence Review Team use AI, claims data, cloud computing, really high-tech stuff to bring these cases.

Investigations really can originate from just about anything.

Human intelligence, cooperators, the so-called people that flip.

They can also originate from qui tam whistleblower lawsuits, HHS OIG referrals, Medicaid administrative contractor anomaly reports, tips from employees and competitors, and increasingly, as I led with, this proactive data analytics work that goes on behind the scenes.

We have, as you've already mentioned, these strike forces, these teams of different expertise being brought together literally under the same roof, maybe in most instances in the same physical location, so you can yell across the hallway-

Yeah.

… And cooperate and collaborate.

Let's demystify how these cases land on your desk as a federal FBI supervisory agent.

Where did it come from when it lands on your desk?

What's the most common entry points into the investigative matrix that ultimately could lead to prosecution?

Yeah, and you, you hit on a lot of those already, Matt.

A, a big source, qui tams, right?

The qui tams were a big source, and we you know, when I took over supervising the squad, that was something we kind of made a focus of is, is the qui tams.

Because listen, they're, they start off as civil matters frequently.

And, and really it was our goal that if we were going to get involved we wanted to see if we could turn it into a criminal matter, a criminal investigation.

But a lot of cases originated, you know, from that.

But, but also, like you said you know, insurance companies, competitors.

Listen, we had one case, I remember the one case where we had a woman call us up and say her ex-boyfriend was committing fraud, healthcare fraud.

Now, she didn't know exactly what he was doing.

She didn't understand it.

She described it the best she could.

You know, and we, we sent out some agents and talked to her and tried to figure out what she was talking about, and then we looked into her, you know, well, who is her boyfriend?

Who does he work for?

And what, what is he doing?

And how is he making his money, and, and so on.

But, but right, hell hath no fury like a woman scorned.

Like she was mad at him.

Oh, yeah.

She was mad at him.

She called us and said, "He's committing health care… He told me he's committing healthcare fraud," right?

That's how… Because there's always that question of-

He bra- he bragged about it.

Yeah … he bragged about it.

There, and there's al- because there's always that question when somebody comes to you and says, "I have a great case for you." It's like, "Well, how do you know about this?" Right?

It's against my ex because I hate him now.

Yeah, right.

But, you know, the agents pursued that doggedly, and it turned into a huge, huge case.

Now he was, you know, he was just the small part in the very beginning, but once he was approached, you know, charged and, and he decided like, "Hey, it's in my interest to cooperate." He, he flips and he starts telling us more, and more, and more, and you kind of work your way up.

And you know, if you find a good case like that you work those for, for years.

But that was, that was a case that, that turned into the compound pharmacy case, and that's, was very big here in New Jersey for a long time, where, you know, creams and, and gels and, and prescriptions were being sold as compound that, that weren't really compounded and weren't really needed.

Were you involved in that one too, Matt?

I, I, I take the Fifth, Laurie.

Okay.

But it started from a simple, like, a woman calls in and says, " I know this person.

He's committing fraud.

He told me so." So, so cases come, you know, would, would find my desk just any number of ways.

We always liked the best cases, the ones that we would prioritize and, and want to work, one, if there's patient harm, like, that's, that's a big one, but, but you always wanted to try to have an insider.

You wanted to have somebody who knew, knew the fraud, knew the crime, knew what was going on because either they participated, they were there, somebody told them you know, somebody who could kind of be your storyteller for the

On the defense side, we call them tour guides or narrators.

Narrators.

Absolutely.

Yeah.

A storyteller.

Yeah.

Narrator.

That's right.

Yeah.

Yeah.

Yeah.

Yeah.

Right?

Because they, they, they lay out the road map for the, for the government.

But how do you evaluate whether a tip or a whistleblower complaint is worth a full-blown investigation versus, like, a preliminary inquiry that goes nowhere?

I would imagine when you're sitting in FBI offices across the country as a supervisory agent, there's a lot of tips that roll in.

Yes.

How do you separate the good ones from the bad?

You can't possibly run all of them down, can you?

No.

No.

No, you, you can't.

You can't.

And, and so you do look for some, some things like, you know, if there's allegations of patient harm, like, those you do run down.

And you look for the larger dollar-value cases.

Now, obviously this woman who, whose boyfriend, ex-boyfriend told her she was, he was committing fraud wasn't at the time a large one, but there was something genuine, something credible about her and her story that we believed that we wanted to pursue and, and figure out what was going on.

Right?

So it, it is.

You need a, you need a storyteller.

You, you need, you know, you need a, a dollar loss or patient harm to make it worth the FBI's time.

You know, those are the cases that really get the highest priority interest.

The healthcare strike force model at DOJ has been operating, like I said, since 2007.

How does that structure work?

How does that interplay work with the local FBI office, the local US Attorney's office?

They are somewhat autonomous in, in, in a lot of respects.

Who's in the room?

Who's calling the shots?

I know at, at least from my vantage point at a time during your career here in the District of New Jersey, the strike force was sort of not operating in ways that it does in other jurisdictions because the local FBI office and US Attorney's offices handled their own healthcare fraud prosecutions, and quite successfully at that.

That's changed and shifting prioritization has injected that strike force, that national strike force into the district.

But how do those lines get drawn in the sand about who gets what cases and who takes what lead on which cases?

Yeah, in working the, the strike force and the task force cases, the way we would do it is we would typically want an agent from each agency involved, right?

We'd want an HHS agent and an FBI agent working side by side together.

You know, again, as we talked about before, they bring different synergies to the, to the investigation.

And quite honestly, then both agencies get, get some credit for it, get, get to put points on the board, you know, if you have a successful case.

How, how it works is sometimes it's, you know, w- if, if you're able to bring something in, if you've got an informant who brings in the information, you're going to be the one to step in and, and work that, and to see it through.

If it's something that involves the VA, the VA agent might be the lead on it.

It really is y- you know, I'd like to say there's some science to it, but it's more that some of these cases really call for one agency versus the other to be the lead, and,

Is there a, is it ripe with turf war or is it just you know, we, we find a way to operate in the same sandbox?

I tell you what I think, you know, and we've all seen those movies and, and TV shows where the FBI's like, "Ah, we're, we're coming in and we're taking over," right?

And I did not want that during my career.

I did not want to take over.

I wanted to work side by side.

And, and I think we did a pretty good job of working side by side, sharing the credit.

I don't think there was a lot of turf war.

I think back, you know, longer ago, you know, 15, 17, 18, 20 years ago, there might have been much more turf war type of things going on.

I think currently, and, you know, when I left the FBI, it was a very, very good working team.

And my counterpart over at HHS was somebody I still keep in touch with to this day.

We worked well together.

We saw eye to eye on things.

So, you know, if I had a problem with something, I'd pick up the phone and call her and say like, "Hey, listen, we, we've got to fix this," and vice versa.

And we would meet at least monthly, you know, FBI, me, HHS, my counterpart, and US Attorney's office to talk about cases, to say which ones are going slow, which ones need a little jumpstart, which ones need the agents to start doing something on it, which ones need the AUSAs to start doing something on it, right?

And there's, you've got to have that discussion right up front and, and frequently.

You know, those touchpoints to say like, "Hey, this case is going good.

I don't think we need to spend a lot of time talking about it.

Let's move on to the next case.

This next case, we've been waiting on subpoenas for, for two weeks.

What's, what's going on?" You know.

And when, when the US Attorney's office, HHS, and FBI would get together and talk about it, we would kind of leave our egos at the door.

We, we'd never thought Listen, I, I believe my people who worked for me were the best, but, but I didn't, wouldn't bring that to the meeting, right?

It, it, it would be, "Yeah, it's possible my f- my folks make a mistake. It's possible your folks make a mistake. Let's just figure out what's best for the case and work it out."

It just so happens, Laurie, that your career was situated as right on top of perhaps what was the largest period of technological advancement in the history of the world, I guess.

So, DOJ makes no secret about its healthcare fraud data fusion center combining data analytics, other interagency cooperation.

They use claims data, cloud computing, AI.

They're looking for things like billing volume spikes, referral anomalies, and something that has always irked me, which is outlier metrics.

Mm-hmm.

I once defended a world-renowned cancer doctor who had outlier metrics in just about everything, but he was literally the doctor that you go to to get another year, another six months, to go to your last vacation because literally you are that sick.

But you go to him and he prolongs your life because he's straight-up brilliant, and he had the sickest of sick that most physicians, most oncologists just simply gave up on because they were that ill.

So it, it … I remember sitting in a meeting with the US Attorney's office, FBI,

HHS, not in your district, but another district, and the government had a consultant who was an emergency room doctor And the emergency room doctor was essentially trying to challenge this world-renowned oncologist about his ordering of certain tests.

And at one point it became so intellectually unmatched between this world-class oncologist and this emergency room physician where…

A- and my client was a sweet guy.

He really was.

He was genuinely trying to do right.

He never was charged.

He was investigated and never prosecuted.

On the defense side, we call that a victory, Laurie

That's right.

But he, he, he was a sweet guy and, and didn't come at it with an ego.

Very much patient.

I probably would've lost my patience about an hour into this six- or so hour meeting.

And at, at various points, he just said, "Respectfully, Dr. whatever, you just don't treat the same type of patients that I do. And outliers standing alone doesn't mean criminality is going on. You have to explore such other patient possibilities." And I use that as an example to really talk about the vulnerabilities of data-driven investigations.

Yeah.

I think there's a lot of problems with just relying exclusively on data.

We talk about it in the context of AI all the time.

AI hallucinates.

Data hallucinates.

You need to put guardrails on it, and you need to view it with almost a level of suspicion that allows you to like we've talked about, trust but verify.

And sometimes it's not right because there's other reasons, other motivating factors.

The technology-

Yeah, I was going to say that-

… really

has transformed the, the healthcare enforcement landscape.

Talk us through what that actually means on the ground.

You know?

Yeah, right.

Not the, not the press release version of, of what they put in those DOJ press releases, but, but the, the version of, of an investigator behind the scenes who says… you know, gets an email or gets a call that says, "We've got this oncology doctor, and he's ordering these crazy tests that cost stupid money, and we want to make sure he's not bilking CMS for it."

Yep.

Yeah, right, and, and y- you hit the nail on the head there is, like, when, when you talk about the difference between an ER doctor and a, a specialist oncologist.

You, you need to compare apples and apples, and it, it sounds like you were in a, a difficult situation there.

Your client was in a difficult situation.

But, but AI and data analytics, all this stuff is great because it's doing what we've always wanted to do with, with the healthcare data.

You know, healthcare is one of those areas of fraud that has a ton of data.

There's just a lot of information out there.

And unlike you know, identity fraud or, or mortgage fraud, you don't have that much data.

Where healthcare fraud has a lot of data.

And the information is there, right?

And the information has always been there.

We've just not always been able to sort through the volumes and volumes of, of data to find those outliers.

Now, with all the new technology, we are able to find, you know, those, those outliers.

But you know, the important part, as, as you pointed out in your story, really very aptly illustrates, is like the data gets you so far, but then you've got to, you've got to test it.

You've got to figure out, like, does this make sense?

Walk us through that process, because I can imagine there are cases, I gave you one example, where the technology flags something that turns out to be entirely legitimate.

And how do you guard against those false positive leading to a wrongful investigation, a wrongful prosecution?

This, after all, is a podcast called "The Presumption of Innocence." On episode 53, we had Dr. Muhamad Aly Rifai.

He was a doctor who was clearly prosecuted in the Eastern District of Pennsylvania on one of these data-driven healthcare fraud cases.

He was acquitted at trial-

Wow

… After his life was upended for years.

The jury was out for minutes before they came back and acquitted him on the strength of a, a prosecution gone awry, largely because of this type of data-driven investigation gone wrong.

When you were leading this particular division of the FBI, how did you ensure that that wasn't the case?

And does that mean ultimately making recommendations not to proceed with, with criminal prosecution?

Yeah.

Yeah, listen, the great thing about working for the government is your, your job isn't to put people in jail.

It isn't to prosecute.

It's to serve justice, right?

So sometimes serving justice means, yeah, this person doesn't have,

you know, this person didn't do it, or this per- or we, or we don't have the evidence to prove this person did it.

But just like attorneys in using AI, right?

They can, AI can write a brief for you and, and, and, and… But you still got to go back and check that, right?

There's got to be the human element, and that was one thing where we would use data analytics for leads, for tips for, like, "Hey, maybe we should consider looking at, you know, this provider."

But that was the starting point.

That had to be-

But doesn't that only work if you have somebody in leadership like yourself who's willing to set that tone?

Don't you need strong supervisory agents-

Yes.

In order to set that tone.

People with the military discipline, the legal background, the mathematics background.

Yes.

The idea that… Would

you agree with me?

Ri- yes, I do agree with you.

And, right?

And, and, you do, as a leader you need to say, like, "That's the starting point. That's not the end." If that's the end, that's a problem, right?

And it's just like a lawyer who uses AI to write a brief.

That can be your starting point, but boy, you better go back and, and fact check that and, and, and cite check and read the cases that it, it's referring to you, because if you don't do that, you, you, you're ending at the beginning.

And, and that's that is a, a very poor you know, poor choice.

That has to be just the lead, just the tip.

You know, we used, we used data analytics but only to get us started.

We always want- we always wanted that storyteller.

We wanted the narrator, right?

And, and if the data analytics are right, you know, there's, it's an outlier and, and there's fraud going on, there is going to be somebody else who knows about that fraud.

Well, that's the tr- the perfect transition to what I wanted to talk to you about next, and that's cultivating human sources.

It's cultivating the cooperators.

In an age of big data, would you agree with me, yes or no, that these human sources are still indispensable to a healthcare fraud case?

Absolutely.

Indispensable, probably more so than ever.

Talk to me about what that looks like, flipping somebody in that healthcare fraud case.

You're often dealing with people that are highly educated.

You're talking about professionals, doctors, administrators.

This is not street crime.

This is not, "Hey, I, I, you know, I know what you're up to.

I know you're a drug dealer.

I'm going to squeeze you now because w- we can kind of mess with you a little bit with the power of the government." These are folks that are largely very sophisticated, that have means, that have acumen to know what they're required to do in terms of interactions with an investigator-

and not required to do.

They often have legal representation early on in the process.

How do you flip somebody?

How do you cultivate those sources?

I've, we've had guests on this program, including just recently talking about the idea of course of charging and stacking charges, where the prosecutors have really turned our system on its head by creating this plea machine through overcharging and using it as a means to develop cooperators.

But that's for another discussion with somebody on the prosecutorial side.

As an investigator, how do you sign up somebody to work for Team USA against a lot of odds being stacked against you when you're dealing with this sophisticated professional space and unlike maybe a street crime investigation.

Yeah.

Right?

You draw a great distinction because the street criminals, you know, the gang members and drugs, sometimes being arrested and charged and going to jail is a, a badge of honor.

You know, it's, it's, it's maybe not a badge of honor, but it's, it shows that they've been around and it's, it, it verifies their membership in the gang or, or as a street criminal.

Where you're right, doctors, lawyers accountants you know, business people, that is not something they want to be associated with.

That is not something that they want to be known for.

So it is, it is much much more difficult.

And the key really is before you even approach somebody to try to win them to your side is you've got to know everything about them.

We, we used to joke that we would know everything about our subjects, about our, the people we're going to approach.

We'd know more about them than their mothers because you want to know what makes them tick.

What, what are they thinking of?

What are they worried about?

What, who do they care, whose opinion do they care about?

And, and how are you going to use that to your advantage when you knock on their door and say, "Hi, I'm Laurie Allen from the FBI and I want to talk to you." Right?

It, it's, it's some, some folks will close the door immediately and not want to talk to you.

Like, "Nope, not going to talk to you." You know, then you, then you got to go-

For those listening at home, it's never a good idea to talk to the government until you have your lawyer.

But what's that hardest part about managing human sources in a white-collar investigation with so much that can seemingly go wrong?

Yeah, you know, managing human sources, there's, there's there's so much that's difficult about it, right?

The, just the human frailty of, of individuals and as they're cooperating the doubts they have and they're calling you to ask if they're doing the right thing or, you know, giving you every piece of information whether you want it or not.

Human sources, you know, they're necessary to make good cases.

For white-collar cases, you got to you got to have human sources, you got to have informants you got to have that storyteller, somebody who's willing to tell you that what's going on.

The thing to remember about that though, for so many of these individuals, you know, they were once a participant in the fraud.

They were, you know, they were a part of it.

They participated, they engaged in the fraud, and now they're working with you, turning against their business partners, turning against their the, you know, their co- their co-conspirators.

And what you've got to, as an agent, what you've got to remember is if they're going to turn against their business partners, people who they've known for, you know, in some cases since they were in high school or, you know, for many years, they'll turn against you, too.

And you know, so that's one thing that as an agent, you got to have the informants, but you've got to know you can't ever really fully trust them.

Just like the data analytics, just like the AI, you take in that information, but you always got to verify and corroborate what they're telling you

So I, I often like to ask my guests on this program a series of crystal ball questions.

Using your experience and background to sort of project into the future.

And lo and behold, because healthcare fraud is such a big part of what white collar criminal defense lawyers do, the white collar landscape, I want to ask you probably a little, a little more than a series that I, than I usually ask my guests.

But you've really been on the front lines watching healthcare fraud go from somewhat of a niche priority to front-page news over and over again.

How did the bureau's commitment change from the time that you were there, from approximately 1997 to 2023?

And where do you see it going next?

I think we've both agreed it's not contracting, it's only expanding.

But what are the brave new worlds that we're about to encounter when it comes to healthcare fraud prosecutions from your investigative background and experience?

Yeah, I think moving forward, you're going to see more AI-enhanced investigation.

You're going to see more investigations initiated based on data analytics.

That's, you know, that's something that's already happening and it's going to continue happening.

But I think what you're also going to see is investigations into fraud schemes that are AI-enhanced and fraud schemes that are using big data.

The, I think the, the… Listen, the motive for healthcare fraud is not going to change, but how it's committed is, is going to change.

And we've already seen it grow into an international commodity where, you know, one cell is, is off in another country and insulated from, from other cells of the, of the scheme.

It, it's going to become even more diverse like that and, and set apart in different countries, different locations and you know, like I said, I think I think AI is going to, you know, be used to, to help the schemes.

Some of the schemes you're going to see going forward, you know, any of the schemes where there's, you know, you mentioned the, the cancer doctor, you know, who was billing high reimbursement codes.

You know, any high reimbursement codes that, that can be billed a lot, those are going to be exploited by fraudsters.

You know, we've seen it with the compound medicine.

We've seen it with wound care, genetic testing, and, you know, listen, there's… Soon as, soon as the government finds the next thing, the fraudsters will find, you know, will, will move on and find, find that next high reimbursable code

By my count, you've served in the FBI under five presidents.

Every administration says healthcare fraud is a priority, at least in my lifetime and in my career.

But does this commitment actually vary with political leaderships?

Did you ever experience the deprioritization or the ebbing and flowing of healthcare investigations among an administration, a new administration coming in that by all accounts has the, the authority and the prerogative, as our system is set up, to prioritize and deprioritize various aspects of criminal law enforcement at the federal level?

Yeah.

I have to say that I never experienced the kind of deprioritization or the, the de-emphasis of healthcare fraud since I've been involved in it.

I think very early in my career, healthcare fraud was not something that many people wanted to work.

You know, the emphasis or the, the higher level desire was there, but from the, the case agent and the line AUSA, people didn't want to work it because you did not have the tools able to review all of those billing claims.

So you were sitting at your desk going through all of those billing claims and creating spreadsheets of that on your own, where now there's, there's AI and other tools that can do that, that type of work.

So it can be done and, and you're not kind of chained to your desk doing healthcare fraud, which is what it used to be back in the, you know, the late '90s.

You know, if you were a healthcare fraud investigator, you were chained to your desk, you know, going through claims and, and data.

Perfect job for a mathematician, right, Laurie?

Yeah, yeah, but, boy, it sounds, it sounds awful boring though, right?

Yeah.

But I I, I think, I think every administration…

And listen, the FBI has traditionally at least been somewhat insulated from political, you know, changes.

You know, we've seen some, some changes with that more recently.

But I think every administration realizes that healthcare fraud is a huge problem that the US government spends a ton of money on healthcare fraud.

So, a, a good way to save the US government some money is to throw more money at healthcare fraud investigators.

So in episode 86, we explored the story of Stephen Keller and how political pressure distorted a prosecution.

In your time at FBI, did you ever witness anything similar, cases that were influenced by considerations beyond the evidence, perhaps political influences that that, that had the propensity to impact the integrity of an investigation?

No, I never experienced that.

How do career agents and supervisors insulate themselves from these political winds?

Are there any institutional safeguards that the public doesn't see?

Because what we hear about in the news these days is a steady stream of information that would cause even the le- least skeptical among us to start scratching their head, to start thinking to themselves, "How possibly could this system have integrity?"

You were in there for a very long time.

You dedicated your career to it, a very distinguished and accomplished career.

How do you reinforce the general public or reassure the general public that what's going on in FBI squad rooms across the country is not in somewhat, some ways what the media wants us to believe is actually happening, that the political process and everything is essentially being weaponized against us.

Yeah.

So, a little caveat, right?

I've been retired three years now, so, you know, current administration wasn't the administration when, when I left.

So I do understand that it's possible things, things have changed since I was there.

But given that, what I can say is, is, you know, the folks I worked with, with, in the FBI, they had the…

When you-- Let me, let me put it this way.

If you were to ask me, what type of people work for the FBI?

My answer would be exactly the type of people who you would want to work for the FBI.

They have integrity.

They have motivation.

They're hard chargers.

They're self-starters.

It is people who are not going to be influenced by things they shouldn't be influenced by.

It's, it's people who are going to raise ethical issues and bring them to their supervisors or, or the management and, and flag issues that need to be flagged but get the job done.

And, and I believe the FBI is, is full of those type of people, the people who, who are doing the work because they believe in the mission, because they believe in the you know, the meaningful work that they're doing.

Again, things may have changed since I've left, but, but there's always been, I believe, some pressure in, you know, in the top leadership ranks.

But that never filtered down to the to the squad room.

That's, that's really reassuring to hear.

Obviously, you left the FBI in April of 2023.

You first founded Laurie Allen Consulting and Investigations.

Then in July 2025, you joined Withum as a principal, leading their investigations and corporate intelligence practice.

You also teach as an adjunct professor at Monmouth University, covering ethics, criminal law, defensive policing, and investigative techniques.

You, you draw on this network of former FBI agents, law enforcement contacts.

You volunteer.

You're out there in the community.

Several of your Withum colleagues have appeared on this podcast.

You're far from the only former federal agent to transition into private practice.

But what's the one thing you wish defense lawyers, compliance officers, members of boards of directors understood about how investigators think that might change how they approach their own work.

Something that you can draw on from your own transition from government to private practice.

An anecdote, if you will.

Yeah.

I think you know what compliance professionals and, and, you know, board members need to, need to realize is you know, everybody has a compliance program.

You know, the fact that you have a compliance program, that's, that's great.

That's, that's minimal, right?

That means you're breathing.

… Right?

That's, that, that's the bare minimum.

And I think if I were to ask a board member or a CEO, like, like, "How do you know fraud's not occurring in your organization right now?" You know, they, they would start talking about their compliance program.

And, and while that might, you know, be, be all well and good, there needs to be more because fraud occurs despite compliance programs, right?

You, you need to be testing your compliance program.

You know, I think about the TSA and how they test TSA agents, right?

They put, put fake bombs through the, the scanners at the airport or, or, or guns or ammunition or, or some type of item that's not supposed to go on an airplane.

Like, are you testing your compliance program?

Are you, are you sending the fake bomb into your compliance program?

Because if not, I think you really don't know if fraud is occurring in your organization.

Wow.

Well, that, that is a terrific stopping point.

Laurie Allen, I think we could chat all day about some really interesting topics and anecdotes from your time with government, 26 years as a supervisory FBI agency agent, retiring from that agency and moving on to the private sector.

I think there's a reason why we work together, Laurie, and that's because these are some great practical pieces of guidance.

That's all the time that we have on this episode of "The Presumption of Innocence." Until next time, I'm your host, Matt Adams.

We'll see you then.

Take care.