43 administrative subpoenas: For a specific discussion of how Brill and Holdren used administrative subpoenas, see USA v. Berkman, Document 1004, Febru- ary 8, 2017, at 216. For a broader discussion of administrative subpoena use, see, for example, David Kravets, “We Don’t Need No Stinking Warrant,” Wired, August 28, 2012.

43 paulca@rocketmail.com: Ibid. at 277–78.

44 a private, secure email program: Server73 addresses appeared to be confined to an upper layer of Le Roux’s organization, and thus provided a handy way to distinguish between his thousands of employees. Among the addresses in- vestigators located were ron@server73.net, michaelross@server73.net, allen@ server73.net, stevelebaron@server73.net, and dimov@server73.net, all of which proved to be aliases for important members of Le Roux’s organization. And of course, pleroux@server73.net.

44 more than twenty separate email accounts: USA v. Berkman, Document 1013, February 22, 2017, at 1917.

44 under the names Levi Kugel and Alon Berkman: USA v. Berkman, Document 948, April 3, 2017, at 17.

45 “Please stop sending so many emails”: USA v. Berkman, Document 952-16, April 3, 2017.

45 a July 2007 article: Jeffrey Young and Kevin Bogardus, “Even John Q. Public Can Hire K Street—if He Has the Cash,” The Hill, July 3, 2007.

46 analyst finally unearthed a photo: Interview with Kent Bailey.

47 obtained a conviction: Amy Forliti, “Minn. Online Prescription Drug Seller Faces up to Life in Prison for Scheme,” Associated Press, November 14, 2015.

47 the Consumer Protection Branch: For a general description of CPB, the only civil division of the Department of Justice that handles civil and criminal pros- ecutions, see justice.gov/civil/consumer-protection-branch.

47 file for legal records from foreign governments: These requests, conducted through what are called Mutual Legal Assistance Treaties, or MLATs, are time-consuming to write and execute. Often they must be drafted by investiga- tors, subjected to legal review by attorneys at the Department of Justice, and translated into a foreign language. Any response must then be translated back into English. In the Le Roux case, investigators had a leg up due to Kimberly Brill’s legal background.

47 FinCEN: fincen.gov/what-we-do

47 a program called Fedwire: For a general description of Fedwire see “Fedwire Funds Services,” Board of Governors of the Federal Reserve System, federal reserve.gov/paymentsystems/fedfunds_about.htm.

48 $250 million a year: Estimates of Le Roux’s RX Limited revenues were diffi- cult if not impossible for investigators to establish accurately, given the vol- ume and variability of bank transfers they were seeing between the United States and Hong Kong, among other locations, and the layers he used to ob- scure his proceeds. According to Bailey, one IRS estimate for Le Roux’s annual revenues was $400 million. Between 2005 and 2010, Kimberly Brill calculated