I used to do anti-money laundering. There is a rules engine that alerts based upon any number of factors. I am unsure of what triggered this alert but a lot of cash moving across several accounts would probably be a trigger. Once you flag, it moves to the next level, and then the next level, etc.
He got snagged by laws that were not designed to snag him. Alan is right in this case and it should have been discretionary.
How do you know??? We have NO idea of what's involved yet?
Just HOW did he happen to hook up with THIS club?? Could it be that Mark Brener is a FRIEND?? Brener does TAXES for the IRS, I think. Something is not seen yet and IMHO it's way more than SEX.