“Fourteen million dollars shifted through eleven different shell accounts since last spring,” Michael said.

“Every single transfer cleared through a bank in the Cayman Islands.”

“You needed the internal master ledgers,” Richard said.

Michael’s voice dropped noticeably.

“We knew the second set of books was sitting on an air-gapped server in his home study, but we couldn’t get a warrant from a judge without physical proof of the double-entry system.”

Richard rubbed the faded scar on his thumb as his mind worked through the tactical picture.

“He’s not just looking at civil penalties,” Richard said.