[toofy]

Dont really know enough about this to do anything other than wild speculation but Id lean towards something like: If a trade crosses a certain risk score threshold it would trigger some kind of preliminary investigation looking at limited information. If the preliminary investigation determines the trader has relationships with a company insider, its then added to the metrics and the risk score may ramp up to a level which would trigger a wider investigation.

But honestly, it’s much more likely that it was simply the timing of the trades and the earnings reports multiple times over a couple years raised some eyebrows.