I am not sure you can start a crime investigation until there is an accusation of a crime. A failing audit isn’t enough.
Financial oversight groups should start an investigation but it probably shouldn’t be called criminal at this point. Just an oversight issue where they demand more info.
Accusation by whom ? Who would have standing to accuse before investigating?
Enforcement bodies start investigation for any reason and none, (see all the stuff FBI did during civil rights movement for example ) at best legal framework used is probable cause
Financial oversight groups should start an investigation but it probably shouldn’t be called criminal at this point. Just an oversight issue where they demand more info.