Alert · reviewed · open

Activity on an entity flagged by screening (PEP status potential).

Detector: sanctions_or_pep
Severity: high
Program: Lantern Lending (simulated)
Subject: entity enti_sim_lant_866sn4vcjd
Transfer: acht_sim_lant_a9dk8j58d9s · $2,475.43 · ach outgoing
Skoor at alert: 15 clear
Hard signal: no
Policy: policy-v1
Opened: 2026-09-17 19:30Z
Closed: —
Decision clock: none · due — no clock
Escalated: —

Draft narrative

What happened. An alert fired on entity enti_sim_lant_866sn4vcjd under the sanctions_or_pep detector due to a potential PEP match. The associated transfer is an ACH outgoing credit of $2,475.43 USD, settled, with a counterparty of unknown country. What the evidence shows. The alert score is 15, in the clear band, with hard_signal false. The single contributing signal is entity.pep_potential (+15). The entity is a verified US person with high_risk false, review reasons listed as none, and screening last performed 2026-06-25. The transfer settled with no return code, indicating no ACH processing failure. Program KRIs show pep_flagged_entities at 1 of 33 (watch) and stale_screening_share at 6.1% (ok), verification_denial_rate at 3.0% (ok), and no sanctioned_country_transfers. manual_review_aging_hours is in breach (1433.5 hours, n=3), and hold_aging_hours is at watch (1406.4 hours, n=1), but these are program-level aging metrics not specific to this alert or entity. What was checked. Alert score and band, hard signal flag, entity verification status and risk flags, review reasons, screening recency, transfer settlement status and return code, counterparty country field, and program KRIs for PEP concentration, screening staleness, and denial rates. What is recommended. The transfer is already settled, so no funds are in a held state to release. The entity is verified, not flagged high risk, has no review reasons, and screening is not stale relative to program norms. The alert sits in the clear band with no hard signal. Nothing in this evidence requires a person to intervene on this specific alert. The program-level manual_review_aging_hours breach is a separate operational matter that should be tracked outside this alert, not as grounds to hold this settled transfer.

Recommendation

Confidence

0.72

Model

claude-sonnet-5

Drafted

2026-09-17 19:31Z

Rationale

Skoor 15 falls in the clear band with hard_signal false.
Entity is VERIFIED, high_risk false, review reasons none, screened 2026-06-25 (not flagged stale by program).
Transfer status is SETTLED with return code none, so there is no pending transfer to hold or release.
Program pep_flagged_entities and stale_screening_share are at watch/ok levels, not breach, and not tied to this specific entity beyond the single PEP signal already scored.
manual_review_aging_hours and hold_aging_hours show program-level aging concerns (breach/watch) but are not specific to this alert's entity or transfer and do not by themselves justify holding a settled transfer.
Confidence is moderate rather than high because counterparty country is unknown, which is a gap in the evidence, though it does not by itself change the clear-band scoring outcome.

Evidence

{
  "n": 263,
  "band": "clear",
  "skoor": 15,
  "signals": [
    {
      "code": "entity.pep_potential",
      "detail": "potential PEP match",
      "weight": 15
    }
  ],
  "routeReason": "detector always reviewed"
}

Skoor signals

Signal	Weight	Hard	Detail
entity.pep_potential	+15		potential PEP match

Decision

Dispositions

No disposition yet.

Actions

Freeze, request to program, and suspend need a second, distinct approver. Clear hold, cancel, and pause execute on the requester's approval. Executed through the bank's own API with the tenant's sandbox key; a dry run when there is none.

No actions requested.