The entity made 3 ACH debits just under $10,000 within 24 hours.

What happened. The entity Northwind Payroll (enti_sim_nort_c2pb9mmf0) was flagged by the structuring_pattern detector for making ACH debits just under $10,000 within a 24-hour window. The alert summary states 3 such debits; the underlying signal detail states 2 debits just under $10,000 in 24h. Only one transfer record was provided in the evidence: acht_sim_nort_5o7ga0n23rl, an outgoing ACH debit of $9,401.23, settled, created 2026-09-07T21:50:56.000Z, counterparty cpty_sim_nort_1i029r3515d with country unknown. What the evidence shows. The alert carries a skoor of 45, band hold, with a hard signal (structuring.pattern, weight 35) that triggered autoHold and routing on hard signal. The single transfer shown carries the same skoor and band, plus an additional amount.gt_3x_median signal (+10). The entity is a verified US business, not flagged high risk, not PEP, with no review reasons and screening current as of 2026-07-17. Program-level KRIs show most metrics in the ok/watch range; manual_review_aging_hours is in breach (1434.69 hours, n=10), and hold_aging_hours, pep_flagged_entities, and high_risk_entity_share are in watch. There are no prior dispositions for this entity. What was checked. Alert evidence, the single linked transfer record, the entity profile, program KRIs, and prior dispositions. Only one of the two-to-three debits referenced in the alert narrative and signal detail is included in the evidence provided; the other debit(s) are not present in this record, and the counterparty's country is unknown. What is recommended. Hold. The alert carries a hard structuring signal with autoHold already applied, and the entity's transaction pattern (multiple debits just under the $10,000 reporting threshold) has not been explained by any information in this record. A person should review the entity's full ACH debit history over the relevant 24-hour window to confirm the count and amounts of near-threshold debits before any further funds move under this entity. The counterparty's unknown country and the discrepancy between the alert's stated count (3) and the signal detail's count (2) should also be resolved before disposition.

{
  "n": 1247,
  "band": "hold",
  "skoor": 45,
  "signals": [
    {
      "code": "structuring.pattern",
      "hard": true,
      "detail": "2 debits just under $10,000 in 24h",
      "weight": 35
    }
  ],
  "autoHold": true,
  "routeReason": "hard signal"
}