The entity made 4 ACH debits just under $10,000 within 24 hours.

What happened. Alert 45ed44c2-722b-4103-b96a-f95fe6c2232b fired on entity enti_sim_nort_c2pb9mmf0 (Northwind Payroll, ACH program) for a structuring pattern detector. The alert summary states 4 ACH debits just under $10,000 within 24 hours; the underlying signal detail states 3 debits just under $10,000 in 24h. The alert carries a hard signal, auto-hold, score 45, and band hold. What the evidence shows. One transfer record is provided in the evidence: acht_sim_nort_3odudhhe3s0, an outgoing ACH debit of $9,203.67, status SETTLED, created 2026-07-29T12:02:28.000Z, counterparty country unknown. This transfer carries the same score (45, band hold) and lists the structuring.pattern signal (weight 35, hard) alongside an amount.gt_3x_median signal (weight 10). No other transfer records for this entity are included in the evidence, so the full set of 3 or 4 near-threshold debits referenced in the summary and signal detail cannot be verified from what was provided. The entity is verified, not flagged high risk, not PEP, has no open review reasons, and was last screened 2026-07-17T10:05:19.000Z. Program-level KRIs show ach_overall_return_rate, ach_unauthorized_return_rate, sanctioned_country_transfers, frozen_accounts, and overdraft_events all within normal range. pep_flagged_entities (1 of 33) and high_risk_entity_share (0.061) are at watch level, and manual_review_aging_hours (1434.67 hours, n=3) is in breach, but none of these KRIs are tied specifically to this entity or this transfer. What was checked. Entity verification status, PEP and high-risk flags, and screening recency were checked and show no independent concern. The single transfer's status, amount, and counterparty were checked; the transfer settled and the counterparty country is unknown. The alert's stated count of 4 debits was checked against the signal detail (3 debits) and against the transfer evidence supplied (1 transfer); the counts do not match and the additional debits are not present in the evidence given. Program KRIs were checked for corroborating strain; none are specific to this entity, though manual_review_aging_hours is in breach at the program level. What is recommended. Hold. The alert carries a hard structuring signal and auto-hold, and the evidence does not include the full set of transfers needed to confirm or rule out a structuring pattern (only 1 of the 3-4 debits referenced is documented). A person should review the entity's full ACH debit history over the 24-hour window before any further debits settle or funds move, and reconcile the discrepancy between the alert summary (4 debits) and the signal detail (3 debits).

{
  "n": 390,
  "band": "hold",
  "skoor": 45,
  "signals": [
    {
      "code": "structuring.pattern",
      "hard": true,
      "detail": "3 debits just under $10,000 in 24h",
      "weight": 35
    }
  ],
  "autoHold": true,
  "routeReason": "hard signal"
}