Transaction Risk Skoor 60 (hold band) on a $2,400.00 ach transfer: entity.denied.

What happened. Alert 464f1205-cf3b-4427-b1ce-d0a967f9a1a5 fired on a $2,400.00 outgoing ACH transfer (acht_sim_lant_619wbdb5ej7) under program Lantern Lending. The transaction risk skoor was 60, placing it in the hold band, driven by a single hard signal: entity.denied (weight 60). The transfer's status is SETTLED, with no return code recorded. What the evidence shows. The originating entity (enti_sim_lant_9312rknkcja, "Denied Origin 3") carries a verification status of DENIED with review reason sanctions_match, last screened 2026-06-24. The alert's routeReason is "hard signal" and autoHold is true, meaning the system intended to hold this transfer, but the transfer record shows it settled on 2026-08-31, and the alert was not opened until 2026-09-17 — after settlement. Program KRIs show verification_denial_rate at 3.0% (ok) and stale_screening_share at 0% (ok), so this does not appear to be a screening-freshness problem, but manual_review_aging_hours is in breach (1433.6 hours, n=6) and hold_aging_hours is in watch (1406.4 hours, n=2), consistent with a delay between alert generation and review that allowed this settlement to go unaddressed. What was checked. Reviewed the alert evidence, transfer record, entity verification record, program KRIs, and prior dispositions. No prior dispositions exist for this alert. Counterparty country is listed as unknown. No return code is present on the settled transfer. The confidence field on the alert itself is 0.7. What is recommended. This transfer is already SETTLED, so it cannot be released or held; funds have moved. Given a hard sanctions_match denial on the originating entity paired with a completed $2,400.00 transfer, and program-level indicators of aging review backlog (manual_review_aging_hours breach, hold_aging_hours watch), this should be escalated for a person to determine whether the settlement occurred despite the hold logic, whether other transfers from this entity or program settled under the same gap, and whether a post-settlement compliance action (e.g., filing, entity offboarding) is required.

{
  "n": 613,
  "band": "hold",
  "skoor": 60,
  "signals": [
    {
      "code": "entity.denied",
      "hard": true,
      "detail": "entity verification DENIED",
      "weight": 60
    }
  ],
  "autoHold": true,
  "confidence": 0.7,
  "routeReason": "hard signal"
}