Alert · reviewed · open
Activity on an entity flagged by screening (PEP status potential).
- Detector
- sanctions_or_pep
- Severity
- high
- Program
- Northwind Payroll (simulated)
- Subject
- entity enti_sim_nort_sr7cv2o3u
- Transfer
- acht_sim_nort_1qtqw7awqr · $2,139.27 · ach outgoing
- Skoor at alert
- 25 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. A sanctions/PEP detector flagged entity enti_sim_nort_sr7cv2o3u for a potential PEP match, triggered by activity on ACH outgoing debit acht_sim_nort_1qtqw7awqr for $2139.27 USD under the Northwind Payroll program. The alert routed to review because the detector always routes to review, not because of score severity.
What the evidence shows. The alert-level skoor is 25, banded clear, with hard_signal false. The only contributing signal is entity.pep_potential (+15). The transfer itself also scored 25, clear band, with signals entity.pep_potential(+15) and counterparty.first_time(+10); it settled with no return code. The entity record shows verification VERIFIED, high_risk false, review reasons none, and a screening date of 2026-06-25, about three months before the transfer. Country is US. The entity name "Potential Pep 0" and simulated identifiers indicate this is test data.
What was checked. Alert evidence, linked transfer detail, entity screening record, and program KRIs. Program KRIs show pep_flagged_entities at 1 of 33 (watch) and high_risk_entity_share at 0.06 (watch), both within a single-digit count that does not indicate a program-wide pattern. manual_review_aging_hours shows a breach but is based on n=1, an unmeasured-scale sample, so it cannot be tied to this alert. No sanctioned_country_transfers, no ach_unauthorized_return_rate, and reserve_coverage_ratio is well above 1. No prior dispositions exist for this alert.
What is recommended. Close the alert. The entity is verified with no open review reasons, the PEP match is marked potential (unconfirmed) rather than confirmed, the transfer settled cleanly with no return, and the alert score sits in the clear band with no hard signal. The transfer was not placed on hold, so no release action applies. A person should confirm the PEP screening outcome at the next periodic review given the entity remains flagged as pep_potential in the underlying record.
- Recommendation
- close
- Confidence
- 0.68
- Model
- claude-sonnet-5
- Drafted
- 2026-09-17 19:30Z
- Rationale
- skoor 25 in clear band, hard_signal false, single contributing signal (entity.pep_potential)
- entity verification status is VERIFIED with review reasons none and a recent screening date
- transfer acht_sim_nort_1qtqw7awqr settled with return code none, no funds currently held so release is not applicable
- program KRIs show pep_flagged_entities and high_risk_entity_share at watch level but with small counts (1 and ~2 of 33), not indicating a broader pattern
- manual_review_aging_hours breach is based on n=1 and cannot be attributed to this specific alert
- no prior dispositions exist to inform escalation history
Evidence
{
"n": 200,
"band": "clear",
"skoor": 25,
"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 | |
| counterparty.first_time | +10 | first transfer with this counterparty |
Decision
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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.