Alert · reviewed · open

First transfer to a new counterparty, $2,146.15, above the program's 95th percentile.

Detector: first_time_counterparty_large
Severity: medium
Program: Lantern Lending (simulated)
Subject: transfer acht_sim_lant_bk80s93lck1
Transfer: acht_sim_lant_bk80s93lck1 · $2,146.15 · ach outgoing
Skoor at alert: null unscored
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 first-time transfer of $2,146.15 to a new counterparty was flagged because the amount exceeds the program's 95th percentile ($1,734.75). What the evidence shows. The transfer acht_sim_lant_bk80s93lck1 is an outgoing ACH credit that has already settled, with no return code recorded. The only signals present are counterparty.first_time and counterparty.first_time_and_large, both driven by this being a new counterparty and the amount exceeding the p95 threshold. The transfer skoor is unscored (n=1, confidence null), and the hard signal flag is false. The counterparty's country is unknown, but no other risk signal is tied to it. The originating entity, Lantern Lending, is a verified business, not high risk, not PEP, with no review reasons and a screening date of 2026-05-20. There are no prior dispositions on this entity or counterparty. What was checked. Reviewed the alert evidence, the transfer record, the program's declared volume, the entity's verification and screening status, and prior disposition history. No additional signals, return codes, or review reasons were found beyond the two listed. What is recommended. The transfer has already settled and there is no hard signal, no entity risk flag, and no pattern across prior dispositions. The alert reflects a single first-time large transfer within a verified business's declared activity. No action is needed from a person before or after the fact; the alert can be closed.

Recommendation

Confidence

0.72

Model

claude-sonnet-5

Drafted

2026-09-17 19:30Z

Rationale

Transfer status is SETTLED with no return code, so no fund-hold action applies.
Hard signal is false and skoor is unscored, indicating no elevated automated risk determination.
Entity is VERIFIED, not high risk, not PEP, with no review reasons and a recent screening date.
No prior dispositions exist for this entity or counterparty, so no pattern of repeated first-time-large alerts is evident.
Counterparty country is unknown, which is a minor evidence gap, but no signal or entity flag ties this to elevated risk.

Evidence

{
  "n": 1,
  "band": "unscored",
  "skoor": null,
  "signals": [
    {
      "code": "counterparty.first_time",
      "detail": "first transfer with this counterparty",
      "weight": 10
    },
    {
      "code": "counterparty.first_time_and_large",
      "detail": "amount above the program p95 (173475)",
      "weight": 15
    }
  ],
  "routeReason": "detector always reviewed"
}

Skoor signals

Signal	Weight	Hard	Detail
counterparty.first_time	+10		first transfer with this counterparty

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.