Activity on an entity flagged by screening (PEP status no, high risk).

What happened. Alert 684755dc-42f9-4c23-9e23-d64a59d8f792 fired on entity enti_sim_harb_130qwgg53wz under the sanctions_or_pep detector, severity high, alert skoor 90 (band hold). The entity is tied to one ACH outgoing credit transfer, acht_sim_harb_1x9rcs6c9kf, for $2,400.00 USD, dated 2026-09-02, which has already settled. What the evidence shows. The entity record shows verification status DENIED, high_risk true, pep no, and review reasons listed as sanctions_match, last screened 2026-06-24. The alert-level evidence lists only entity.high_risk (+20) and reports hard_signal false, but the transfer-level skoor record for acht_sim_harb_1x9rcs6c9kf shows three signals: entity.denied (+60, hard), entity.high_risk (+20), and amount.gt_3x_median (+10), for a transfer skoor of 90 (band hold, n=1737, confidence 0.715). This is inconsistent with the alert's stated hard_signal=false. The transfer status is SETTLED, meaning the $2,400.00 already moved despite the entity carrying a DENIED verification status and a sanctions_match review reason. The counterparty country is unknown. Program-level KRIs show pep_flagged_entities and high_risk_entity_share at watch, manual_review_aging_hours and ach_unauthorized_return_rate at breach, but these are program-wide figures and not specific to this entity or transfer. What was checked. Reviewed the alert evidence block, the transfer record and its skoor/signals, the entity screening record, and program KRIs. No prior dispositions exist for this alert. The mismatch between the alert's hard_signal=false and the transfer's hard entity.denied signal was checked and could not be reconciled from the evidence provided. What is recommended. This is not a case where the flagged transfer is currently held; the $2,400.00 ACH credit already settled, so a release action does not apply and a simple close is not appropriate given the entity's DENIED verification and sanctions_match reason. The hard entity.denied signal on a settled outgoing transfer, combined with the discrepancy between alert-level and transfer-level hard-signal reporting, indicates this needs review by a person beyond this single alert, including checking whether other transfers moved for this same entity after the DENIED determination. Recommend escalation.

{
  "n": 1737,
  "band": "hold",
  "skoor": 90,
  "signals": [
    {
      "code": "entity.high_risk",
      "detail": "entity marked high risk by screening",
      "weight": 20
    }
  ],
  "autoHold": true,
  "routeReason": "detector always reviewed"
}