First transfer to a new counterparty, $14,400.00, above the program's 95th percentile.

What happened. Alert 75e7d69e flagged an outgoing ACH transfer of $14,400.00 from Lantern Lending program to a first-time counterparty, cpty_sim_lant_1gour80xeja, located in NG. The detector first_time_counterparty_large fired because the amount exceeds the program's 95th percentile ($2,497.31). The transfer settled on 2026-09-05, prior to alert review. What the evidence shows. The transfer scored 60 (band review) with four contributing signals: counterparty.first_time (+10), counterparty.first_time_and_large (+15), amount.gt_10x_median (+20), and geo.outside_declared_countries (+15). The program's declared countries are US only, but the counterparty is in NG, so this transfer falls outside the program's declared geographic scope. The originating entity, Alder Co 30, is BUSINESS-verified, not high-risk, not PEP, and was screened 2026-09-02 with no review reasons on file. Program KRIs show sanctioned_country_transfers at 0 (n=592, ok) and stale_screening_share at 0 (n=33, ok), so this does not appear tied to a broader sanctions or screening failure at the program level. However, manual_review_aging_hours is in breach (1433.56 hrs, n=6) and hold_aging_hours is at watch (1406.44 hrs, n=2), indicating reviews and holds in this program are running slow generally. What was checked. Reviewed the alert evidence, transfer record, entity verification status, program KRIs, and prior dispositions. No prior dispositions exist for this alert or entity. The transfer status is SETTLED with no return code, so funds have already moved; there is no held transfer to release. What is recommended. Because the transfer already settled, no hold or release action applies. The combination of first-time counterparty, amount over 10x median, and a transfer to a country outside the program's declared list (NG vs. declared US) is a pattern that a person should examine, particularly given the program-level breach on manual_review_aging_hours. This should be escalated for review of whether the program's declared-country scope needs updating or whether this counterparty requires further screening, rather than closed outright.

{
  "n": 673,
  "band": "review",
  "skoor": 60,
  "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 (249731)",
      "weight": 15
    }
  ],
  "routeReason": "detector always reviewed"
}