The entity made 4 ACH debits just under $10,000 within 24 hours.

What happened. The structuring_pattern detector fired on entity enti_sim_harb_kytao1m3ti (Harbor Marketplace Payouts) after the entity made 4 ACH debits just under $10,000 within 24 hours. The alert carries a skoor of 55 (band hold) with a hard signal, and routed to review as 'reviewed' due to the hard signal. One transfer of the group, acht_sim_harb_323d3hwi9k0 for $9,526.72, is shown as SETTLED. What the evidence shows. The evidence includes one transfer detail (acht_sim_harb_323d3hwi9k0, $9,526.72, SETTLED, no return code) that is representative of the pattern described (3 debits just under $10,000 in 24h per the signal detail, though the summary states 4). The transfer-level skoor is also 55/hold with signals amount.gt_10x_median(+20) and structuring.pattern(+35,hard). The entity is BUSINESS, VERIFIED, not high risk, not PEP, last screened 2026-07-15, with no review reasons on file. The transfer in evidence has already settled, so there is no held transfer to release. Program KRIs show ach_unauthorized_return_rate and manual_review_aging_hours in breach status, and hold_aging_hours, pep_flagged_entities, and high_risk_entity_share in watch status, but none of these are tied directly to this entity or this alert's transfers. What was checked. Checked the alert summary and evidence signals, the single transfer record provided and its skoor/signal breakdown, the entity's verification and risk profile, the program's declared volume and KRIs, and prior dispositions. Prior dispositions: none. Only one of the referenced transfers (of the 3-4 described) is present in the evidence, so the full set of transfers making up the structuring pattern cannot be independently confirmed from this context. What is recommended. Hold. A hard signal (structuring.pattern) fired with a settled transfer just under the $10,000 reporting threshold, repeated multiple times in 24 hours, on a verified but otherwise unremarkable business entity. This pattern needs a person to review the full transaction set, confirm the count and amounts of qualifying debits, and determine whether this meets internal structuring/CTR-avoidance criteria before further transfers from this entity are permitted to proceed without scrutiny. The transfer shown has already settled, so no release action applies to it, but the entity's pattern warrants review before any further transactions are cleared.

{
  "n": 1927,
  "band": "hold",
  "skoor": 55,
  "signals": [
    {
      "code": "structuring.pattern",
      "hard": true,
      "detail": "3 debits just under $10,000 in 24h",
      "weight": 35
    }
  ],
  "autoHold": true,
  "routeReason": "hard signal"
}