Alert · reviewed · open
Activity on an entity flagged by screening (PEP status potential).
- Detector
- sanctions_or_pep
- Severity
- high
- Program
- Lantern Lending (simulated)
- Subject
- entity enti_sim_lant_866sn4vcjd
- Transfer
- acht_sim_lant_8jptm9taeb7 · $894.92 · ach outgoing
- Skoor at alert
- 15 clear
- Hard signal
- no
- Policy
- policy-v1
- Opened
- 2026-09-17 19:31Z
- Closed
- —
- Decision clock
- none · due — no clock
- Escalated
- —
Draft narrative
What happened. Screening flagged entity enti_sim_lant_866sn4vcjd (Potential Pep 3) for a potential PEP match. The alert fired on an outgoing ACH debit of $894.92 USD (transfer acht_sim_lant_8jptm9taeb7) under program Lantern Lending, settled on 2026-09-09.
What the evidence shows. The alert score is 15, banded clear, with hard_signal false. The single contributing signal is entity.pep_potential (weight 15). The entity record shows verification status VERIFIED, high_risk false, review reasons none, and a last screening date of 2026-09-01, five business days before the transfer. The transfer itself carries the same clear-band score of 15 with no independent signals, is settled, and has no return code. Counterparty country is unknown but the transfer is domestic ACH under a US-only program.
What was checked. Reviewed the entity screening detail, transfer status and return code, program declared volume and country scope, and program KRIs. pep_flagged_entities sits at 1 of 33 entities (watch level, not breach). Other sanctions/PEP-relevant KRIs (sanctioned_country_transfers, stale_screening_share, high_risk_entity_share, verification_denial_rate) are all at ok. manual_review_aging_hours is in breach, but this reflects program-wide review queue timing, not evidence tied to this specific entity or transfer. No prior dispositions exist for this alert.
What is recommended. No signal in the entity or transfer record indicates the PEP match is confirmed or unresolved; the entity is verified, not marked high risk, and has no open review reasons. The transfer has already settled with no return, so there is no held transfer to act on. Recommend closing the alert. The transfer is not in a held state, so release does not apply.
- Recommendation
- close
- Confidence
- 0.62
- Model
- claude-sonnet-5
- Drafted
- 2026-09-17 19:32Z
- Rationale
- Alert score 15, band clear, hard_signal false, single low-weight signal (entity.pep_potential +15).
- Entity verified, high_risk false, review reasons none, screened 2026-09-01, within a week of the transfer.
- Transfer settled, no return code, transfer-level score also clear band 15 with n=719 confidence 1.
- Program KRI pep_flagged_entities is at watch (1/33), not breach; other sanctions/PEP KRIs are ok.
- manual_review_aging_hours breach is a program-wide queue metric, not specific evidence against this entity or transfer.
- No prior dispositions to inform pattern; evidence here is limited to a single low-score screening flag.
Evidence
{
"n": 719,
"band": "clear",
"skoor": 15,
"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 |
Decision
Sign in as an operator to decide. Operator sign-in →
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.