A $2,400.00 ach transfer was initiated for an entity whose verification was denied.

What happened. A $2,400.00 outgoing ACH transfer (acht_sim_harb_6mf9ak9b9ki) was initiated under the Harbor Marketplace Payouts program for entity enti_sim_harb_130qwgg53wz, whose verification status is DENIED. The transfer has already settled. What the evidence shows. The entity record shows verification DENIED, high risk true, and review reasons including sanctions_match, last screened 2026-06-24. The transfer-level skoor is 90 (band hold, n=954, confidence 0.7) driven by a hard signal entity.denied (+60), entity.high_risk (+20), and amount.gt_3x_median (+10), with autoHold true and routeReason 'hard signal'. Despite the hold band, the transfer status is SETTLED with no return code, meaning funds already moved before or without an effective hold being applied. Program KRIs show verification_denial_rate at 3.3% (ok, n=30), high_risk_entity_share at 6.7% (watch), pep_flagged_entities=1 (watch), manual_review_aging_hours at 1438 hours (breach), and ach_unauthorized_return_rate at 1.24% (breach). No prior dispositions exist for this alert or entity. What was checked. Alert evidence, transfer record, entity verification record, program KRIs, and prior dispositions were reviewed. No counterparty country or additional transfer history for this entity was available in the context provided. What is recommended. This transfer cannot be released because it is not in a held state; it has already settled. The combination of a denied-verification entity with a sanctions_match review reason and a settled ACH credit warrants escalation for a person to assess whether this indicates a broader control gap (hold not applied before settlement) and whether related transfers from this entity or program need review. The two KRI breaches (manual_review_aging_hours, ach_unauthorized_return_rate) support looking beyond this single alert.

{
  "n": 954,
  "band": "hold",
  "skoor": 90,
  "signals": [
    {
      "code": "entity.denied",
      "hard": true,
      "detail": "entity verification DENIED",
      "weight": 60
    }
  ],
  "autoHold": true,
  "routeReason": "hard signal"
}