Transaction Risk Skoor 45 (hold band) on a $9,234.82 ach transfer: amount.gt_3x_median, structuring.pattern.

What happened. An automated risk detector (skoor_hold, severity high) flagged outgoing ACH transfer acht_sim_lant_90piwgzoej4 for $9,234.82 from entity Lantern Lending. The transfer scored 45, placing it in the hold band, and triggered a hard signal for structuring. The transfer's status is SETTLED as of the alert data. What the evidence shows. The evidence lists two signals: amount.gt_3x_median (transfer amount exceeds 3x the program median of $1,238.99, weight 10) and structuring.pattern (three debits just under $10,000 within 24 hours, weight 35, flagged as a hard signal). The routeReason confirms routing to review was driven by the hard signal. Confidence on the skoor evidence is 1. The transfer itself is already SETTLED with no return code, meaning funds have already moved and there is no pending transfer to hold. The counterparty's country is unknown. The entity Lantern Lending is VERIFIED, not high risk, not PEP, with no review reasons and screening current as of 2026-07-23. Program KRIs show manual_review_aging_hours in breach (1433.57 hours, n=8) and hold_aging_hours in watch status (1406.45 hours, n=3), and pep_flagged_entities in watch status (1 of 33). Other KRIs (return rates, reserve coverage, velocity vs declared, concentration) are within normal range. There are no prior dispositions on this alert. What was checked. Reviewed the alert summary, evidence signals and weights, transfer status and settlement details, program declared volume and KRIs, entity verification and screening status, and prior disposition history. No additional transactions beyond the three referenced in the structuring signal detail are included in the evidence. What is recommended. The transfer is already settled, so there are no funds to hold or release on this specific transaction. However, the hard signal for structuring (three debits just under the $10,000 reporting threshold within 24 hours) is a pattern indicator, not resolved by this transfer's settlement alone, and the evidence does not include the other two debits referenced in the pattern. This warrants escalation for a person to review the full set of transactions tied to this counterparty and entity, assess structuring/SAR filing obligations, and determine whether related transfers or the counterparty relationship should be restricted going forward.

{
  "n": 761,
  "band": "hold",
  "skoor": 45,
  "signals": [
    {
      "code": "amount.gt_3x_median",
      "detail": "amount > 3× program median (123899)",
      "weight": 10
    },
    {
      "code": "structuring.pattern",
      "hard": true,
      "detail": "3 debits just under $10,000 in 24h",
      "weight": 35
    }
  ],
  "autoHold": true,
  "confidence": 1,
  "routeReason": "hard signal"
}