Alert · reviewed · open
Activity on an entity flagged by screening (PEP status no, high risk).
- Detector
- sanctions_or_pep
- Severity
- high
- Program
- Northwind Payroll (simulated)
- Subject
- entity enti_sim_nort_91eod4q93y
- Transfer
- acht_sim_nort_qlu0zzx1e6 · $1,858.94 · ach outgoing
- Skoor at alert
- 20 clear
- Hard signal
- no
- Policy
- policy-v1
- Opened
- 2026-09-17 19:30Z
- Closed
- —
- Decision clock
- none · due — no clock
- Escalated
- —
Draft narrative
What happened. Alert bc4327fa-bd50-44fa-8610-5b0e49e558af fired on entity enti_sim_nort_91eod4q93y under the sanctions_or_pep detector after a $1,858.94 outgoing ACH credit (acht_sim_nort_qlu0zzx1e6) settled under the Northwind Payroll program on 2026-07-31. The detector routes to review on every trigger regardless of score.
What the evidence shows. The entity is a verified US business flagged high risk by screening but not PEP, with no review reasons listed and a last screening date of 2026-06-26. The only contributing signal is entity.high_risk (weight 20), producing a skoor of 20 in the clear band with hard_signal false. The transfer itself settled with no return code and the counterparty country is unknown but not flagged as sanctioned. Program-level KRIs show sanctioned_country_transfers at 0 (n=313) and ach_unauthorized_return_rate at 0, consistent with no adverse outcome tied to this transfer.
What was checked. Reviewed the alert score and band, the single contributing signal, entity verification and PEP status, transfer status and return code, and program KRIs including pep_flagged_entities (watch, 1/33), high_risk_entity_share (watch, 0.061), stale_screening_share (ok, 0), and manual_review_aging_hours (breach, 1434.67 hours). These KRIs are program-wide metrics, not specific to this entity or transfer, and no prior dispositions exist for this alert.
What is recommended. Close this alert. The evidence supports no immediate action on this specific transfer: entity is verified, not PEP, screening is current, transfer settled cleanly with no return, and the score sits in the clear band with only one low-weight signal. The manual_review_aging_hours breach and the two watch-level KRIs (pep_flagged_entities, high_risk_entity_share) are program-level conditions that a person should track separately; they do not point to a pattern specific to this alert or entity.
- Recommendation
- close
- Confidence
- 0.78
- Model
- claude-sonnet-5
- Drafted
- 2026-09-17 19:30Z
- Rationale
- Skoor 20, band clear, hard_signal false, single signal entity.high_risk with weight 20.
- Entity is VERIFIED, PEP no, no review reasons, last screened 2026-06-26 (33 days before transfer).
- Transfer status SETTLED, return code none, counterparty country unknown but not flagged sanctioned; program sanctioned_country_transfers=0 (n=313).
- Program KRIs pep_flagged_entities and high_risk_entity_share are at watch level but are program-wide, not entity-specific, and do not by themselves indicate a pattern tied to this alert.
- manual_review_aging_hours is in breach (1434.67 hours, n=3) but this measures review queue timing across the program, not evidence about this transaction or entity, so it does not change the disposition of this specific alert.
- No prior dispositions exist to indicate repeat activity on this entity.
Evidence
{
"n": 458,
"band": "clear",
"skoor": 20,
"signals": [
{
"code": "entity.high_risk",
"detail": "entity marked high risk by screening",
"weight": 20
}
],
"routeReason": "detector always reviewed"
}
Skoor signals
| Signal | Weight | Hard | Detail |
|---|---|---|---|
| entity.high_risk | +20 | entity marked high risk by screening | |
| returns.counterparty_prior_unauthorized | +40 | 1 prior unauthorized return(s) |
Decision
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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.