Alert · reviewed · open
A single $9,664.70 ACH debit sits just under the $10,000 reporting threshold with no 24-hour pattern around it.
- Detector
- amount_just_below_threshold
- Severity
- low
- Program
- Harbor Marketplace Payouts (simulated)
- Subject
- transfer acht_sim_harb_2an17oui9k3
- Transfer
- acht_sim_harb_2an17oui9k3 · $9,664.70 · 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. A single outgoing ACH debit of $9,664.70 from Harbor Marketplace Payouts to counterparty cpty_sim_harb_9a1a9pcv46d was flagged by the amount_just_below_threshold detector because the amount sits just under the $10,000 reporting threshold. The alert was opened 2026-09-17 for a transfer created and settled 2026-07-26.
What the evidence shows. The transfer status is SETTLED with no return code. The transfer-level skoor is 20, band clear, with one contributing signal, amount.gt_10x_median(+20), confidence 0.835 on n=505. The evidence block confirms the amount ($966,470 cents) falls between the configured min ($900,000) and max ($999,999) threshold band. The summary states no 24-hour pattern of similar transfers around this one. The entity, Harbor Marketplace Payouts, is VERIFIED, not high risk, not PEP, last screened 2026-07-15, country US. Counterparty country is unknown, and there is no other adverse information on the counterparty in the record. No prior dispositions exist for this entity or transfer.
What was checked. Transfer status and return code, transfer skoor and band, entity verification and risk flags, presence of a 24-hour clustering pattern, and program-level KRIs. Program KRIs are mostly within normal range: frozen_accounts, overdraft_events, ach return rates, sanctioned_country_transfers, stale_screening_share, and reserve_coverage_ratio all show 'ok'. Two KRIs show 'watch' (pep_flagged_entities 1/30, high_risk_entity_share 0.067), and one shows 'breach' (manual_review_aging_hours=1438 hours, n=2), but none of these are tied to this specific transfer or entity in the evidence provided, and the n counts are thin.
What is recommended. Close the alert. The transfer is a single, already-settled ACH debit with no return, no clustering pattern, a clear-band score, and a verified low-risk entity. There is no basis in the evidence for holding funds since the transfer has already settled, and no pattern here suggests a broader typology beyond this one transaction. The program-level manual_review_aging_hours breach is noted but is based on n=2 and not connected to this alert's subject; it should be tracked separately at the program level rather than driving this disposition.
- Recommendation
- close
- Confidence
- 0.80
- Model
- claude-sonnet-5
- Drafted
- 2026-09-17 19:30Z
- Rationale
- Transfer status is SETTLED with no return code, so there is no pending movement to hold or release.
- Transfer skoor is 20 in the clear band with only one contributing signal (amount.gt_10x_median), and confidence is 0.835 on a reasonably sized sample (n=505).
- Entity is VERIFIED, not high risk, not PEP, and was screened within the last two months relative to alert open date.
- Summary explicitly states no 24-hour pattern around the transfer, arguing against a structuring interpretation of the near-threshold amount.
- Program KRIs are largely 'ok'; the two 'watch' and one 'breach' KRIs are program-wide with small n and are not linked in the evidence to this specific transfer or entity, so they do not by themselves justify escalation of this alert.
- No prior dispositions exist, so there is no history of repeated near-threshold activity on this entity to escalate against.
Evidence
{
"n": 505,
"band": "clear",
"skoor": 20,
"typology": "amount_just_below_threshold",
"confidence": 0.835,
"thresholds": {
"maxCents": "999999",
"minCents": "900000"
},
"amountCents": "966470",
"routeReason": "detector not auto-closable"
}
Skoor signals
| Signal | Weight | Hard | Detail |
|---|---|---|---|
| amount.gt_10x_median | +20 | amount > 10× program median (42860) |
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.
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