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_by83dsnvdag · $2,307.96 · ach outgoing
- Skoor at alert
- 25 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. Sanctions/PEP detector fired on entity enti_sim_lant_866sn4vcjd (Lantern Lending, ACH program) following an outgoing ACH debit of $2,307.96 on 2026-08-03 to first-time counterparty cpty_sim_lant_6wkj1ys5dag (country unknown). The transfer settled with no return code. The detector routes to review by default regardless of score.
What the evidence shows. The transfer-level skoor is 25, in the clear band, with hard_signal false. The only signals present are entity.pep_potential (+15) and counterparty.first_time (+10), both low-weight contextual flags rather than confirmed derogatory findings. The entity record shows verification status VERIFIED, high_risk=false, and review reasons: none, with a last screening date of 2026-06-25. Program KRIs show pep_flagged_entities at 1/33 (watch) and stale_screening_share at 6.1% (ok), neither specific to this entity. manual_review_aging_hours is in breach at the program level (1433.5h, n=3), which reflects review-queue timing rather than this alert's substance. No sanctioned-country transfers, no unauthorized/administrative returns, and ach_overall_return_rate is 0.
What was checked. Alert evidence and skoor/band; transfer details (status, amount, rail, counterparty, return code); entity verification status, high-risk flag, review reasons, and last screening date; program KRIs for PEP-related and screening-related metrics; prior dispositions (none on record).
What is recommended. Close the alert. The entity is a potential PEP match only, has passed verification, carries no high-risk flag, and has no open review reasons. The associated transfer scored clear with no hard signal and settled without incident. Nothing in the evidence indicates a confirmed PEP match, adverse finding, or fund-movement concern requiring a hold. The program-level manual_review_aging_hours breach is noted for operational awareness but does not change the disposition of this specific alert.
- Recommendation
- close
- Confidence
- 0.72
- Model
- claude-sonnet-5
- Drafted
- 2026-09-17 19:31Z
- Rationale
- Transfer skoor 25 falls in the clear band with hard_signal false.
- Entity is VERIFIED, high_risk=false, and has no listed review reasons despite pep_potential flag.
- Transfer status is SETTLED with return code none; no counterparty sanctions or country flags triggered.
- No prior dispositions exist to suggest a repeat or escalating pattern for this entity.
- Program KRIs relevant to PEP/screening (pep_flagged_entities, stale_screening_share, high_risk_entity_share, verification_denial_rate) are all in 'ok' or low 'watch' state, not indicating a systemic issue tied to this alert.
- Because the transfer already settled, 'release' does not apply; there is no held transfer to release.
Evidence
{
"n": 281,
"band": "clear",
"skoor": 25,
"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 | |
| counterparty.first_time | +10 | first transfer with this counterparty |
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.