The entity made 3 ACH debits just under $10,000 within 24 hours.

What happened. The alert flags entity enti_sim_harb_kytao1m3ti for a structuring pattern: the alert summary states 3 ACH debits just under $10,000 within 24 hours, while the underlying signal detail states 2 debits just under $10,000 in 24h. Only one transfer is included in the evidence, acht_sim_harb_a0znszfb9k9, an outgoing ACH debit of $9,711.80, settled, created 2026-07-27T06:15:35.000Z. The transfer skoor is 65, band hold, with a hard structuring.pattern signal weighted 35, alongside amount.gt_10x_median(+20) and velocity.sum_24h_gt_2x_daily_avg(+10). autoHold is true and routeReason is 'hard signal'. What the evidence shows. The entity is a verified US business, not flagged high risk, not PEP, with no review reasons and a screening date of 2026-07-15 that predates this transfer. Program KRIs are mostly in normal range (ach_overall_return_rate 1.53%, ach_unauthorized_return_rate 0%, reserve_coverage_ratio 5.62), but manual_review_aging_hours shows a breach at 1438 hours on n=2, and high_risk_entity_share and pep_flagged_entities are at watch level. Only one of the transactions referenced by the alert (either 2 or 3, depending on which field is read) is present in the evidence; the other 1-2 debits that would confirm or refute the pattern are not provided. What was checked. Reviewed the transfer record, entity verification and risk status, program KRIs, and prior dispositions. Prior dispositions: none. The alert's own summary and signal detail disagree on the count of near-threshold debits (3 vs 2), and only a single transfer is attached as evidence, so the full structuring pattern cannot be independently confirmed from what is provided. What is recommended. Hold. The structuring signal is hard and the transfer band is hold with autoHold true, which by policy requires a person to review before any further related funds move. A person should pull the complete set of ACH debits in the 24-hour window around 2026-07-27 to reconcile the 2-vs-3 count discrepancy and confirm whether the pattern meets the structuring definition, and should also note the manual_review_aging_hours breach as a separate operational issue.

{
  "n": 526,
  "band": "hold",
  "skoor": 65,
  "signals": [
    {
      "code": "structuring.pattern",
      "hard": true,
      "detail": "2 debits just under $10,000 in 24h",
      "weight": 35
    }
  ],
  "autoHold": true,
  "routeReason": "hard signal"
}