> So any time you're seeing a 2-3 day hold on ACH, it's the bank doing risk management decisions, not something in the underlying transfer.

I'm not sure if this is what you meant to begin with, but the institution is probably not doing anything at all. They're just waiting to see if the name gets flagged and to give you time to cancel your credit card or whatever it is. The fishiest transactions start to smell immediately and all you have to do is wait a second for the smell to waft in.