LPB, alerts, ROI, 24 hours, SITI and audit

Blocked Persons List match: immediate flow

Decision point

The LPB match opens a case with a clock, an owner and immediate preservation. Identity is first validated with additional attributes; the measures and reports applicable to the outcome are then executed. The analysis must cover related relationships, beneficiaries and linked instructions without asserting a match before confirming it.

Checklist

1. Freeze the case and preserve data.
2. Resolve identity using documented criteria.
3. Escalate, report and execute measures according to the outcome.

Observed pattern

In an anonymized case, the match came from a beneficiary and not from the customer; the data model made it possible to locate related instructions and preserve evidence.

How to put it into practice

Open the case with the original match and preserve the search result. Use additional attributes to confirm or rule out identity. Locate related transactions, attempts, beneficiaries and balances without waiting to conclude. Record each clock and owner. If measures are applied, the order must reach operational systems and not remain in email. The final case file clearly distinguishes alert, confirmation, action and report, avoiding attributing to a person facts based solely on name coincidence.

Stress test

Set up a partial match during an already funded instruction. The flow must prevent disposition, preserve funds and escalate the review without improperly tipping off the person. Record the query time, list version, matching fields and subsequent actions. If confirmed, blocking and reporting follow the applicable sequence; if ruled out, the disambiguation evidence supports the release.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.

LPB with no subsequent transaction: how to document the decision

Decision point

When there is no subsequent transaction, the timeline must distinguish historical relationship, attempt, database query and inclusion date. The decision whether or not to report is grounded in those facts and in the applicable rule. The logs and searches prove that no activity was invented to justify the case file.

Checklist

1. Pin down the last transaction and the match date.
2. Retain searches and results.
3. Document the basis for reporting or not reporting.

Observed pattern

In an anonymized case file, there was no subsequent movement; the timeline and the logs made it possible to explain why the case was handled preventively.

How to put it into practice

Pin down the last activity before the inclusion date and search for subsequent events across all sources. Distinguish query, failed attempt and completed transaction. Retain logs that prove absence, including rejected records. The decision on reporting cites the exact scenario and explains why the facts do or do not trigger it. If a historical relationship exists, specify monitoring measures. This avoids filling a narrative with nonexistent movements to justify a preventive conclusion.

Stress test

A match can arise during a list update even if the user does not attempt another transaction. Reconstruct the last activity, balance, products and controls available at the time of detection. The decision must explain why an additional act does or does not exist, without treating inactivity as an automatic dismissal. Retain the periodic query that generated the case and the assessment of any funds still subject to control.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.

24-hour report vs. unusual transaction

Decision point

The 24-hour report and the unusual report have triggers and clocks that must be documented separately. A single case file establishes when the fact became known, what transaction or attempt existed and what information was available. If there are related reports, their narratives must be compatible without duplicating conclusions.

Checklist

1. Define the knowledge event.
2. Use a decision matrix by scenario.
3. Reconcile related reports before submission.

Observed pattern

In an anonymized review, a single case had two drafts with different knowledge dates; a single case file corrected the clock and the narrative.

Common risk

Different knowledge dates in parallel drafts can alter the deadline and the explanation submitted.

How to put it into practice

Build a timeline with transaction, alert, knowledge, decision and submission. Mark what information was known at each moment. Use a matrix to choose the type of report and prevent the same fact from receiving incompatible labels. Compare the structured file and the narrative. If two related reports are filed, link them without copying conclusions. The deadline control must start from the documented regulatory event, not from the convenient date of the final draft.

Stress test

Compare an event that requires immediate attention due to a blocked list with conduct that requires an unusualness analysis. Dates, triggers and decisions must follow separate tracks even if they share documents. The reporting matrix records the basis, deadline, owner and acknowledgment for each path. Merging them into a single narrative can delay the urgent obligation or submit unsupported conclusions.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.

How to write an unusual transaction narrative

Decision point

The narrative starts from a chronology and the expected profile, not from the blank form. It explains subjects, transaction, deviation, investigation, sources and reason for suspicion, distinguishing confirmed data from inference. The structured fields and the text are reconciled before submission so that they do not describe different roles or amounts.

Checklist

1. Build the chronology before drafting.
2. Quantify the deviation against the profile.
3. Remove unsupported conclusions.

Observed pattern

In an anonymized layout, separating facts, analysis and conclusion prevented the analyst's hypotheses from appearing as confirmed data.

Common risk

Listing movements without explaining why they depart from the profile produces volume, but not a useful analytical conclusion.

How to put it into practice

Draft the facts in order first and then the deviation from the profile. Identify the sources consulted and the result of each. Separate inferences through prudent language and do not assert crimes. Quantify the frequency, amount or relationship that makes the pattern unusual. Check that the fields and the text name the same roles. A second person must be able to explain why the report is filed using only the case file and to point out which hypothesis was ruled out.

Stress test

Draft the narrative from a timeline and not from adjectives. Include the user's expectation, observed pattern, deviating variables, counterparties and the result of the analysis. Each figure must reconcile with the submitted table. A reader unfamiliar with the case must understand what happened and why it matters without opening ten annexes, but must also be able to locate the evidence if they need to verify it.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.

Quality control before submitting a report through SITI

Decision point

SITI requires two reviews: a technical one for format and catalogs, and a semantic one against the case file. Identifiers, dates, roles, amounts, narrative and the final version are validated. The accepted file is stored with a hash and acknowledgment to demonstrate exactly what left the entity.

Checklist

1. Separate technical and legal validation.
2. Reconcile the sample against the source system.
3. Store the final file, hash and acknowledgment.

Observed pattern

In an anonymized upload, the XML passed validation but an inverted catalog changed the counterparty's role; a semantic reconciliation detected it.

Common risk

XML validation can approve an inverted catalog that turns the beneficiary into the originator.

How to put it into practice

Upload the file in a validation environment and retain corrected errors. Then compare a sample against the source system, including catalogs and signs. The person reviewing the narrative must know the case, not just the XML. Generate a hash before submitting and download the acknowledgment. If the platform accepts it, still confirm the period and the number of records. The final evidence joins the case file, the transmitted file and the technical response without allowing subsequent substitutions.

Stress test

Insert into a test file an amount that does not match the narrative and a date in an invalid format. Quality control must detect them before signing. Then reconcile the number of cases, totals and types against the source system, and retain the rejected and corrected versions. The acknowledgment is tied to the exact batch to demonstrate what information the authority actually received.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.

Concerning internal transactions: channel and evidence

Decision point

A concerning internal transaction requires an independent channel, confidentiality and conflict control. The investigation preserves accesses, decisions, communications and interviews without depending on the flagged area. The competent body receives sufficient facts and limits distribution of the case file.

Checklist

1. Enable an independent channel.
2. Preserve logs and conflicts of interest.
3. Escalate to the competent body with restricted access.

Observed pattern

In an anonymized case, an employee alert was closed as an operational error without interviewing or reviewing accesses; the second review level changed the conclusion.

Common risk

Closing the conduct as an operational error without reviewing privileges or instructions can conceal a deliberate intervention. The access log must retain who consulted the case and with what justification.

How to put it into practice

Enable a channel that bypasses the potentially involved manager. Upon receiving a signal, preserve accesses, communications and decisions before interviewing. Define an investigation team without conflict and limit copies. The analysis distinguishes error, non-compliance and concerning conduct. If it is reported, the narrative protects unnecessary data but retains the facts. The competent body documents labor and regulatory measures separately. Traceability must show who consulted the case and with what justification.

Stress test

Test the channel with conduct attributable to a person with administrative privileges. Intake must prevent the person involved from viewing, modifying or closing their own case. Preserve the original message, accesses and decisions, limiting circulation on a need-to-know basis. The case file separates the labor investigation, the PLD analysis and any eventual report, because each path has different owners, deadlines and evidence standards.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.

What the CCC must decide and document in response to an alert

Decision point

The CCC must know the population reviewed, the alert, the analysis, the sources and the decision options. The minutes record conflicts, vote, basis, actions and follow-up, while the sensitive detail remains in the annexed case file. The subsequent session verifies that the resolution was executed.

Checklist

1. Circulate the case file in advance with controlled access.
2. Record conflict, vote and basis.
3. Assign follow-up and a verification date.

Observed pattern

In anonymized minutes, the conclusion was clear but did not identify the population reviewed; annexing the case file corrected traceability.

Common risk

A conclusion without reference to the case or its annexes does not allow reconstruction of what information supported the vote.

How to put it into practice

Provide the committee with a brief containing chronology, profile, alert, investigation and proposal. Identify missing information and its effect on the decision. The members declare conflicts and record their vote. The annex retains sensitive detail while the minutes summarize the basis. Assign actions with an owner and a date. At the next session, review compliance. The decision becomes auditable when it can be linked to the exact case file and not when only a phrase of approval is recorded.

Stress test

Bring to the committee an alert with incomplete information and a split recommendation. The minutes must show available facts, pending questions, conflict of interest, decision and follow-up condition, without copying unnecessary sensitive data. At the subsequent session, the body verifies the condition and closes or reopens. Recording only 'reviewed and approved' prevents assessment of the quality of governance.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.

PLD alert SLA: how to avoid an indefensible backlog

Decision point

The SLA is designed from criticality and the regulatory clock, not from the historical average. Triage prioritizes LPB, short deadlines, high risk and perishable data; the dashboard measures age, volume, cause and capacity. Contingencies are activated before the queue makes quality review impossible.

Checklist

1. Prioritize by risk and due date.
2. Measure age, volume and root cause.
3. Activate contingency before exceeding capacity.

Observed pattern

In an anonymized matrix, old low-value alerts were blocking critical cases because the queue was strictly chronological.

Common risk

Extending the internal deadline to show fewer overdue items only changes the indicator; it does not reduce the accumulated risk.

How to put it into practice

Measure age by criticality and not just the queue average. Reserve capacity for LPB and upcoming due dates. Analyze the cause of accumulation: a noisy rule, missing data, provider or staffing. Test sampling of quick closures to detect loss of quality. Contingency can redistribute cases but maintains independence. Report volume, risk and plan to the body. Reducing the backlog requires correcting its origin without deactivating scenarios that still detect relevant conduct.

Stress test

Measure age by stage and risk, not just the total of open alerts. One case may be awaiting external information while another remains unassigned. Define authorized pauses, the applicable clock and a priority criterion, and test reassignment during absences. The dashboard must reveal trend, capacity and due dates so that the owner acts before the inventory becomes a mass remediation.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.

PLD audit: independence and closure of findings

Decision point

The audit defines population, period, sample and criteria before testing design and effectiveness. Each finding separates condition, cause, risk and evidence; the response assigns an action and an owner. Closure requires retesting the control, not accepting a newly drafted policy.

Checklist

1. Define the population and a reproducible sample.
2. Classify findings by risk and recurrence.
3. Validate closure with an independent test.

Observed pattern

In an anonymized checklist, several controls existed in the manual but left no evidence of execution during the period.

Common risk

Marking a finding as addressed because a new document exists can conceal that it was never executed in production.

How to put it into practice

Define population and sample in a reproducible way. For each control, contrast what is written with the period's transactions. The finding describes observed evidence and risk, not just documentary absence. The response includes cause and a verifiable change. Before closing, select a new sample. Maintain independence between the executor and the validator. The report must allow the board to distinguish deficient design, failed execution and insufficient evidence, since each problem requires a different remediation.

Stress test

Include a finding whose owner proposes to close it with an updated policy, even though the failure came from the system. The auditor must require operational proof and a subsequent sample. Independence includes the absence of design and of self-assessment of the reviewed control. Closure documents cause, action, owner, date, evidence and validation; accepting a promise without a retest leaves the risk intact.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.

Regulatory calendar with audit-ready evidence

Decision point

The audit-ready folder functions as an evidentiary index by obligation and period. It links the basis, owner, final file, version, hash, acknowledgment, review and remediation. The calendar stops being an isolated traffic light and makes it possible to go from the date to the evidence without depending on personal memory.

Checklist

1. Link the task to the final file and acknowledgment.
2. Apply dual control to critical dates.
3. Reconcile the calendar with regulatory changes.

Observed pattern

In an anonymized control, the submission date was recorded, but the exact file was missing; adding a hash and path turned the calendar into an evidentiary index.

Common risk

Recording 'submitted' without retaining the exact file makes it impossible to prove what information the authority received. Periodic sampling must confirm that each index still opens the correct file and acknowledgment.

How to put it into practice

Organize the folder by obligation and cutoff, not by employee name. Each index links the final version, hash, acknowledgment and approval. Test permissions and availability after staff changes. Periodic sampling must confirm that each link opens the correct support. Record substitutions without deleting the submitted file. To respond to an official request, the folder must quickly produce the population and the explanation of exceptions. That capability demonstrates continuous control, not improvisation in the face of supervision.

Stress test

Build an obligation from its legal basis to the acknowledgment and add a substitute for each owner. If the format or portal changes, record the decision and update the instructions before the due date. The calendar distinguishes the regulatory date, the internal date, preparation and approval. A timely but incomplete filing is not marked green until content, signature, submission and evidence of receipt are reconciled.

Legal basis

• Legal provisions applicable to money transmitters — DCG derived from article 95 Bis and its amendments.
• Ley General de Organizaciones y Actividades Auxiliares del Crédito (text in force) — articles 81-A Bis, 81-B, 81-D, 86 Bis and 95 Bis, depending on the topic.