Quick Response
For vulnerable activities, first confirm the applicable scenario; then review identification, accumulation, notice threshold, cash restriction, controlling beneficiary, and date. Thresholds differ and must be updated using official sources.
Identify vulnerable activity, client, beneficiary, accumulation, and thresholds before submitting AML notices and saving acknowledgments.
Verify Current Thresholds
Classification, accumulation, and date depend on the scenario. Use the minisite and current law before submitting.
Four Different Controls
Vulnerable activities first require confirming if the transaction fits a scenario. Then distinguish obligations for identification, file, cash restriction, and notice.
Thresholds may be expressed in UMA and change with the annual value. Maintain a versioned matrix and do not copy amounts from previous years.
AML Decision Matrix
| Control | Question | Outcome |
|---|---|---|
| Activity | Does it fit a scenario? | Classification |
| Identification | Does it exceed threshold? | File |
| Accumulation | Are operations accumulated? | Monitor |
| Notice | Does it exceed threshold and date? |
AML File by Client
- Activity and legal scenario.
- Client and controlling beneficiary.
- Amount, date, and payment method.
- Accumulation and applicable threshold.
- Notice, acknowledgment, and file retention.
Frequently Asked Questions
Does identifying mean submitting a notice?
Not always. Thresholds and obligations must be analyzed separately.
Should I accumulate operations?
Yes, in applicable scenarios; keep a view by client and period.
What is a controlling beneficiary?
The person who ultimately obtains benefit or control; document the corresponding analysis.
Compliance Engine
- Classify activity and operation.
- Identify client and beneficiary.
- Update UMA and thresholds.
- Accumulate and decide on notice.
- Submit and retain file.
Case: identifying does not always mean notifying
A business performs several operations with the same client over six months. The compliance officer does not review each isolated transaction: consolidates according to applicable rules, verifies identity and controlling beneficiary, and determines if a notice must be submitted.
The identification threshold and the notice threshold may differ; the matrix must keep both and accumulate operations when applicable.
— Fintax
Failures of an AML matrix
- Using thresholds from another year.
- Reviewing isolated transactions without accumulation.
- Confusing client with beneficiary.
- Submitting notice without retaining acknowledgment and file.
Sources and further reading
Consult official sources: Vulnerable Activities minisite, current LFPIORPI, UMA 2026.
To complete the process within Fintax, review: compliance opinion, e.firma validity, monthly controls.
What to do now
Turn this review into a file with responsible person, date, source, and evidence. If there is a material difference, an overdue obligation, or a decision that changes the calculation, validate the case with your accounting responsible before submitting, canceling, or paying.
