CEMI

Governance and the lines we do not cross

Virtual Financial Ecosystem Simulation - CEMI Financial Innovation Lab
An initiative of CEMI’s Financial Innovation Lab
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Governance and the lines we do not cross

Some of what follows is a constraint on what this project may claim, and some of it is a constraint on what it may do. Both are stated on this site and on cemi.ai in the same words, so neither can be quietly relaxed in one place.

Lines we do not cross

Governance — read this before you use a report

The discipline that makes what comes out of here usable is the same discipline that stops it claiming to be more than it is.

  • Never the real thing. Every simulator carries a Lab name and a visible notice. There are no real credentials, keys, BINs, routing identifiers, aliases or certificates anywhere, and no institution being modelled has endorsed it.
  • This is NOT an «ambiente de prueba» under Art. 83 of the Reglamento de Sistemas de Pago. The ecosystem involves no real providers and no real external users, so it does not fall under the no-objection regime. A run is never a substitute for the Central Bank’s no objection: it is evidence for a request and nothing more.
  • No real personal data. The synthetic population is generated from the run seed, its generator is auditable, and identifiers carry LAB- and LB prefixes so they cannot collide with real ones.
  • Rules cite their source and carry their date. A rule that does not name its article, its resolution and that resolution’s date fails to load. The 2026 values are marked as such and re-checked each January.
  • Reports say what was tested — scenario, variant, seed, fidelity tiers, clock mode, rule catalogue version. A “pass” is a pass on that run.