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
- Never the real thing. Every simulator carries a Lab name and a visible notice. No real credentials, keys, BINs, routing identifiers, aliases or certificates. No claim of endorsement by any institution being modelled unless a written agreement says so.
- Not an «ambiente de prueba» under Art. 83. No real providers, no real external users — so the ecosystem does not fall under the no-objection regime, and a run is never a substitute for the Central Bank’s no objection.
- No real personal data. Including from Living Lab participants, beyond anonymized traces with consent. The synthetic population is generated and its generator is auditable.
- Regulators are invited in, not simulated behind their back. The Banco Central and the Superintendencia are offered a seat now, and the seat is built.
- Rules cite their source and carry their date. Every executable rule names its article and its resolution; the 2026 capital and cap values are marked as such and re-checked each January when the Junta Monetaria adjusts them.
- Reports say what was tested. Scenarios, seed, fidelity tiers, modes and rule-catalogue version. A pass is a pass on that run.
- Open where it can be. Message contracts, the rule catalogue and the scenario formats are published; actor implementations may be proprietary or sponsored.
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-andLBprefixes 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.