Research and legal mapping
The starting point was a review of the primary legal sources, AMLA, AMLO and AMLO-FINMA, to identify the obligations applicable to financial intermediaries in the context of client onboarding and suspicious activity reporting. The key regulatory triggers, including the duty to identify customers, establish beneficial owners, clarify increased risks, and report suspicious activity to MROS, were mapped to their respective legal provisions across all three instruments.
Diagram drafting and iteration
The visual was assembled as a diagram, arranging swim lanes, decision diamonds, and document symbols into a BPMN layout. Several iterations were required to correctly reflect the conditional logic, for instance, the branching at the reasonable suspicion gateway, the parallel notification and freeze obligations, and the timeout path triggered by the five-day MROS response window.
Runnable BPMN
The finalised diagram was produced as a standards-compliant BPMN 2.0 file, directly executable on standard process engines. Each process node, gateway, and sequence flow corresponds to a typed BPMN element, preserving the full conditional logic of the depicted process. The runnable BPMN file enables financial intermediaries and compliance teams to deploy the process directly into their workflow infrastructure and automate execution of the depicted obligations.

