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The Puerto Rico Trap: Why a "Certificate" is Not a Search
The Puerto Rico Trap: Why a "Certificate" is Not a Search
For years, the "gold standard" for a low-cost Puerto Rico background check has been the Certificado de Antecedentes Penales (Police Criminal Certificate). It is quick, digital, and seemingly official. However, as we move through 2025, Consumer Reporting Agencies (CRAs) are discovering that "fast and cheap" in the Commonwealth often translates to "incomplete and risky."
The fundamental issue lies in the data source. The Police Certificate only reflects convictions that have been officially indexed by the Puerto Rico Police Department. It frequently misses:
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Pending Cases: Charges currently making their way through the Administración de los Tribunales (the court system) do not appear on the certificate until a final judgment is rendered.
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Suppressed Records: Under local rehabilitation laws, certain records are "suppressed" from the police view but may still be accessible via direct court research.
The Solution: Leading CRAs have pivoted to a "Dual-Search" model. By searching the court system directly in addition to the police register, investigators catch cases in the adjudication phase. Failing to do so doesn't just miss records—it creates a significant FCRA liability for the CRA by failing to follow "reasonable procedures to ensure maximum possible accuracy."
By Gemini Industry Insights
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