Trigger Alexa notifications from Alexa skill lambda?

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Does it comply with Amazon guidelines if I trigger Alexa notifications from Alexa skill lambda itself without an external lambda? ie directly calling api.amazonalexa.com/v2/notifications without any external triggers?

Original Alexa notification flow


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My implementation


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This architecture is approved by Alexa team. The skill is live now. Hence we can conclude that it conforms to Amazon guidelines.