Practice area
Compliance and Corporate Integrity
Colombian law requires companies above certain thresholds to implement anti-money-laundering (SAGRILAFT) and anti-bribery (PTEE) regimes, merged into Chapter IX by External Circular 100-000020 of 2026, with a compliance deadline of 31 May 2027. We design, implement and audit these systems and respond to regulatory investigations.
Scope
Compliance and Corporate Integrity services
- Adequacy to the merged Chapter IX (External Circular 100-000020 of 2026)
- SAGRILAFT anti-money-laundering system design and implementation
- PTEE transparency and business ethics programmes
- Personal data protection policies and procedures
- Codes of ethics and anti-corruption and anti-bribery policies
- Information security policies under Colombian ICT standards
- Risk matrices and whistleblowing channels
- Compliance training for boards and senior management
- Response to Superintendence of Companies and SIC requirements
- OECD procedures and policy training
Who handles it
Lawyers in this practice
Common questions
Questions about compliance and corporate integrity
- Which companies must implement SAGRILAFT in Colombia?
- Companies supervised by the Superintendence of Companies that exceed the revenue or asset thresholds of Chapter IX, as set by External Circular 100-000020 of 2 July 2026. That circular merged the AML and anti-bribery regimes and now states thresholds in UVB units rather than minimum wages. The compliance deadline is 31 May 2027.
- How does SAGRILAFT differ from a PTEE programme?
- SAGRILAFT addresses money laundering, terrorist financing and proliferation financing. PTEE addresses transnational bribery and corruption. Since External Circular 100-000020 of 2026 they share Chapter IX, but they remain separate regimes with different obligated parties and criteria: each test is run independently.
- What is the exposure for a foreign parent company?
- Beyond penalties on the Colombian subsidiary, the Superintendence may impose personal sanctions on directors and the compliance officer. For groups subject to the FCPA or the UK Bribery Act, a Colombian compliance failure also becomes a reportable issue at group level.