The Financial Superintendency of Colombia has issued External Circular 10 of 2025, in compliance with Constitutional Court Ruling T-113 of 2025, aimed at ensuring access to financial products and services for individuals with criminal records or ongoing criminal investigations.
Under the new guidelines, financial institutions are required to apply their Anti-Money Laundering and Counter-Terrorism Financing Risk Management System (SARLAFT) in a proportional and reasonable manner. Controls must be tailored to each customer’s risk profile, avoiding the use of automatic restrictions that could unjustifiably limit access to financial services.
Risk assessments must be based on objective and individualized criteria, considering factors such as the nature of the criminal record, how long ago the offense occurred, and its relevance to the financial product or service being requested.
Furthermore, financial services cannot be denied solely based on a criminal record or an ongoing investigation without a prior, case-by-case analysis. If access is denied, institutions must provide the customer with clear, timely, and sufficient justification, including objective reasons, supporting grounds, and any alternative measures considered, as specified in the Circular.
Superintendency will actively oversee compliance with these provisions. Financial institutions must update their internal procedures by October 15, 2025
