On 16 September, the Colombian Superintendence of Surveillance and Private Security issued Circular No. 20251000000035CS, establishing a mandatory requirement for all legal entities under its supervision to implement a Corporate Transparency and Ethics Program (PTEE).
This regulation applies to both armed and unarmed surveillance companies, cash-in-transit services, armored vehicle providers, armored vehicle rental firms, cooperatives, security training schools, in-house security departments, and security consulting and investigative firms, among others.
The PTEE aims to mitigate the risks of corruption, bribery, and fraud (CO/SO/F) through integrity policies, risk management procedures, whistleblowing channels, training programs, and monitoring and enforcement mechanisms. Each company must also appoint a Compliance Officer responsible for implementing and overseeing the program.
Companies with current operating licenses must comply with the PTEE by March 2026 — six months from the publication of the Circular. Entities that receive their operating authorization after that date must adopt the program within six months from the effective date of their registration or licensing. Non-compliance may lead to administrative sanctions under Decree Law 356 of 1994.
