The Superintendence of Companies has released a draft External Circular that replaces Chapters X and XIII of the Legal Basic Circular, which relate to the SAGRILAFT and PTEE Compliance Programs.
The most significant development is the consolidation of both programs into a single Risk Management and Self-Control System, covering Money Laundering, Terrorism Financing, Financing of the Proliferation of Weapons of Mass Destruction, Domestic Corruption, and Transnational Bribery.
The draft eliminates the need to consider factors such as international transactions or contracts with government entities when determining whether the programs are mandatory. Going forward, the requirements would apply to companies not supervised by another regulatory body that report revenues or assets equal to or exceeding 4,929,017 Basic Value Units (UVB), equivalent to COP 59,690,395,870 in 2026.
Sectors such as real estate agents, legal services, and other Designated Non-Financial Professional Activities (DNFPAs) that exceed the thresholds established specifically for these activities will be required to implement a Minimum Measures Regime to prevent Money Laundering and Corruption risks.
Key changes also include: a risk-based Due Diligence approach in line with Law 2195 of 2022, the mandatory appointment of a Deputy Compliance Officer, and a dedicated policy to manage the risk of Financing the Proliferation of Weapons of Mass Destruction.
This draft would significantly expand the universe of obligated entities, including sectors not previously covered and lowering the thresholds for revenue and assets.
With the public comment period closing on January 4, 2026, companies should begin preparing to anticipate and assess the potential impacts of its approval.
