On December 6, the Superintendence of Companies modified sections 4.4 and 4.5 of Chapters X and XIII of the Basic Legal Circular through External Circular 100-300000. This modification affects the obligations of Chambers of Commerce and Foreign Non-Profit Entities (ESAL) with permanent operations in Colombia regarding the Anti-Money Laundering and Terrorism Financing System (SAGRILAFT) and the Business Transparency and Ethics Program (PTEE).
Foreign ESALs (non-profit entities) with permanent operations in Colombia must adopt the Minimum Measures Regime to prevent the risks of Money Laundering and Terrorism Financing. Additionally, they will be required to identify and assess the risks of corruption and transnational bribery only if their total income for the previous year is equal to or greater than 9,000 legal monthly minimum wages (9,000 SMMLV).
Meanwhile, Chambers of Commerce with annual income greater than 40,000 SMMLV must implement both SAGRILAFT and PTEE. Those with income between 9,000 and 40,000 SMMLV must adopt the Minimum Measures Regime and assess only corruption risks. Chambers with income below 9,000 SMMLV are exempt from these obligations, although they may adopt these measures as best practices.
Entities that meet the established criteria on December 31 of each year will have until May 31 of the following year to comply with these provisions.