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Compensation accounts in Colombia: using a foreign bank account for regulated FX operations, registration with Banco de la República, monthly reporting and the fines for getting it wrong

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Last verified: 2026-10-26 · Status: Stable

Colombian residents may hold bank accounts abroad freely, but if they use one for any operation that must go through the FX market (imports, exports, foreign loans, foreign investment) or for paying obligations between residents in foreign currency, they must register it with Banco de la República as a compensation account. Registration is due within the calendar month after the first such operation, and every month the holder must transmit a movement report for the previous month through the Sistema de Información Cambiaria, together with the FX declarations for investments and loans. Accounts used only for operations that need not be channelled stay unregistered, and DIAN fines include 200 UVT for each missing or wrong monthly report and 25 UVT per month for late reports.

USD figures use the TRM (tasa representativa del mercado) of COP 3,158.43 per US dollar, valid 24 to 26 October 2026, from the official TRM series certified by the Superintendencia Financiera and published on the national open data portal. Amounts in UVT use the 2026 UVT of COP 52,374 (DIAN Resolución 000238 de 2025). Conversions are for orientation only.

Key facts

Deadline to register a foreign account used for channelled operations	Within the calendar month following the first channelled operation textResolución Externa 1 de 2018 art. 37; DCIP-83 num. 8.2.1, as of 2026-10-26 · in force
Monthly movement report for compensation accounts	Within the calendar month following the month reported textDCIP-83 num. 8.4.1, as of 2026-10-26 · in force
Residents may hold bank accounts abroad	Yes, freely; registration needed only if used for channelled operations textResolución Externa 1 de 2018 art. 81 and art. 37, as of 2026-10-26 · in force
Fine per compensation account report not filed or wrong	200 UVTDecreto Ley 2245 de 2011 art. 3 num. 12, as of 2026-10-26 · in force
Fine for late compensation account report	25 UVT per month, max 150 UVT UVTDecreto Ley 2245 de 2011 art. 3 num. 13, as of 2026-10-26 · in force

The rule

1. Residents may freely open accounts abroad with currency bought in the FX market or from residents who need not channel it, and use them for any operation not compulsorily channelled; returns on those funds may be used likewise and transfers to and from the holder's own compensation accounts are allowed. Residents who use foreign bank accounts for operations that must go through the FX market must register them with Banco de la República as compensation accounts no later than the month following the first such operation. Residents may also agree to use compensation accounts to settle obligations between residents that are not authorized to be paid in foreign currency.Resolución Externa 1 de 2018 of the Board of Banco de la República, Art. 37 and art. 81, 2018-05-25 official text · verified 2026-10-26

2. Only the holder's own operations may pass through a compensation account, with exceptions: when a non resident sells its shares to a resident, the sale proceeds may be paid through the buyer's compensation account (numeral 4560), and dividends declared by a company receiving foreign investment may be remitted through its own compensation account (numeral 2074), the holder acting as agent of the non resident. Loans between residents may not be disbursed through these accounts.Circular Reglamentaria Externa DCIP-83 de 2023, num. 8.1 as amended by Circular DCIP-83 of 19 December 2024, Num. 8.1, 2024-12-19 official text · verified 2026-10-26

3. The account is registered directly by the holder in the Sistema de Información Cambiaria no later than the calendar month following the first compulsorily channelled operation or the first payment of an internal obligation. Cancellation is reported no later than the month after the holder stops using it as a compensation account or closes it. Holders without the electronic means to transmit information may not register compensation accounts and must use FX intermediaries.Circular Reglamentaria Externa DCIP-83 de 2023 (compiled), num. 8.2.2 as amended by Circular DCIP-83 of 23 November 2023, Num. 8.2.1, 8.2.2 and 8.4.1, 2023-11-23 official text · verified 2026-10-26

4. Inflows may come from exchange operations, internal operations settled through the mechanism, purchases of currency from banks or other residents, royalties under the Sistema General de Regalías and transfers from the holder's other accounts; outflows mirror these and include debit card payments. An inflow to the account is the channelling into the FX market and an outflow is the channelling out. Available balances may be used for financial investments abroad. Overdrafts on compensation accounts are not reported as foreign debt.Circular Reglamentaria Externa DCIP-83 de 2023, num. 8.3 (ordinal viii added by Circular DCIP-83 of 15 May 2024), Num. 8.3.1, 8.3.2 and 8.3.3, 2024-05-15 official text · verified 2026-10-26

5. Holders must report the movements of each month within the following calendar month by transmitting a consolidated Informe de Movimientos de Cuenta de Compensación. Before that report they must transmit the FX declarations for international investment (numerals 4026, 4032, 4035, 4036, 4040, 4563, 4565 and 4580) and for foreign loans and guarantees. For imports and exports the movement report itself is the FX declaration. Foreign loans received into a compensation account still need the loan report and any deposit through a Colombian bank before disbursement.Circular Reglamentaria Externa DCIP-83 de 2023, num. 8.4.1 as amended by Circular DCIP-83 of 19 December 2024, Num. 8.3.1, 8.3.2, 8.4.1 and 8.4.2, 2024-12-19 official text · verified 2026-10-26

6. Consortia and joint ventures (uniones temporales) are not residents for exchange purposes and may not carry out FX operations or register compensation accounts in their own name; operations must be in the name of a member, and accounts list all the participants.Circular Reglamentaria Externa DCIP-83 de 2023 (compiled), Num. 10.1 and 8.7, 2023-09-12 official text · verified 2026-10-26

7. DIAN fines for compensation accounts: 200 UVT for each monthly movement report not filed or filed incomplete or wrong (even if the account had no movement); 25 UVT per month or part of a month of delay for late reports or late reporting of cancellation, capped at 150 UVT; 100 percent of the amount for channelling third party operations not authorized; and 25 UVT per FX declaration not transmitted on time, capped at 1,000 UVT per investigation.
Cost to do it: A missing monthly report costs 200 UVT (COP 10,474,800, about US$3,316); a late one 25 UVT (COP 1,309,350, about US$415) per month up to 150 UVT (COP 7,856,100, about US$2,487).Decreto Ley 2245 de 2011 (DIAN exchange sanctions regime), Art. 3 num. 1, 12, 13 and 15, 2011-06-28 official text · verified 2026-10-26

Use of the foreign account	Register as compensation account?	Reporting
Receiving fees for services, personal savings, investments with free market currency	No	None under the exchange rules (tax reporting still applies)
Paying imports or receiving export proceeds	Yes, within the month after the first operation	Monthly movement report (serves as FX declaration)
Receiving a foreign loan or paying its interest	Yes	Loan report through a bank before disbursement, FX declaration, monthly report
Receiving foreign capital or remitting dividends for foreign shareholders	Yes	Investment FX declaration before the monthly report
Settling an obligation with another resident in foreign currency	Yes	Monthly report with internal operation numerals 3000 and 3500

Bank account abroad: when it must be registered (Resolución Externa 1 de 2018 art. 37 and 81; DCIP-83 ch. 8)

Worked example

A Bogotá distributor opens an account with a Miami bank and, on 10 March, pays a Chinese supplier for imported goods from it. It must register the account as a compensation account by 30 April (the month following the first operation) and from then on report each month's movements by the end of the following month.
It forgets the March, April and May reports and files all three on 15 July. If DIAN treats them as late, each one costs 25 UVT per month or part of a month of delay: the March report is about three months late, 75 UVT (COP 3,928,050, about US$1,244); if any report were never filed, the fine would be 200 UVT (COP 10,474,800, about US$3,316) each.
It then lets a sister company pay its own supplier through the account. Channelling another company's operations through a compensation account is fined at 100 percent of the amount (Decreto Ley 2245 art. 3 num. 15).

Step by step

1. Map which foreign accounts touch channelled operations; keep a separate unregistered account for free market funds if useful.
2. Get Sistema de Información Cambiaria user access for the company (DCIP-83 Annex 3).
3. Register each compensation account within the month after its first channelled operation, with bank, country, currency and first operation date.
4. For each investment or loan flow, transmit the FX declaration before the month's movement report; for loans, file the loan report through a Colombian bank before disbursement.
5. Transmit the monthly movement report by the end of the following month, even for months with no movement.
6. Report cancellation within the month after closing the account or ceasing to use it as a compensation account.

Common traps

Assuming an account with no movement needs no report. The 200 UVT fine applies even if the account had no movement in the period (Decreto Ley 2245 art. 3 num. 12).
Using one group account for several Colombian companies. Only the holder's own operations may pass through it, save the dividend and share sale exceptions (DCIP-83 num. 8.1).
Registering an account by mistake. If no channelled operation ever happened, the holder must annul the registration, which also annuls the reports filed (DCIP-83 num. 8.2.3).
Opening the account in the name of a consortium. Consortia are not exchange residents; the account must belong to a member and list all participants (DCIP-83 num. 10.1).

Sources

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