Countries › Colombia › Guide › 13. Regulation › AML and ethics compliance in Colombia: the Supersociedades unified LA/FT/FP and C/ST system, minimum measures regime, compliance officer, due diligence, UIAF reporting and penalties

AML and ethics compliance in Colombia: the Supersociedades unified LA/FT/FP and C/ST system, minimum measures regime, compliance officer, due diligence, UIAF reporting and penalties

Last verified: 2026-10-27 · Status: Changing

Since 2 July 2026 companies supervised by the Superintendencia de Sociedades no longer run separate AML (SAGRILAFT) and ethics (PTEE) programs: Chapter IX of the new Circular Básica Jurídica requires one risk management system for money laundering, terrorist and proliferation financing, corruption and transnational bribery. It applies to companies and foreign company branches with income or assets of at least 4,929,017 UVB (COP 59,690,395,870, about US$18.9 million), to listed high risk sectors from 3,696,762 UVB, and a lighter minimum measures regime applies to some sectors from 369,676 UVB of income or 616,127 UVB of assets; existing programs must migrate by 31 May 2027. Obliged companies need a board approved system, an independent compliance officer domiciled in Colombia, risk based due diligence on counterparties and beneficial owners, a whistleblowing channel and immediate suspicious transaction reports to the UIAF; breaches carry Supersociedades fines of up to 200 pre 2024 minimum wages each, and money laundering itself carries 10 to 30 years in prison.

USD figures use the TRM (tasa representativa del mercado) of COP 3,157.94 per US dollar, valid 27 October 2026, from the official TRM series published by the Superintendencia Financiera on the national open data portal. Conversions are for orientation only.

Key facts

Income or asset threshold for the unified LA/FT/FP and C/ST system, general	4929017 UVBSupersociedades Circular Externa 100-000020 de 2026 num. 9.4, as of 2026-10-27 · in force
Income or asset threshold for the unified system, general, 2026 pesos	59690395870 COPSupersociedades Circular Externa 100-000020 de 2026 num. 9.4; UVB 2026, as of 2026-10-27 · in force
Income or asset threshold for the unified system, listed sectors	3696762 UVBSupersociedades Circular Externa 100-000020 de 2026 num. 9.5, as of 2026-10-27 · in force
Income threshold for the minimum measures regime (listed sectors)	369676 UVBSupersociedades Circular Externa 100-000020 de 2026 num. 9.6, as of 2026-10-27 · in force
Asset threshold for the minimum measures regime (listed sectors)	616127 UVBSupersociedades Circular Externa 100-000020 de 2026 num. 9.6, as of 2026-10-27 · in force
Deadline for existing SAGRILAFT and PTEE programs to adapt to the unified system	2027-05-31 dateSupersociedades Circular Externa 100-000020 de 2026 num. 9.29, as of 2026-10-27 · in force
Maximum number of obliged companies one compliance officer may serve outside a group	10 companiesSupersociedades Circular Externa 100-000020 de 2026 num. 9.9.3, as of 2026-10-27 · in force
Maximum prison term for money laundering	30 yearsCódigo Penal art. 323, as of 2026-10-27 · in force

The rule

1. Supersociedades Circular Externa 100-000020 of 2 July 2026 issued a new Circular Básica Jurídica, in force on publication. Its Chapter IX merges the former SAGRILAFT (anti money laundering, terrorist and proliferation financing) and PTEE (transparency and business ethics) into a single Sistema de Autocontrol y Gestión de Riesgos LA/FT/FP y C/ST. Companies, sole proprietorships and branches of foreign companies supervised or controlled by the Superintendencia de Sociedades (and not under another special supervisor) with total income or total assets at 31 December of the prior year of 4,929,017 UVB or more must implement it.
Example: Threshold: 4,929,017 UVB x COP 12,110 = COP 59,690,395,870. / About us$18.9 million.Superintendencia de Sociedades Circular Externa 100-000020 de 2026 (Circular Básica Jurídica), Chapter IX num. 9.4, 2026-07-02 official text · verified 2026-10-27 · changed: From 2 July 2026 the separate SAGRILAFT and PTEE circulars were replaced by one unified system with thresholds in UVB; programs under the previous circulars remain valid until 31 May 2027.

2. Lower thresholds apply to supervised companies in listed sectors, by registered CIIU code: real estate agents (6810, 6820), precious metals and stones trading (4662, 3211, 2421, 0722), legal services (6910), accounting services (6920), building and civil works construction (4111, 4112, 4210, 4220, 4290) and vehicle dealers (4511, 4512, G4541), all from 3,696,762 UVB of income or assets. Companies receiving contributions in virtual assets, or providing virtual asset services, are covered from 12,323 UVB of contributions or operations (service providers also subject to income or asset tests). Special supervision regimes and chambers of commerce have their own rules.
Example: Sector threshold: 3,696,762 UVB = COP 44,767,787,820; virtual asset trigger: 12,323 UVB = COP 149,231,530. / About us$14.2 million; about US$47,300.Supersociedades Circular Externa 100-000020 de 2026, Chapter IX num. 9.5.1 to 9.5.9, 2026-07-02 official text · verified 2026-10-27

3. A Régimen de Medidas Mínimas (RMM) applies to designated non financial businesses and supervised companies in listed sectors (real estate agents, precious metals and stones, legal and accounting services, vehicle dealers, pharmaceutical, infrastructure and construction, certain manufacturing codes and mining and energy codes) with income of at least 369,676 UVB or assets of at least 616,127 UVB, and to some chambers of commerce. Under the RMM the legal representative designs, executes and supervises the measures and the board or highest corporate body approves them.
Example: RMM triggers: income of COP 4,476,776,360 or assets of COP 7,461,297,970. / About us$1.4 million or about US$2.4 million.Supersociedades Circular Externa 100-000020 de 2026, Chapter IX num. 9.6 and 9.21, 2026-07-02 official text · verified 2026-10-27

4. Obliged companies must appoint a principal and an alternate compliance officer reporting directly to the board (or highest body). Each must hold a professional degree updated at least every 3 years, have at least 1 year of experience in AML and anti corruption compliance, prove training through formal postgraduate studies or courses of at least 90 hours, and be domiciled in Colombia. The officer may not serve more than 10 obliged companies (no limit within a declared group), may not be a director, legal representative, administrator, shareholder, statutory auditor or internal or external auditor. Appointments must be reported to the Superintendencia within 15 business days through the online non financial report, and a vacancy must be filled within 30 calendar days.Supersociedades Circular Externa 100-000020 de 2026, Chapter IX num. 9.9.2, 9.9.3 and 9.9.4, 2026-07-02 official text · verified 2026-10-27

5. Due diligence must identify each counterparty and its beneficial owner and be updated at least once a year for high risk counterparties and at least every 2 years for medium or low risk ones, or sooner when alerts arise. Enhanced due diligence applies to higher risk counterparties, politically exposed persons (PEPs), extending to spouses, relatives up to the second degree, foreign accounts and close associates, and counterparties in non cooperative or high risk jurisdictions. Companies must have a confidential and anonymous whistleblowing channel with non retaliation, and must report suspicious transactions to the UIAF immediately as a ROS through the SIREL system; supporting documents are kept under the commercial books retention rules.Supersociedades Circular Externa 100-000020 de 2026, Chapter IX num. 9.15, 9.17, 9.18, 9.19 and 9.22, 2026-07-02 official text · verified 2026-10-27

6. New obliged companies (those first meeting the thresholds from 31 December 2026) must put the system in place by 31 May of the following year. Companies already obliged under Circulares 100-000016 de 2020, 100-000011 de 2021 and 100-300000 de 2024 must adjust by 31 May of the year after the circular (31 May 2027), and their current programs remain valid meanwhile. A company that stops meeting the thresholds stays obliged for 2 more years (1 year for the RMM).Supersociedades Circular Externa 100-000020 de 2026, Chapter IX num. 9.28, 9.29 and 9.30, 2026-07-02 official text · verified 2026-10-27

7. The Superintendencia de Sociedades may impose fines, successive or not, of up to 200 monthly minimum wages on anyone who breaches its orders, the law or the bylaws. Under Chapter IX, breaching its instructions can lead to sanctions on the company, its administrators, the compliance officer and the statutory auditor, calculated in UVB under Ley 2294 de 2023 art. 313 at the value in force when imposed.
Cost to do it: Maximum fine per breach in 2026: COP 280,952,000 (about US$89,000), which can be repeated.Ley 222 de 1995; Supersociedades Circular Externa 100-000020 de 2026, Ley 222 art. 86 num. 3; Circular Chapter IX num. 9.27, 1995-12-20 official text · verified 2026-10-27

8. Money laundering (acquiring, holding, investing, transporting, transforming or administering assets from listed crimes, including drug trafficking, extortion, crimes against public administration, smuggling and customs fraud, or giving them an appearance of legality) is punished with 10 to 30 years in prison and a fine of 1,000 to 50,000 monthly minimum wages, even if the underlying crime happened abroad, with prison increased by one third to one half when exchange or foreign trade operations are used. Terrorist financing carries 13 to 22 years and a fine of 1,300 to 15,000 minimum wages.Código Penal, Ley 599 de 2000 (art. 323 as amended by Ley 1762 de 2015 art. 11; art. 345 as amended by Ley 1453 de 2011 art. 16), Art. 323 and art. 345, 2000-07-24 official text · verified 2026-10-27

9. From 1 January 2024, fines, sanctions and thresholds previously set in monthly minimum wages are calculated through their equivalent in Unidades de Valor Básico (UVB), at 2023 values (one 2023 minimum wage of COP 1,160,000 equals 116 UVB of COP 10,000); tax, customs and exchange control amounts in UVT are excluded. The 2026 UVB is COP 12,110 (Resolución MinHacienda 3488 of 31 December 2025), so each pre 2024 minimum wage cap is worth COP 1,404,760 in 2026.Ley 2294 de 2023 (Plan Nacional de Desarrollo), Art. 313, 2023-05-19 official text · verified 2026-10-27

Group	Regime	Threshold (UVB)	2026 COP	USD
Supersociedades supervised companies and foreign company branches	Unified system	4,929,017	59,690,395,870	about US$18.9 million
Real estate, precious metals, legal, accounting, construction, vehicle dealers (listed CIIU codes)	Unified system	3,696,762	44,767,787,820	about US$14.2 million
Virtual asset contributions or services	Unified system	12,323 of contributions or operations	149,231,530	about US$47,300
Listed RMM sectors (real estate, precious metals, legal, accounting, vehicles, pharmaceutical, construction, some manufacturing, mining and energy)	Minimum measures regime (RMM)	369,676 income or 616,127 assets	4,476,776,360 or 7,461,297,970	about US$1.4 million or about US$2.4 million

Who must comply (Supersociedades Circular Externa 100-000020 de 2026, Chapter IX; income or assets at 31 December of the prior year; 2026 UVB COP 12,110; USD at TRM COP 3,157.94)

Worked example

A foreign owned distributor SAS supervised by the Superintendencia de Sociedades closes 2026 with COP 65,000,000,000 in income, above the 4,929,017 UVB threshold (COP 59,690,395,870). If it was first obliged at 31 December 2026, it must have the board approved unified system, a compliance officer domiciled in Colombia, PEP and beneficial owner due diligence, a whistleblowing channel and SIREL reporting running by 31 May 2027. Each breach of Supersociedades instructions can draw a fine of up to COP 280,952,000 (about US$89,000) on the company and personal sanctions on officers.

Step by step

Each January, test prior year income and assets against the thresholds in UVB for the company's CIIU code.
If already running SAGRILAFT or PTEE, plan the migration to the unified Chapter IX system before 31 May 2027.
Have the board approve the system and appoint principal and alternate compliance officers who meet the requirements; file the non financial report within 15 business days.
Implement counterparty and beneficial owner due diligence with risk based refresh (yearly for high risk, every 2 years for others) and enhanced checks for PEPs and high risk countries.
Register with the UIAF SIREL system and report suspicious transactions immediately.
Set up a confidential, anonymous whistleblowing channel with non retaliation protections.
Keep documentation for the commercial books retention period.

Common traps

A company that drops below the thresholds remains obliged for 2 more years.
The compliance officer cannot be the legal representative, a director, a shareholder or the statutory auditor, and must live in Colombia.
For a foreign company branch, the officer is appointed by the competent body of the head office.
Using exchange or foreign trade operations increases money laundering prison terms by one third to one half.
Sanctions under Chapter IX can reach administrators, the compliance officer and the statutory auditor personally.

Sources

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