Countries › Colombia › Guide › 13. Regulation › Anti bribery in Colombia: corporate liability for transnational bribery (Ley 1778), sanctions for domestic corruption offences, private corruption and self reporting benefits

Anti bribery in Colombia: corporate liability for transnational bribery (Ley 1778), sanctions for domestic corruption offences, private corruption and self reporting benefits

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

A company domiciled in Colombia is administratively liable when its employees, contractors, managers or shareholders, or those of a subsidiary, bribe a foreign public official in an international business transaction; parents answer for subsidiaries they tolerated and subsidiaries for group bribes made for their benefit. The Superintendencia de Sociedades can fine up to 200,000 pre 2024 minimum wages (COP 280,952,000,000, about US$89.0 million) plus the benefit sought, bar public contracting for up to 20 years and ban subsidies for 10, with a 10 year limitation period; similar sanctions apply when a manager is convicted of domestic corruption and the company benefited. Self reporting before an investigation can earn full exemption, later reporting up to 50 percent, and an effective ethics program and pre deal due diligence reduce fines; individuals face 9 to 15 years in prison for transnational bribery and 4 to 8 for private corruption.

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

Maximum administrative fine for a company for transnational bribery in 2026 pesos (23,200,000 UVB), plus the benefit	280952000000 COPLey 1778 de 2016 art. 5 (Ley 2195 de 2022 art. 21); Ley 2294 de 2023 art. 313, as of 2026-10-27 · in force
Maximum ban on contracting with the State for transnational bribery	20 yearsLey 1778 de 2016 art. 5, as of 2026-10-27 · in force
Limitation period for transnational bribery sanctions against companies	10 yearsLey 1778 de 2016 art. 9, as of 2026-10-27 · in force
Maximum exemption when self reporting after the proceeding started	50 %Ley 1778 de 2016 art. 19 par., as of 2026-10-27 · in force
Maximum prison term for transnational bribery	15 yearsCódigo Penal art. 433 (Ley 1778 de 2016 art. 30), as of 2026-10-27 · in force
Maximum prison term for private corruption (with economic harm to the entity)	10 yearsCódigo Penal art. 250A (Ley 1474 de 2011 art. 16), as of 2026-10-27 · in force

The rule

1. Legal entities are sanctioned when, through one or more employees, contractors, managers or shareholders, their own or of any subordinate entity, they give, offer or promise a foreign public official, directly or indirectly, money, anything of pecuniary value or any other benefit, in exchange for an act, omission or delay related to the official's functions and to an international business or transaction. Parent companies are liable when a subordinate does so with their consent or tolerance, and subordinates are liable when the parent or another group company does so for their benefit. The rule extends to branches of companies operating abroad and State owned companies, but not to conduct by a shareholder without control. Foreign public officials include anyone holding legislative, administrative or judicial office, exercising a public function for a foreign State or State owned company, and officials of public international organizations.Ley 1778 de 2016 (art. 2 as amended by Ley 2195 de 2022 art. 19), Art. 2, 2022-01-18 official text · verified 2026-10-27

2. The Superintendencia de Sociedades investigates and sanctions transnational bribery, including conduct abroad, provided the legal entity or foreign company branch responsible or benefited is domiciled in Colombia. The preliminary inquiry lasts up to one year (extendable one year for mutual legal assistance), and the power to sanction lapses 10 years after the conduct, interrupted by the statement of charges, after which a new 10 year term runs.Ley 1778 de 2016 (art. 3 as amended by Ley 2195 de 2022 art. 20), Art. 3, 9 and 11, 2016-02-02 official text · verified 2026-10-27

3. Sanctions: (1) a fine of up to 200,000 monthly minimum wages, plus the greater of the benefit obtained or sought, part of which may be ordered spent on the ethics program; (2) a ban on contracting with the Colombian State for up to 20 years; (3) publication of an extract of the decision in mass media and on the company's website for up to 1 year at its cost; and (4) a 10 year ban on government incentives or subsidies. The final sanction is entered in the commercial registry and appears on the company's certificate of existence.
Cost to do it: Maximum fine in 2026: COP 280,952,000,000 (about US$89.0 million) plus the benefit.
Example: 200,000 pre 2024 minimum wages x 116 UVB x COP 12,110 = COP 280,952,000,000, plus the benefit sought. / About us$89.0 million plus the benefit.Ley 1778 de 2016 (art. 5 as amended by Ley 2195 de 2022 art. 21), Art. 5, 2022-01-18 official text · verified 2026-10-27

4. Liability follows the business: if the offending company is absorbed in a merger, the absorbing or new company bears the sanction; in a spin off, all participating companies are jointly liable; and when control is transferred, the acquirer is subject to the sanctions.Ley 1778 de 2016, Art. 6, 2016-02-02 official text · verified 2026-10-27

5. Sanctions are graduated by the benefit obtained or sought, financial capacity, repetition, obstruction, use of intermediaries to hide the conduct, express admission before evidence is ordered, the existence, execution and effectiveness of transparency and business ethics programs, compliance with interim measures, adequate due diligence before a merger, spin off, reorganization or acquisition of control, and having reported the conduct of employees, the legal representative or shareholders to the authorities.Ley 1778 de 2016, Art. 7, 2016-02-02 official text · verified 2026-10-27

6. The Superintendencia de Sociedades may grant total or partial exemption to participants who report the infringement and cooperate with information and evidence, considering the quality and timing of the information, whether it was already known or under investigation by other national or foreign authorities, and the remedial measures adopted. Full exemption requires reporting before the administrative proceeding starts and not having exercised the rights arising from the contract obtained through the bribe; when information comes later, exemption is partial and capped at 50 percent.Ley 1778 de 2016 (art. 19 as amended by Ley 2195 de 2022 art. 22), Art. 19, 2022-01-18 official text · verified 2026-10-27

7. Legal entities, foreign company branches, members of consortia, State owned companies and non profits domiciled in Colombia are subject to administrative sanctions when (i) a manager or officer is finally convicted, or receives a firm principle of opportunity, for crimes against public administration, the environment, the economic and social order, terrorist financing or organized crime financing, offences in Ley 1474 de 2011 or crimes affecting public assets; (ii) the entity benefited or sought to benefit; and (iii) it consented to or tolerated the conduct. Each sector supervisor sanctions its supervised entities, with fines of up to 200,000 minimum wages plus the benefit, contracting bans, publication up to 5 times and on the website for 6 months to 1 year, a 10 year subsidy ban and removal of the convicted managers and of those who tolerated the conduct. The limitation period is 10 years from the final conviction. The SIC is excluded, and transnational bribery stays under Ley 1778.
Cost to do it: Maximum fine in 2026: COP 280,952,000,000 (about US$89.0 million) plus the benefit.Ley 1474 de 2011 (art. 34 and art. 34-1 to 34-7 as replaced and added by Ley 2195 de 2022 art. 2 to 9), Art. 34, 34-1, 34-2 and 34-6, 2022-01-18 official text · verified 2026-10-27

8. Supervised legal entities must adopt transparency and business ethics programs with internal audit mechanisms. The Superintendencia de Sociedades sets their content and who must adopt them based on sector, risks, assets, income, employees and corporate purpose; since 2 July 2026 it does so through the unified LA/FT/FP and C/ST system in Chapter IX of its Circular Básica Jurídica (Circular Externa 100-000020 de 2026).Ley 1778 de 2016 (art. 23 as amended by Ley 2195 de 2022 art. 25); Ley 1474 de 2011 art. 34-7; Supersociedades Circular Externa 100-000020 de 2026, Ley 1778 art. 23; Circular Chapter IX, 2026-07-02 official text · verified 2026-10-27

9. Individuals who give, promise or offer a foreign public official money or another benefit in connection with an international business transaction face 9 to 15 years in prison, disqualification for the same term and a fine of 650 to 50,000 monthly minimum wages. Private sector bribery (corrupción privada), offering or accepting an unjustified benefit to or by directors, managers, employees or advisers of a company, association or foundation to its detriment, carries 4 to 8 years in prison and a fine of 10 to 1,000 minimum wages, rising to 6 to 10 years if the entity suffers economic harm.Código Penal, Ley 599 de 2000 (art. 433 as rewritten by Ley 1778 de 2016 art. 30; art. 250A added by Ley 1474 de 2011 art. 16), Art. 433 and art. 250A, 2016-02-02 official text · verified 2026-10-27

10. 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

Feature	Transnational bribery (Ley 1778 de 2016)	Domestic corruption linked crimes (Ley 1474 de 2011 art. 34)
Trigger	Bribe to a foreign official by employees, contractors, managers or shareholders (or of a subsidiary)	Final conviction or principle of opportunity of a manager or officer, benefit to the entity, consent or tolerance
Authority	Superintendencia de Sociedades	Each sector supervisor (not the SIC)
Maximum fine	200,000 minimum wages plus benefit, COP 280,952,000,000	200,000 minimum wages plus benefit, COP 280,952,000,000
Other sanctions	Up to 20 year contracting ban, publication, 10 year subsidy ban	Contracting ban, publication, 10 year subsidy ban, removal of managers
Limitation	10 years from the conduct	10 years from the final conviction

Two corporate liability regimes (fines at 116 UVB per pre 2024 minimum wage and the 2026 UVB of COP 12,110; USD at TRM COP 3,157.94)

Worked example

A Colombian engineering SAS wins a contract in a neighbouring country after its local agent pays a ministry official. Even though the payment happened abroad and was made by a contractor, the SAS is liable under Ley 1778 art. 2: it faces a fine of up to COP 280,952,000,000 (about US$89.0 million) plus the value of the contract benefit, a ban of up to 20 years on Colombian public contracts and entry of the sanction in its commercial registry. If it self reports before the Superintendencia opens a proceeding and has not exercised rights under the tainted contract, it can obtain full exemption.
A foreign buyer acquires control of a Colombian company that bribed officials two years earlier. Under Ley 1778 art. 6 the acquirer is exposed to the sanctions; documented pre closing due diligence is a statutory mitigating factor under art. 7 num. 9.

Step by step

Map third parties that interact with foreign or domestic officials (agents, customs brokers, consultants) and run risk based due diligence before engagement.
Adopt or update the ethics program under the Supersociedades unified system if thresholds are met; even if not obliged, a working program mitigates fines.
Include anti bribery representations, audit rights and termination rights in agency and distribution contracts.
In M&A, run anti corruption due diligence on the target and its subsidiaries and keep the report as evidence.
If a payment is discovered, assess self reporting quickly: full exemption requires reporting before a proceeding starts and not using the contract rights obtained.

Common traps

Payments by contractors and agents count as the company's own conduct.
A parent is liable for a subsidiary's bribes it tolerated, and a subsidiary for group bribes made for its benefit.
Buying control of a company transfers its bribery exposure to the acquirer.
The limitation period is 10 years and restarts for another 10 once charges are stated.
A conviction of one manager for a domestic corruption crime can trigger corporate fines, a contracting ban and the removal of other managers who tolerated it.

Sources

← Personal data protection in Colombia: consent, sensitive data, data subject requests, database registry (RNBD), international transfers and SIC sanctionsAML 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 →