Countries › Colombia › Guide › 13. Regulation › Regulation in Colombia: competition and merger control, personal data, anti bribery liability, the unified AML and ethics compliance system, and environmental sanctions

Regulation in Colombia: competition and merger control, personal data, anti bribery liability, the unified AML and ethics compliance system, and environmental sanctions

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

Every business in Colombia answers to a few cross sector regulators: the SIC for competition, merger control and personal data; the Superintendencia de Sociedades for bribery and compliance programs; and the environmental authorities for licences and sanctions. Mergers between competitors or companies in the same value chain above the SIC's yearly thresholds need clearance before closing; personal data needs prior consent and cross border transfers are restricted; companies are liable for bribes paid by staff, contractors and group companies, with fines of up to 200,000 minimum wages and 20 year debarment. Since 2 July 2026 a single Supersociedades circular merges the AML (SAGRILAFT) and ethics (PTEE) programs into one system with thresholds in UVB, existing programs must adapt by 31 May 2027, and most old fine caps in minimum wages are now calculated in UVB.

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 published by the Superintendencia Financiera on the national open data portal. Conversions are for orientation only.

Key facts

Maximum competition fine per infringement for a company, in monthly minimum wages (or 150 percent of the profit if higher)	100000 monthly minimum wagesLey 1340 de 2009 art. 25, as of 2026-10-26 · in force
Maximum fixed competition fine for a company in 2026 pesos (11,600,000 UVB)	140476000000 COPLey 1340 de 2009 art. 25; Ley 2294 de 2023 art. 313; Res. MinHacienda 3488 de 2025, as of 2026-10-26 · in force
Alternative competition fine cap as a share of profit from the conduct	150 %Ley 1340 de 2009 art. 25, as of 2026-10-26 · in force
Maximum competition fine for an individual	2000 monthly minimum wagesLey 1340 de 2009 art. 26, as of 2026-10-26 · in force
Limitation period for competition sanctions	5 yearsLey 1340 de 2009 art. 27, as of 2026-10-26 · in force
Combined relevant market share below which a reportable deal only needs notification	20 %Ley 1340 de 2009 art. 9, as of 2026-10-26 · in force
SIC term to clear a deal or open phase two after the filing	30 daysLey 1340 de 2009 art. 10 num. 3, as of 2026-10-26 · in force
Deemed approval if no objection after the complete phase two filing	3 monthsLey 1340 de 2009 art. 10 num. 5, as of 2026-10-26 · in force
Maximum data protection fine per sanction	2000 monthly minimum wagesLey 1581 de 2012 art. 23, as of 2026-10-26 · in force
Maximum data protection fine in 2026 pesos (232,000 UVB)	2809520000 COPLey 1581 de 2012 art. 23; Ley 2294 de 2023 art. 313, as of 2026-10-26 · in force
Maximum suspension of data processing activities	6 monthsLey 1581 de 2012 art. 23, as of 2026-10-26 · in force
Total assets above which companies must register databases in the RNBD	100000 UVTDecreto 1074 de 2015 art. 2.2.2.26.1.2 (Decreto 90 de 2018), as of 2026-10-26 · in force
Deadline to register a new database in the RNBD	2 monthsDecreto 1074 de 2015 art. 2.2.2.26.3.1, as of 2026-10-26 · in force
Maximum administrative fine for a company for transnational bribery, plus the benefit	200000 monthly minimum wagesLey 1778 de 2016 art. 5 (Ley 2195 de 2022 art. 21), as of 2026-10-26 · in force
Maximum ban on contracting with the State for transnational bribery	20 yearsLey 1778 de 2016 art. 5, as of 2026-10-26 · in force
Maximum prison term for transnational bribery	15 yearsCódigo Penal art. 433 (Ley 1778 de 2016 art. 30), as of 2026-10-26 · in force
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 2026-10-26 · in force
Income or asset threshold for the unified system, listed sectors (real estate, precious metals, legal, accounting, construction, vehicles)	3696762 UVBSupersociedades Circular Externa 100-000020 de 2026 num. 9.5, as of 2026-10-26 · 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 2026-10-26 · 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 2026-10-26 · in force
Maximum environmental fine	100000 monthly minimum wagesLey 1333 de 2009 art. 40 (Ley 2387 de 2024 art. 17), as of 2026-10-26 · in force
Environmental fine reduction for confession before the proceeding opens	30 %Ley 2387 de 2024 art. 11, as of 2026-10-26 · in force
Unidad de Valor Básico (UVB) for 2026	12110 COPRes. MinHacienda 3488 de 2025; Ley 2294 de 2023 art. 313, as of 2026-10-26 · in force

The rule

1. Agreements that directly or indirectly aim to limit the production, supply, distribution or consumption of raw materials, products, goods or services, national or foreign, are prohibited, as are all practices, procedures or systems that tend to limit free competition or to set unfair prices. Ley 155 de 1959, Decreto 2153 de 1992 and Ley 1340 de 2009 form the general competition regime for all sectors and economic activities, with sector specific rules prevailing only on their specific subject. The Superintendencia de Industria y Comercio (SIC) is the sole national competition authority: it investigates, fines and takes the other administrative decisions on competition infringements, and supervises compliance with unfair competition rules.Ley 155 de 1959 (art. 1 as amended by Decreto 3307 de 1963); Ley 1340 de 2009, Ley 155 de 1959 art. 1; Ley 1340 de 2009 art. 4 and art. 6, 2009-07-24 official text · verified 2026-10-26

2. Companies engaged in the same economic activity or in the same value chain must inform the SIC before they merge, consolidate, acquire control or integrate in any legal form when, jointly or individually, their operating income in the previous fiscal year or their total assets at its close exceed the amounts the SIC sets each year (fixed during the previous year and not changed during the year they apply). If the parties meet either test but jointly hold less than 20 percent of the relevant market, the deal is deemed authorized and only a notification to the SIC is needed. Integrations involving only entities supervised by the Superintendencia Financiera are decided by that authority after an SIC competition analysis. The procedure: a pre evaluation filing; publication of a notice within 3 days so third parties can comment within 10 days; an SIC decision within 30 days to clear the deal or open a second phase; 15 days for the parties to file the full information; and if the SIC has not objected or set conditions 3 months after the complete filing, the deal is deemed authorized. Inactivity by the parties for more than 2 months counts as withdrawal. The SIC may order a deal reversed if it was not reported, closed before the review period ended, was objected to, or breached its conditions.
Cost to do it: The SIC charges a filing fee (tasa) under Ley 2010 de 2019 art. 152, updated for 2026 by SIC Resolución 4806 de 2026; the amounts were not available on an official page reachable in this session, so they are not stated here. Professional fees for a filing vary by provider.Ley 1340 de 2009 (art. 9 rewrites Ley 155 de 1959 art. 4), Art. 9, art. 10 and art. 13, 2009-07-24 official text · verified 2026-10-26

3. For each infringement of competition rules, including failing to report a reportable integration, breaching approval conditions, ignoring SIC information requests or obstructing an investigation, the SIC may fine each company up to 100,000 legal monthly minimum wages or, if greater, up to 150 percent of the profit the infringer obtained from the conduct. Individuals who collaborate in, facilitate, authorize, execute or tolerate infringements face fines of up to 2,000 monthly minimum wages, which the company, its parent or its group may not pay, insure or guarantee. Participants who report a cartel and collaborate with evidence may obtain total or partial exemption from the fine (leniency), except the instigator or promoter. The SIC's power to sanction expires 5 years after the conduct or, for continuing conduct, after its last act, unless the sanction has been notified.
Cost to do it: Caps set in minimum wages before 2024 are calculated through their 2023 UVB equivalent under Ley 2294 de 2023 art. 313: one 2023 minimum wage (COP 1,160,000) equals 116 UVB of COP 10,000. The SIC applies this conversion (for example a 16 September 2026 sanction of 100 minimum wages stated as 11,600 UVB, COP 140,476,000). At the 2026 UVB of COP 12,110 the corporate cap of 100,000 minimum wages is 11,600,000 UVB and the individual cap of 2,000 minimum wages is 232,000 UVB.
Example: Maximum fixed fine per infringement for a company: 11,600,000 UVB x COP 12,110 = COP 140,476,000,000, or 150 percent of the profit from the conduct if higher. Maximum for an individual: 232,000 UVB x COP 12,110 = COP 2,809,520,000. / About US$44.5 million for a company and about US$0.89 million for an individual.Ley 1340 de 2009 (art. 25 and 26 rewrite Decreto 2153 de 1992 art. 4 num. 15 and 16), Art. 14, art. 25, art. 26 and art. 27, 2009-07-24 official text · verified 2026-10-26

4. Colombia's personal data law applies to personal data in any database processed in Colombian territory, or by a controller or processor not established in Colombia when Colombian law applies to it under international rules or treaties. Processing requires the prior and informed authorization of the data subject, obtained by a means that can be checked later, except for listed cases such as information required by a public authority or court, public data, medical emergencies, historical, statistical or scientific uses authorized by law and civil registry data. Transferring personal data of any kind to countries without an adequate level of protection, as defined by SIC standards, is prohibited unless the data subject gave express and unequivocal authorization, or the transfer is a bank or securities transfer, is agreed under a treaty, is needed to perform a contract with the data subject (with authorization), or is legally required for the public interest or a judicial claim; in other cases the SIC issues a declaration of conformity.Ley Estatutaria 1581 de 2012, Art. 2, art. 9, art. 10 and art. 26, 2012-10-17 official text · verified 2026-10-26

5. The SIC may impose on private data controllers and processors fines of up to 2,000 monthly minimum wages, which may be repeated while the breach continues; suspension of the related processing for up to 6 months; temporary closure of processing if corrections are not made; and immediate and permanent closure of operations involving sensitive data. Databases with personal data must be entered in the Registro Nacional de Bases de Datos (RNBD) run by the SIC, together with the data processing policy, when the controller is a company or non profit entity with total assets above 100,000 UVT, or a public legal entity; databases created after the initial deadlines (which ended in 2018 and 2019) must be registered within 2 months of their creation, and registered information must be updated when there are substantial changes.
Cost to do it: At the 2026 UVT of COP 52,374, the RNBD asset threshold is COP 5,237,400,000 (about US$1.66 million). The 2,000 minimum wage fine cap is 232,000 UVB under Ley 2294 de 2023 art. 313.
Example: Maximum fine per sanction: 232,000 UVB x COP 12,110 = COP 2,809,520,000, repeatable while the breach continues. / About US$0.89 million per sanction.Ley Estatutaria 1581 de 2012; Decreto 1074 de 2015 (art. 2.2.2.26.1.2 and 2.2.2.26.3.1 as amended by Decreto 90 de 2018), Ley 1581 art. 23 and art. 25; Decreto 1074 de 2015 art. 2.2.2.26.1.2, 2.2.2.26.3.1 and 2.2.2.26.3.3, 2018-01-18 official text · verified 2026-10-26 · changed: Decreto 90 de 2018 (Diario Oficial 50.480, 18 January 2018) limited mandatory RNBD registration to companies and non profit entities with assets above 100,000 UVT and to public legal entities.

6. Companies are administratively liable when, through employees, contractors, managers or shareholders (their own or of a subsidiary), they give, offer or promise a foreign public official money, anything of pecuniary value or any other benefit in exchange for an act or omission related to an international business transaction. Parent companies are liable for subsidiaries' bribery done with their consent or tolerance, and subsidiaries for bribery by the parent or group companies for their benefit. The Superintendencia de Sociedades investigates and sanctions, including conduct abroad when the company or branch responsible or benefiting is domiciled in Colombia. Sanctions: a fine of up to 200,000 monthly minimum wages plus the greater of the benefit obtained or sought; a ban on contracting with the Colombian State for up to 20 years; publication of the decision for up to 1 year; and a 10 year ban on government incentives or subsidies; the sanction is entered in the company's commercial registry. The Superintendencia de Sociedades decides which companies must adopt transparency and business ethics programs. Individuals face 9 to 15 years in prison for transnational bribery (Código Penal art. 433).
Cost to do it: The 200,000 minimum wage cap equals 23,200,000 UVB under Ley 2294 de 2023 art. 313.
Example: Maximum fixed fine: 23,200,000 UVB x COP 12,110 = COP 280,952,000,000, plus the benefit obtained or sought. / About US$89.0 million plus the benefit.Ley 1778 de 2016, as amended by Ley 2195 de 2022 (art. 19, 20, 21 and 25), Ley 1778 art. 2, art. 3, art. 5, art. 23 and art. 30, 2022-01-18 official text · verified 2026-10-26 · changed: Ley 2195 de 2022 (Diario Oficial 51.921, 18 January 2022) extended liability to bribery through contractors and by parent or group companies, raised the fine to 200,000 minimum wages plus the benefit, extended the contracting ban to 20 years and gave the Superintendencia de Sociedades jurisdiction over conduct abroad by Colombian domiciled companies.

7. Companies, branches of foreign companies, members of consortia, State owned commercial companies and non profit entities domiciled in Colombia are subject to administrative sanctions when one of their managers or employees is finally convicted (or receives a firm principle of opportunity) for crimes against public administration, the environment, the economic and social order, terrorist financing and other listed offences, the entity benefited or sought to benefit, and it consented to or tolerated the conduct considering its risk controls. The sector supervisor imposes the sanctions, which include fines of up to 200,000 monthly minimum wages plus the greater of the benefit obtained or sought (with up to 10 percent assignable to the company's ethics program) and the ban on public contracting. Transnational bribery stays under the special Ley 1778 regime.Ley 1474 de 2011 (art. 34 as amended by Ley 2195 de 2022 art. 2; art. 34-1 and 34-2 added by art. 3 and 4), Ley 1474 de 2011 art. 34, art. 34-1 and art. 34-2, 2022-01-18 official text · verified 2026-10-26

8. The Superintendencia de Sociedades issued a new Circular Básica Jurídica on 2 July 2026, in force on publication, which merges the former anti money laundering system (SAGRILAFT) and the transparency and business ethics program (PTEE) into a single Sistema de Autocontrol y Gestión de Riesgos LA/FT/FP y C/ST covering money laundering, terrorist and proliferation financing, corruption and transnational bribery. It applies to companies, sole proprietorships and branches of foreign companies supervised by the Superintendencia de Sociedades (and not under another special supervisor) with total income or total assets of 4,929,017 UVB or more at 31 December of the previous year; to real estate agents, precious metals traders, legal and accounting services, building and civil works construction and vehicle dealers at 3,696,762 UVB; and to virtual asset contributions or services at 12,323 UVB of contributions or operations (with income or asset tests for service providers). Other listed sectors (including pharmaceutical, infrastructure, manufacturing and mining and energy) must apply a Régimen de Medidas Mínimas. Obliged companies must appoint a principal and an alternate compliance officer with a professional degree, at least 1 year of relevant experience, accredited training (refreshed at least every 3 years) and domicile in Colombia, serving no more than 10 obliged companies outside a group, and must report suspicious operations to the UIAF immediately through SIREL. Companies already obliged must adapt by 31 May 2027, and companies that newly qualify at 31 December must implement the system by 31 May of the next year; a company that falls below the thresholds stays obliged for 2 more years.
Cost to do it: In 2026 pesos (UVB COP 12,110) the general threshold is COP 59,690,395,870 (about US$18.9 million) and the sector threshold COP 44,767,787,820 (about US$14.2 million). Compliance officer and system costs depend on the provider and are not regulated.
Example: A Supersociedades supervised trading company with COP 65,000,000,000 of 2026 income newly exceeds the 4,929,017 UVB test at 31 December 2026 and must have its system running by 31 May 2027. / Income of about US$20.6 million against a general threshold of about US$18.9 million.Superintendencia de Sociedades, Circular Externa 100-000020 de 2026 (Circular Básica Jurídica), Chapter IX, Num. 9.4, 9.5, 9.6, 9.9.2, 9.9.3, 9.19, 9.27 to 9.30, 2026-07-02 official text · verified 2026-10-26 · changed: Circular Externa 100-000020 de 2026 (2 July 2026) replaced the Circular Básica Jurídica and repealed Circulares 100-000016 de 2020 (SAGRILAFT), 100-000011 de 2021 (PTEE) and 100-300000 de 2024 among others, unifying both programs in Chapter IX with thresholds in UVB; existing programs remain valid until 31 May 2027.

9. Any act or omission that breaches environmental rules or environmental administrative acts is an environmental infringement, as is causing environmental damage; the offender's fault or intent is presumed and the offender bears the burden of disproving it. The competent environmental authority (the one that grants the licence or permit, or the one with jurisdiction where the infringement occurred) may impose, as main or accessory sanctions, a written warning; fines of up to 100,000 monthly minimum wages, valued at the wage in force on the date of the sanction; temporary or permanent closure; revocation of the environmental licence, permit or concession; demolition at the offender's cost; confiscation; and restitution of species, without prejudice to restoration duties and civil, criminal and other liability. The authority must decide within 80 days after the defence or closing arguments term. An offender who confesses gets a 30 percent fine reduction before the proceeding opens, or 15 percent before charges are filed, except in flagrante cases.
Cost to do it: With the 2026 minimum wage of COP 1,750,905 (Decreto 1469 de 2025), the cap is COP 175,090,500,000.
Example: A COP 1,000,000,000 environmental fine falls to COP 700,000,000 if the company confesses before the proceeding opens, or COP 850,000,000 if it confesses before charges. / About US$316,613 falling to about US$221,629 or US$269,121; the cap is about US$55.4 million.Ley 1333 de 2009, as amended by Ley 2387 de 2024 (art. 6, 9, 11 and 17), Ley 1333 art. 5, art. 27 and art. 40; Ley 2387 art. 11, 2024-07-25 official text · verified 2026-10-26 · changed: Ley 2387 de 2024 (Diario Oficial 52.828, 25 July 2024) raised the environmental fine cap to 100,000 monthly minimum wages, set the confession discounts, cut the decision term to 80 days and requires that a fine normally be imposed together with another sanction.

10. From 1 January 2024 all charges, sanctions, fines, fees and financial or asset thresholds previously set in minimum wages or UVT are calculated through their equivalent in Unidades de Valor Básico (UVB), using 2023 values (UVB COP 10,000); amounts that became final before 1 January 2024 stay in minimum wages or UVT, and tax, customs and exchange control amounts in UVT are excluded. The Ministry of Finance publishes the UVB each year, indexed to CPI without food and regulated prices; for 2026 it is COP 12,110 under Resolución 3488 of 31 December 2025, in force from 1 January 2026.
Cost to do it: One 2023 monthly minimum wage of COP 1,160,000 (Decreto 2613 de 2022) equals 116 UVB, which is COP 1,404,760 at the 2026 UVB, against a 2026 minimum wage of COP 1,750,905.
Example: A 2,000 minimum wage cap: 2,000 x 116 = 232,000 UVB x COP 12,110 = COP 2,809,520,000, instead of COP 3,501,810,000 at the 2026 wage. / About US$0.89 million instead of about US$1.11 million.Ley 2294 de 2023 (Plan Nacional de Desarrollo); Ministerio de Hacienda Resolución 3488 de 2025, Ley 2294 art. 313 and par. 2 to 4; Res. 3488 de 2025 art. 1, 2025-12-31 official text · verified 2026-10-26

Area	Regulator	Main law	Maximum fine for a company	2026 COP	USD
Competition and merger control	SIC	Ley 155 de 1959; Ley 1340 de 2009	100,000 minimum wages or 150% of profit	140,476,000,000	about 44.5 million
Personal data	SIC	Ley 1581 de 2012	2,000 minimum wages, repeatable	2,809,520,000	about 0.89 million
Transnational bribery	Superintendencia de Sociedades	Ley 1778 de 2016 (Ley 2195 de 2022)	200,000 minimum wages plus benefit	280,952,000,000 plus benefit	about 89.0 million plus benefit
Domestic corruption linked crimes	Sector supervisor	Ley 1474 de 2011 art. 34 to 34-2	200,000 minimum wages plus benefit	280,952,000,000 plus benefit	about 89.0 million plus benefit
Environment	ANLA or regional environmental authority	Ley 1333 de 2009 (Ley 2387 de 2024)	100,000 minimum wages at the sanction date wage	175,090,500,000	about 55.4 million

Main regulators, laws and maximum penalties for companies (2026 pesos; minimum wage caps set before 2024 converted at 116 UVB per wage and the 2026 UVB of COP 12,110 under Ley 2294 de 2023 art. 313; USD at TRM COP 3,158.43)

Group	Threshold (UVB)	2026 COP	USD
Companies and foreign company branches supervised by Supersociedades	4,929,017	59,690,395,870	about 18.9 million
Real estate agents, precious metals traders, legal and accounting services, building and civil works construction, vehicle dealers (listed CIIU codes)	3,696,762	44,767,787,820	about 14.2 million
Companies receiving virtual asset contributions, or providing virtual asset services for others (plus income or asset tests for service providers)	12,323 of contributions or operations	149,231,530	about 47,249
Special regimes: SAPAC, payroll lending operators, multilevel marketing, livestock funds, supervised factoring companies	No size test

Who must run the unified LA/FT/FP and C/ST compliance system (Supersociedades Circular Externa 100-000020 de 2026, Chapter IX); income or assets at 31 December of the previous year; pesos at the 2026 UVB of COP 12,110

Worked example

Two Colombian beverage distributors plan to merge. Both are in the same activity and one exceeds the SIC's 2026 income threshold, so the deal must be reported; if their combined relevant market share is below 20 percent, a notification is enough and the deal is deemed authorized, otherwise they file for pre evaluation, the SIC has 30 days to clear it or open phase two, and if it opens phase two and does not object within 3 months of the complete filing, the deal is deemed approved. Closing early or without reporting exposes each company to a fine of up to COP 140,476,000,000 (about US$44.5 million) and a possible reversal order.
A US software group's Colombian SAS with COP 6,000,000,000 of assets (above the 100,000 UVT threshold of COP 5,237,400,000, about US$1.66 million) must register its customer and employee databases in the RNBD with its data policy, obtain prior consent, and check that each transfer to its US cloud provider fits a Ley 1581 art. 26 exception or an SIC declaration of conformity; a sanction can reach COP 2,809,520,000 (about US$0.89 million) and be repeated while the breach continues.
A distributor of a foreign parent pays a customs official abroad through a local agent to speed a tender. Under Ley 1778, the Colombian company can be fined up to COP 280,952,000,000 (about US$89.0 million) plus the benefit sought, barred from public contracts for up to 20 years, and the parent can be liable if it consented to or tolerated the payment.

Step by step

Before any acquisition, joint venture or asset deal with a competitor, supplier or customer, test the parties' prior year income and assets against the SIC's yearly threshold and estimate the combined relevant market share; build pre evaluation (30 days) and a possible 3 month phase two into the timetable and do not close before clearance.
Run an antitrust review of distribution, pricing and information exchange arrangements, and train sales teams on cartel and bid rigging risks; if a problem surfaces, assess a leniency application with counsel quickly, since benefits depend on timing.
Map every database with personal data, adopt and publish a data processing policy, collect prior consent in a verifiable form, register the databases in the RNBD if assets exceed 100,000 UVT (within 2 months for new databases), and document the legal basis for each international transfer.
Check whether the company is supervised by the Superintendencia de Sociedades and whether its income or assets at 31 December reach the Circular Externa 100-000020 de 2026 thresholds; if so, design and approve the unified LA/FT/FP and C/ST system, appoint a principal and alternate compliance officer who meet the requirements, register with SIREL and report suspicious operations to the UIAF immediately.
If the company already runs SAGRILAFT or PTEE, plan the migration to the unified Chapter IX system before 31 May 2027; the existing programs remain valid until then.
Before starting works, confirm which environmental licences and permits apply and which authority grants them; if a breach occurs, weigh a confession before the proceeding opens (30 percent discount) or before charges (15 percent).
Recalculate fine exposure in UVB each January when the Ministry of Finance publishes the new value, and convert pre 2024 minimum wage caps at 116 UVB per wage.

Common traps

The merger threshold changes every year and is set by the SIC, and a reportable deal closed without clearance can be fined and reversed even if it would have been approved.
The 20 percent shortcut still requires a notification to the SIC; it removes the review, not the filing.
Competition fines for individuals cannot be paid, insured or guaranteed by the employer, its parent or any group company, so D&O style indemnities do not cover them.
Ley 1581 reaches controllers abroad when Colombian law applies to them, and international transfers to countries without adequate protection are prohibited unless an exception applies; cloud and group data flows need a documented basis.
Bribery liability is strict on structure: payments by contractors and agents count, a parent is liable for subsidiaries it tolerated, and subsidiaries are liable for group payments made for their benefit; sanctions are entered in the commercial registry and show on the company's certificate.
The 2 July 2026 circular repealed the old SAGRILAFT and PTEE circulars; a company that drops below the thresholds stays obliged for 2 more years, and a compliance officer must live in Colombia.
Environmental fault is presumed: the company must prove it was not at fault, and a fine normally comes with another sanction such as closure or licence revocation.
Old fine caps written in minimum wages are calculated in UVB under Ley 2294 de 2023 art. 313, but Ley 2387 de 2024 expressly values environmental fines at the minimum wage in force on the sanction date, so the two methods coexist.

Sources

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