CMC Abogados

New compliance obligations

External Circular 100-000020 of 2026: SAGRILAFT and PTEE are unified into a single system

Colombia's Superintendency of Companies merged SAGRILAFT and PTEE into a single self-control and risk management system. More sectors are now covered, Compliance Officer requirements are stricter and thresholds move to UVB. Deadline: May 31, 2027.

We are sharing with you a summary of External Circular 100-000020 of July 2026, issued by the Superintendency of Companies (Superintendencia de Sociedades), which introduces significant changes regarding the prevention of money laundering, terrorist financing, corruption, and transnational bribery.

Main developments and obligations

  1. What changed?

    The Superintendency unified into a single chapter (the new Chapter IX of its Basic Legal Circular) the two programs that had previously operated separately: SAGRILAFT (in effect since 2020) and PTEE (in effect since 2021). From now on, both are integrated into a single “Self-Control and Risk Management System for ML/TF/WMDF and TB/C” (Sistema de Autocontrol y Gestión de Riesgos LA/FT/FP y C/ST).

    In practice, this means a single compliance policy, a single procedures manual, and a single Compliance Officer (with the corresponding alternate) to manage all risks: money laundering, terrorist financing, financing of weapons of mass destruction, corruption, and transnational bribery.

  2. Points that may be of interest to you

    More sectors are now subject to the obligation
    Construction, manufacturing, pharmaceutical, mining-energy, and vehicle trading companies may now be required to implement the system, even if they do not hold contracts with the State.
    The Compliance Officer must meet stricter requirements, and an Alternate Compliance Officer is now mandatory.
    Minimum experience of one year (previously six months), with knowledge updates required every three years.
    Two new policies are required
    A lobbying policy and a Code of Ethics as a standalone document.
    Due diligence on Politically Exposed Persons (PEPs) is expanded
    It now also covers their spouse, close family members, and associated partners.

  3. Minimum Measures Regime: simplified obligations

    Not all obligated companies must implement the full system. The circular provides for a Minimum Measures Regime (RMM), aimed at companies, branches, and sole proprietorships whose income or assets exceed the RMM thresholds but fall short of the general regime threshold, as well as certain Designated Non-Financial Businesses and Professions (real estate agents, dealers in precious metals and stones, and legal and accounting services).

    Under this regime, the obligations are considerably lighter than those of the full system: an extensive policy and manual are not required, the legal representative (and not necessarily a dedicated Compliance Officer) may take on responsibility for designing, approving, and implementing the measures, and training, due diligence, and reporting are applied in a simplified manner proportional to the company's size and risk.

    In other words, if your company falls between the RMM threshold and the general regime threshold, it will likely only need to adopt these simplified measures rather than the full system — representing a considerably lighter compliance burden. We would be glad to assess which regime applies to your company once we know your income and asset figures.

  4. Thresholds in UVB (Basic Value Unit)

    The new circular measures the applicability thresholds in UVB, rather than minimum wages. With the 2026 UVB currently in effect ($12,110 COP, Resolution 3488 of 2025 of the Ministry of Finance) and the current exchange rate (TRM), the main thresholds are approximately equivalent to:

    General regime (full system)

    Threshold in UVB
    4,929,017 UVB
    Approx. in COP
    $59,690 million
    Approx. in USD
    USD 18.3 million

    Specific sectors (real estate, precious metals, legal, accounting)

    Threshold in UVB
    3,696,762 UVB
    Approx. in COP
    $44,768 million
    Approx. in USD
    USD 13.7 million

    RMM sectors (Minimum Measures Regime) — income (construction, manufacturing, pharmaceutical, mining-energy, vehicles)

    Threshold in UVB
    369,676 UVB
    Approx. in COP
    $4,477 million
    Approx. in USD
    USD 1.37 million

    RMM sectors (Minimum Measures Regime) — assets

    Threshold in UVB
    616,127 UVB
    Approx. in COP
    $7,461 million
    Approx. in USD
    USD 2.29 million

    Virtual assets (contributions received)

    Threshold in UVB
    12,323 UVB
    Approx. in COP
    $149.2 million
    Approx. in USD
    USD 45,700

  5. Who does it apply to, and within what timeframe?

    Already has SAGRILAFT and/or PTEE

    What you must do
    Merge and update your system in accordance with the new guidelines, and verify that your Compliance Officer meets the new requirements.
    Deadline
    No later than May 31, 2027. In the meantime, current programs remain valid.

    Has never been obligated

    What you must do
    If your company belongs to the construction, manufacturing, pharmaceutical, mining-energy, or vehicle trading sectors, check whether this change makes it obligated for the first time.
    Deadline
    No later than May 31 of the year following the one in which it became an obligated party.

    In both cases, it is recommended not to wait until the deadline, given the time required for the design, board approval, and implementation of the system.

We are here to help

At CMC Abogados, we have a team specialized in regulatory compliance that can assist you in diagnosing, updating, or designing your system in accordance with this new circular. We remain available for any questions.

Do you need to review a specific case?

Talk to our Compliance team
Compliance Team — CMC Abogados S.A.S.