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Acevedo & Acevedo Abogados by Interpoint Legal

Practice area

Compliance and Corporate Integrity

Colombian law requires companies above certain thresholds to implement anti-money-laundering (SAGRILAFT) and anti-bribery (PTEE) regimes, merged into Chapter IX by External Circular 100-000020 of 2026, with a compliance deadline of 31 May 2027. We design, implement and audit these systems and respond to regulatory investigations.

Scope

Compliance and Corporate Integrity services

  • Adequacy to the merged Chapter IX (External Circular 100-000020 of 2026)
  • SAGRILAFT anti-money-laundering system design and implementation
  • PTEE transparency and business ethics programmes
  • Personal data protection policies and procedures
  • Codes of ethics and anti-corruption and anti-bribery policies
  • Information security policies under Colombian ICT standards
  • Risk matrices and whistleblowing channels
  • Compliance training for boards and senior management
  • Response to Superintendence of Companies and SIC requirements
  • OECD procedures and policy training

Who handles it

Lawyers in this practice

Common questions

Questions about compliance and corporate integrity

Which companies must implement SAGRILAFT in Colombia?
Companies supervised by the Superintendence of Companies that exceed the revenue or asset thresholds of Chapter IX, as set by External Circular 100-000020 of 2 July 2026. That circular merged the AML and anti-bribery regimes and now states thresholds in UVB units rather than minimum wages. The compliance deadline is 31 May 2027.
How does SAGRILAFT differ from a PTEE programme?
SAGRILAFT addresses money laundering, terrorist financing and proliferation financing. PTEE addresses transnational bribery and corruption. Since External Circular 100-000020 of 2026 they share Chapter IX, but they remain separate regimes with different obligated parties and criteria: each test is run independently.
What is the exposure for a foreign parent company?
Beyond penalties on the Colombian subsidiary, the Superintendence may impose personal sanctions on directors and the compliance officer. For groups subject to the FCPA or the UK Bribery Act, a Colombian compliance failure also becomes a reportable issue at group level.

Need counsel on compliance and corporate integrity?

An initial conversation is enough to establish whether the matter calls for ongoing counsel, a one-off intervention, or simply a second reading.

Calle 100 # 8A-37, Oficina 701, Torre A · Bogotá · Mon–Fri, 8:00 a.m. – 6:00 p.m.