Is Your Company Obligated to Implement SAGRILAFT? The 4,929,017 UVB Threshold

In Colombia, unlike Ecuador, the obligation to implement an anti-money laundering system in the real sector does not arise from the line of business but from the size of the company. The right question is not "what do I do?" but "how much do I earn and what assets do I hold?". Here is how External Circular 100-000020 of 2026 answers it.

The general threshold

Companies, single-member companies and branches of foreign companies supervised or controlled by the Superintendencia de Sociedades must implement SAGRILAFT when their total revenues or assets are equal to or above 4,929,017 UVB (basic value units) as of December 31 of the previous year. Exceeding either one is enough: revenues or assets.

Sectors with their own thresholds

Some sectors have their own, lower thresholds: this is the case for real estate agents and the trade in precious metals and stones. If your company operates in one of those sectors, it may be obligated even without reaching the general threshold.

The Minimum Measures Regime

The circular also provides a Minimum Measures Regime for companies in certain sectors with lower revenues or assets: a lighter regime under which the legal representative is accountable. Falling below the general threshold does not always mean falling outside the obligation.

If your company is obligated

The system requires appointing a Compliance Officer, building the AML/CTF/PF risk matrix, adopting a manual with due diligence policies, knowing your customers, suppliers and ultimate beneficial owners, reporting suspicious transactions to the UIAF, and training your team. Thresholds are also reviewed: it pays to run the numbers again at every year-end close. If your supervisor is not the Superintendencia de Sociedades, check which system applies to you.

Not sure whether your company exceeds the threshold or which regime it falls under? Our SAGRILAFT and PTEE consulting starts exactly there. Contact us.