Knowing SAGRILAFT and PTEE terms precisely makes communication between the Compliance Officer and their team easier, and avoids confusing concepts that the regulation distinguishes.
The system and its programs
- SAGRILAFT — Self-Control and Comprehensive Risk Management System for Money Laundering, Terrorist Financing and Financing of the Proliferation of Weapons of Mass Destruction.
- PTEE — Corporate Transparency and Ethics Program. It operates alongside SAGRILAFT but is a separate program, focused on corruption and transnational bribery.
- Minimum measures regime — A reduced version of SAGRILAFT for companies that exceed a lower threshold.
Authorities
- Superintendencia de Sociedades — Supervises SAGRILAFT in the non-financial real sector.
- UIAF — Financial Information and Analysis Unit. It receives reports; it does not supervise or sanction.
- Superintendencia Financiera — Supervises regulated entities in the financial sector, under its own regime.
Roles and obligations
- Compliance Officer — Responsible for ensuring that SAGRILAFT works. Must be appointed by the highest corporate body.
- Counterparty — Any person the company has a relationship with: customer, supplier, employee, partner or contractor. In Colombia the term is broader than “customer”.
- Ultimate beneficial owner — The individual who ultimately controls or benefits from a legal entity.
- Enhanced due diligence — Reinforced measures for higher-risk counterparties, such as PEPs.
- ROS (STR) — Suspicious Transaction Report filed with the UIAF. Filing it does not constitute a criminal complaint or an accusation.
- Risk matrix — A tool that cross-references risk factors and associated risks to measure inherent and residual risk.
- SMMLV — Current legal monthly minimum wage. It is the unit in which the thresholds that determine the obligation are expressed.
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