Implementing SAGRILAFT in mining and gold trading
Companies that extract or trade gold, metals or coal must implement SAGRILAFT (the self-control and comprehensive AML/CTF risk management system) or the Minimum Measures Regime. They are supervised by the Superintendence of Companies (Supersociedades). The governing rule is Chapter IX of its Basic Legal Circular (CBJ), as amended by External Circular 100-000020 of 2026.
Since that circular, SAGRILAFT and the Business Transparency and Ethics Program (PTEE) form a single system: the "Self-Control and Risk Management System for ML/TF/PF and C/TB" (LA/FT/FP y C/ST in Spanish). It covers money laundering, terrorist and proliferation financing, corruption and transnational bribery. If your mining company buys from miners or exports gold, RUCOM registration is not enough: Líderes APLA extends the system across the real chain of mining title, collection, smelting and export.
Is your mining company required to have SAGRILAFT?
| Scenario | Condition or threshold | Supervisor | Regulation |
|---|---|---|---|
| Full system, gold and precious metals | CIIU (industry classification) codes 0722, 2421, 3211 or 4662, supervised by Supersociedades, revenue or assets from 3,696,762 UVB (basic value units) | Supersociedades | CBJ, section 9.5.2 |
| Minimum measures, gold and precious metals | Same CIIU codes, revenue from 369,676 UVB or assets from 616,127 UVB | Supersociedades | CBJ, section 9.6.2 |
| Minimum measures, mining and energy sector | CIIU B05 (coal), B07 (metal ores) or 4662, with the same thresholds | Supersociedades | CBJ, section 9.6.10 |
| Full system, any supervised company | Revenue or assets from 4,929,017 UVB | Supersociedades | CBJ, section 9.4 |
Figures are taken from the previous year-end close, in basic value units (UVB). A mining company that crosses the threshold for the first time must implement the system by the following May 31 (section 9.28). Other mines and quarries (division B08) are only obligated if they exceed the general threshold in section 9.4.
Elements of SAGRILAFT in mining
- Mining risk matrix: by counterparty, product, channel and area, with greater weight on regions with illegal mining.
- Supplier due diligence: verify that the seller is registered in the National Registry of Mineral Traders (RUCOM) or is an authorized operator, with a certificate of origin.
- Beneficial owner and PEPs: identify the beneficial owner of buyers, suppliers and partners, with enhanced due diligence for politically exposed persons (PEPs) (section 9.17).
- Cash control: the company defines its normal pattern of cash payments to miners and collectors (section 9.16.1).
- Compliance Officer: principal and alternate, domiciled in Colombia, with at least one year of risk experience and 90 hours of training (section 9.9.2).
- Whistleblower channel and training: an anonymous reporting channel and annual training.
Reports and deadlines with the UIAF and Supersociedades
| Report | To whom | When |
|---|---|---|
| Suspicious transaction report (ROS) | Financial Information and Analysis Unit (UIAF), via SIREL (its online reporting system) | Immediately (section 9.19) |
| No-ROS report (AROS) | UIAF, via SIREL | 10 calendar days after each quarter without an ROS |
| Appointment of the Compliance Officer | Supersociedades, non-financial report | 15 business days from the appointment |
| Assets of persons on binding lists | UIAF and the Attorney General's Office | Immediately upon identification (sections 9.15.1 and 9.21.4) |
Red flags in mining and gold trading
According to the Supersociedades catalog for metals and precious stones and the 2025 typologies report of GAFILAT (the Financial Action Task Force of Latin America):
- Suppliers not listed in RUCOM, or who claim to extract the mineral in areas with no mining titles or mines.
- Gold exporters with no record of royalty payments that frequently use tariff heading 7112910000 (gold waste and scrap) without justification.
- Gold sales or exports exceeding what was purchased or produced, or out of line with the company's profile and capital.
- Several companies in the same sector set up by the same shareholders, with no known source of funds.
Penalties for SAGRILAFT non-compliance
A non-compliant mining company risks fines of up to 200 monthly minimum wages (Law 222 of 1995, art. 86, section 3), calculated in UVB (Law 2294 of 2023, art. 313). Supersociedades can impose them on the company, its directors and officers, the Compliance Officer and the statutory auditor (section 9.27). In addition, according to the National Mining Agency, trading without a RUCOM certificate exposes you to penalties and seizures.
How Líderes APLA implements SAGRILAFT for mining companies
- Assessment: registered CIIU code, revenue and assets in UVB, and the gap against the 2026 circular.
- Matrix and manual: a matrix by mine, supplier, buyer and area, and a manual for the board.
- Due diligence: supplier files, including RUCOM, and buyer files. AplaSoft records every list check with date and time.
- Reports: escalation of atypical payments to miners and a calendar for ROS and AROS filings in SIREL.
- Training: purchasing, sales and treasury teams, with e-learning courses.
See our AML/CTF consulting, the Colombian regulations and the glossary.
Do you mine coal, buy gold from miners or export metals? Let's review the regime for your mining title or trading company: the assessment is free.
Updated: October 2026.
Frequently asked questions
Does a coal mine need SAGRILAFT?
Who is responsible for the Minimum Measures Regime at a mining company?
Does RUCOM registration replace SAGRILAFT?
Until when can a mining company operate with its current SAGRILAFT and PTEE?
Tell us what your company needs
Fill in the form and a specialist will get back to you shortly with the scope for your sector. Free of charge and with no commitment.