SIPLAFT for Notaries in Colombia: AML/CTF Prevention and UIAF

Notarial SIPLAFT: AML/CTF prevention in Colombia's notary offices

All notaries in Colombia must apply the Comprehensive System for the Prevention and Control of the Risk of Money Laundering, Terrorist Financing and Financing of the Proliferation of Weapons of Mass Destruction (SIPLAFT). It is overseen by the Superintendence of Notaries and Registry (SNR), and reports go to the Financial Information and Analysis Unit (UIAF). The governing rule is Administrative Instruction (AI) 17 of 2016, supplemented by Administrative Instruction 08 of 2017.

SIPLAFT covers acts formalized by public deed. It is scaled to the size of your notary office and to your region's economy, but no notary office is exempt. Líderes APLA adapts it to each office, with a focus on real estate sales and company incorporations.

Is your notary office required to have SIPLAFT?

SIPLAFT exempts no notary office on account of size: proportionality lies in how the system is designed, not in who applies it.

Elements of SIPLAFT in notary offices

• The notary's policies: designed and approved in minutes by the notary, and communicated to all staff.
• SIPLAFT Coordinator: the notary or a direct employee, with an optional alternate. The role cannot be outsourced, and the Coordinator registers with the UIAF to use SIREL.
• Know your user: identity, economic activity, address, marital status, signature and fingerprint; legal entities provide their certificate of existence and legal representation.
• PEPs and UN lists: for politically exposed persons (PEPs), stricter due diligence until two years after they leave office (Decree 830 of 2021). The Security Council lists are always checked, with a digital record, and a match goes immediately to the UIAF.
• Employees and higher-risk countries: the notary checks staff backgrounds before hiring. Users from countries flagged by the GAFI (Financial Action Task Force, FATF) are subject to enhanced due diligence (AI 17, sections 4.3.1.2.3 and 4.3.1.2.5).
• Training and annual report: at least once a year for all staff, with attendance records. The Coordinator delivers a written annual report to the notary.

ROS and RON reports and deadlines with the UIAF

A notarial ROS is not a criminal complaint, and no one may disclose that it was filed.

Money laundering red flags in deed execution

• A party or beneficiary appears on UN Security Council lists or other control lists.
• A declared price far above or below the property's market value, according to the UIAF's sector study.
• Properties deeded to front men or shell companies and paid for with cash of unknown origin.
• Properties linked to asset forfeiture proceedings, or appraisals that do not match the property.
• Acts involving jurisdictions the FATF lists as non-cooperative, or paid for with virtual currencies: two red flags cited in AI 17.

Penalties for SIPLAFT non-compliance

If your notary office fails to comply with AI 17 of 2016, you are personally liable and face disciplinary sanctions from the SNR. The General Disciplinary Code, Law 1952 of 2019, provides the following for notaries (arts. 80 and 81):

• removal from office with a 5- to 20-year disqualification;
• suspension for 1 to 48 months;
• a fine of 10 to 180 days of minimum wage.

How Líderes APLA implements SIPLAFT at your notary office

1. Assessment against AI 17 of 2016 and AI 08 of 2017: policies, minutes, know-your-user forms and SIREL records.
2. Deed execution risk map: by type of act, user, payment method and area.
3. SIPLAFT manual and minutes: policies, procedures, internal reports and forms ready for the notary's signature.
4. Support for the SIPLAFT Coordinator: a calendar for RON, ROS and auction reports; the Coordinator's duties remain with the notary office.
5. Annual staff training: through our e-learning courses. AplaSoft supports restrictive list checks with date-and-time evidence.

Part of our AML/CTF Consulting in Colombia; see the regulations and the glossary.

Have you just taken office as a notary, or are you expecting an SNR inspection? Book your free SIPLAFT assessment.

Updated: October 2026.