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Other Obligated Entities · Colombia

SARLAFT and SAGRILAFT for Other Obligated Entities in Colombia

Colombia See also: Ecuador · Peru

Obligated entities in Colombia: SARLAFT, SIPLAFT and SAGRILAFT outside the financial sector

Colombia has no single list of obligated entities: each supervisor sets its own AML/CTF prevention system. All of them report to the Financial Information and Analysis Unit (UIAF), which groups them into 17 sectors. As of September 29, 2026, the DIAN (Colombia's tax and customs authority) accounted for 3,940 and Supertransporte (the Superintendence of Transport) for 3,391 (UIAF, reporting sectors).

SAGRILAFT is the system of the Superintendence of Companies (Supersociedades). Since External Circular 100-000020 of 2026, it has been called the "Self-Control and Risk Management System for ML/TF/PF and C/TB" (Chapter IX). Other supervisors require a SARLAFT (AML/CTF Risk Management System) or a SIPLAFT (Comprehensive AML/CTF Prevention System). If Supersociedades does not supervise you, that does not exempt you: another supervisor may require its own system.

Hands looking for a file inside an accordion folder full of documents
Hands looking for a file inside an accordion folder full of documents

Is your company obligated? Obligated entities by sector

Scenario Condition or threshold Supervisor Regulation
Transport and infrastructure SARLAFT with revenue from 142,206.50 UVB (basic value units); below that, the Simplified Measures Regime Supertransporte Res. 4607 of 2026
Health (EPS health insurers, prepaid medicine and other supervised entities) As set out in the circular Supersalud (Superintendence of Health) EC 009 of 2016 and EC 005-5 of 2021
Games of chance National or territorial concessionaires (chance lottery) Coljuegos (national gaming regulator); CNJSA (National Council of Games of Chance) Res. 20195100044514 of 2019; Agreement 897 of 2026
Virtual assets Contributions or services from 12,323 UVB; services must also have revenue from 369,676 UVB or assets from 616,127 Supersociedades and UIAF CBJ (Basic Legal Circular), section 9.5.7; UIAF Res. 314 of 2021
Legal services (CIIU industry code 6910) and accounting services (6920) Full system from 3,696,762 UVB; minimum measures from 369,676 UVB in revenue or 616,127 in assets Supersociedades CBJ, sections 9.5.3, 9.5.4, 9.6.3 and 9.6.4
Pharmaceutical and manufacturing Minimum measures only, same thresholds Supersociedades CBJ, sections 9.6.7 and 9.6.9
Chambers of commerce Full system from 4,929,017 UVB in revenue; minimum measures from 1,109,029 UVB Supersociedades CBJ, sections 9.5.9 and 9.6.6
Money changers and customs users Registered money changers (SARLAFT); customs users (SIPLA) DIAN Res. 210 of 2025; Circular 170 of 2002
Postal payment operators Licensed operators MinTIC (Ministry of ICT) Res. 1292 of 2021
Clubs with professional athletes SIPLAFT MinDeporte (Ministry of Sport) Circular 005 of 2016
Parties and campaigns 2026 elections CNE (National Electoral Council) and UIAF Circular 001 of 2026

Chapter IX does not apply to entities that already have a special-regime supervisor. Figures in basic value units (UVB) are those of the previous year-end close. Entities already obligated and those newly obligated at the 2026 cutoff have until May 31, 2027 (sections 9.28 and 9.29).

Elements of SARLAFT or SAGRILAFT in special sectors

  • Applicable regime: a company may have two supervisors, as in virtual assets.
  • Risk matrix: by counterparty, product, channel and jurisdiction; Supersociedades adds corruption and transnational bribery (C/ST).
  • Due diligence and beneficial owner: covering clients, suppliers, employees and shareholders; enhanced for politically exposed persons (PEPs) and virtual assets.
  • Compliance Officer: principal and alternate under the full system; under the Minimum Measures Regime, the legal representative is responsible.
  • Objective reports: cash transactions, prize winners, postal money orders or player transfers, according to each sector's technical annex.

ROS reports and deadlines with the UIAF

Report To whom Deadline
Suspicious transaction report (ROS) UIAF, via SIREL (its online reporting system) Immediately, in all sectors
No-ROS report (AROS) UIAF, via SIREL 10 calendar days after a quarter without an ROS (section 9.19)
Sector-specific objective reports UIAF, via SIREL Each sector's 2026 calendar

The ROS is confidential and is not a criminal complaint (section 9.19).

Red flags in other obligated entities

  • A counterparty that avoids explaining the source of its funds, or whose activity does not fit its financial profile (section 9.20).
  • Accounting firms that invoice nonexistent services (Financial Action Task Force of Latin America, GAFILAT; 2025 Typologies Report).
  • Lawyers who set up companies in the names of front men (same report).
  • Several users of a virtual asset service provider sharing the same phone number or using false data (a Colombian case).

Penalties for non-compliance

Under Chapter IX, fines reach up to 200 monthly minimum wages (Law 222 of 1995, art. 86, section 3), calculated in UVB (Law 2294 of 2023, art. 313). Section 9.27 covers the company, its directors and officers, the Compliance Officer and the statutory auditor. Outside Chapter IX, each supervisor imposes penalties under its own regime.

How Líderes APLA implements SARLAFT or SAGRILAFT in your sector

  1. Obligation assessment: your supervisor, CIIU code and figures in UVB determine your regime and your deadline.
  2. Matrix and manual tailored to the supervisor: within our AML/CTF consulting, because a Supertransporte SARLAFT looks nothing like a MinDeporte SIPLAFT.
  3. Reports to the UIAF: SIREL registration and a calendar according to your supervisor.
  4. Tools: AplaSoft checks restrictive lists, RUES (the national business registry) and DIAN, and stores unusual transactions and ROS filings.
  5. Training: the officer and department heads, with e-learning courses. Circulars in Colombian regulations; acronyms in the glossary.

Not sure whether you need SARLAFT, SIPLAFT or Chapter IX? Tell us about your business, at no cost and with no commitment.

Updated: October 2026.

Frequently asked questions

Am I obligated if Supersociedades does not supervise me?
<p>Yes, if another supervisor requires an AML/CTF system. Supertransporte, Supersalud, Coljuegos, DIAN and MinTIC have their own systems.</p>
Must the statutory auditor report suspicious transactions?
<p>Yes: the statutory auditor reports to the UIAF, with their own SIREL user account (<a href="https://www.uiaf.gov.co/node/1375">UIAF</a>), under section 10 of article 207 of the Commercial Code.</p>
How does a newly obligated company start reporting to the UIAF?
<p>It requests a reporting entity code in SIREL, and then a user account for its Compliance Officer or legal representative (<a href="https://www.uiaf.gov.co/sistema-nacional-ala-cft/ros-reporte-de-operacion-sospechosa">UIAF</a>). That record accompanies the notice of the officer's appointment (section 9.9.4).</p>
What if my company already has an AML/CTF system?
<p>The assessment confirms whether it meets your supervisor's requirements and identifies the gaps.</p>
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