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AML/CTF Prevention

External Circular 100-000020 of 2026: What Changes in SAGRILAFT and the PTEE

·Colombia
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The Superintendencia de Sociedades has reorganized the anti-money laundering framework for Colombia's real sector: External Circular 100-000020 of 2026 repeals, among others, the two circulars companies had been applying and brings their requirements together in Chapter IX of the Basic Legal Circular. If your company already has a SAGRILAFT or a PTEE in place, you are not starting from scratch — but you do have work to do, and a deadline.

What changes

  • One single rule. External Circular 100-000016 of 2020, which adopted SAGRILAFT in Chapter X, and External Circular 100-000011 of 2021, which regulated the Corporate Transparency and Ethics Program (PTEE), are repealed. Everything now lives in Chapter IX.
  • One single system. SAGRILAFT and the PTEE merge into a single Self-Control and Risk Management System for ML/TF/PF and C/ST, adding the management of local corruption and transnational bribery risk to AML prevention.
  • Thresholds and regimes. The general obligation is defined by revenues or assets equal to or above 4,929,017 UVB, with specific thresholds for some sectors and a Minimum Measures Regime for companies in certain sectors with lower revenues or assets.

The deadline: May 31, 2027

Companies that were already obligated have until May 31, 2027 to adjust their system to the new Chapter IX. In the meantime, systems already implemented remain valid: the risk is not being left without a system, but reaching the date without having closed the gap between what your company has and what the new circular requires.

Where to start

The first step is a gap assessment against Chapter IX: confirm whether your company is still obligated and under which regime, review the risk matrix to incorporate corruption and transnational bribery, update the manual and policies, and verify that the Compliance Officer meets the appointment requirements. The regulatory detail is on our Colombia regulations page.

Want to know exactly what your system is missing for the new Chapter IX? Our SAGRILAFT and PTEE consulting performs that gap assessment and supports you all the way to the deadline. Contact us.