The PTEE Merges into SAGRILAFT: Corruption and Bribery in a Single System
For years, Colombian companies in the real sector ran two programs in parallel: SAGRILAFT for money laundering and the Corporate Transparency and Ethics Program (PTEE) for corruption and transnational bribery, each with its own circular. External Circular 100-000020 of 2026 put an end to that duality.
One single system: ML/TF/PF and C/ST
Chapter IX of the Basic Legal Circular integrates both programs into a single Self-Control and Risk Management System for ML/TF/PF and C/ST. The new acronym is the key: to the prevention of money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction, the same system now adds the management of local corruption and transnational bribery risk. External Circular 100-000011 of 2021, which regulated the PTEE separately, has been repealed.
What it means for your company
- An integrated matrix. The risk matrix no longer looks only at laundering typologies: it incorporates corruption and bribery risks into the same identification, measurement and control processes.
- One person in charge. The appointment and duties of the Compliance Officer cover the entire system, including what used to be the PTEE.
- Consistent policies and due diligence. Knowing your customers, suppliers and ultimate beneficial owners serves both AML prevention and the management of corruption and transnational bribery risks.
The calendar is the same
Adjusting to the new Chapter IX shares the general deadline: companies already obligated have until May 31, 2027, and their current systems remain valid in the meantime. The full framework is on our Colombia regulations page.
If your PTEE and your SAGRILAFT grew separately, an integration assessment is the first step. Our SAGRILAFT and PTEE consulting does it with your team. Contact us.