SAGRILAFT for Car and Motorcycle Dealerships in Colombia

Implementing SAGRILAFT at car and motorcycle dealerships

Car and motorcycle dealerships above a certain size must apply SAGRILAFT (Colombia's AML/CTF self-control and comprehensive risk management system), issued by the Superintendence of Companies (Supersociedades). Since External Circular 100-000020 of 2026, chapter IX of its Basic Legal Circular (CBJ) calls it the «Sistema de Autocontrol y Gestión de Riesgos LA/FT/FP y C/ST» (Self-Control and Risk Management System for money laundering, terrorist financing, proliferation financing, corruption and transnational bribery). It merges the former SAGRILAFT and the Business Transparency and Ethics Program (PTEE).

A vehicle is worth a lot, resells quickly and can be paid for in cash. According to the 2025 regional typologies of the Financial Action Task Force of Latin America (GAFILAT), car sales are the third-largest laundering channel, after banking and notaries. If your dealership is already an obligated entity, you have until May 31, 2027 to align with chapter IX (section 9.29). The system has to work on the showroom floor, not just on paper.

Is your dealership required to implement SAGRILAFT?

Cross-check the economic activity in your tax registry (RUT), coded under the CIIU (the DANE adaptation of the ISIC industry classification), against your figures as of the previous December 31, expressed in basic value units (UVB). One year of lower figures does not release you: you remain obligated for two years under the full system and one year under minimum measures (section 9.30).

SAGRILAFT components at a dealership

• Risk matrix: by customer, vehicle line, payment method, channel and city. External Circular 100-000020 requires you to avoid copying other companies' systems.
• Buyer due diligence: identity, beneficial owner and purpose of the purchase. Data is updated every year for high-risk buyers and every two years otherwise (section 9.15.1).
• Enhanced due diligence: mandatory for politically exposed persons (PEP), their relatives and associates, and for FATF high-risk countries. It requires senior management approval (section 9.17).
• Cash and trade-in policy: cash is a risk factor and calls for defined normal payment patterns (section 9.16.1). Trade-ins are controlled the same way.
• Compliance Officer: a principal and an alternate, each with a professional degree, one year of experience and certified training, such as a 90-hour diploma course.
• Annual training: with priority for sales advisors, cashiers, credit staff and used-vehicle intake (section 9.8).

ROS reports and deadlines with the UIAF and Supersociedades

Under minimum measures, the legal representative registers with SIREL and is responsible for both reports. A ROS is confidential and is not a criminal complaint (UIAF).

Money laundering red flags in vehicle sales

• Down payment or balance paid in cash with no record of who actually provides the money (section 9.20).
• Payment split over short periods or across several payment methods for the same vehicle.
• A vehicle reserved by one buyer and invoiced on delivery to an unidentifiable third party.
• Several high-end purchases within a short time in the name of third parties or shell companies (GAFILAT).

Penalties for failing to comply with SAGRILAFT

An incomplete SAGRILAFT can cost fines of up to 200 monthly minimum wages (Law 222 of 1995, art. 86, sec. 3), calculated in UVB (Law 2294 of 2023, art. 313). Supersociedades can impose them on the dealership, its directors and officers, the Compliance Officer and the statutory auditor (section 9.27). It also penalizes a system that exists only on paper.

How Líderes APLA implements SAGRILAFT at dealerships

1. Assessment: CIIU, revenue, assets and current system; we tell you your regime, your deadline and your gaps.
2. Risk matrix: high-end vehicles, trade-ins, third-party payments and branches.
3. Manual and forms: policies, manual and buyer form, as part of our AML/CTF consulting.
4. Tools: with AplaSoft, buyers complete the form via a link, restrictive lists are screened, and unusual transactions and ROS filings are logged.
5. Showroom training: sales advisors, cashiers and trade-in appraisers, with e-learning courses. Regulations and acronyms: Colombian regulations and glossary.

Does your dealership network need to bring its SAGRILAFT up to date before May 2027? Book a free assessment of your dealership: you will learn your regime, your deadline and your gaps, with no obligation.

Updated: October 2026.