SARLAFT for Savings and Credit Cooperatives in Colombia

SARLAFT for savings and credit cooperatives supervised by Supersolidaria

Savings and credit cooperatives in Colombia must implement the full Money Laundering and Terrorist Financing Risk Management System (SARLAFT). They are supervised by the Superintendence of the Solidarity Economy (Supersolidaria) under Title V of its Basic Legal Circular (CBJ). Title V implements articles 102 to 107 of the Organic Statute of the Financial System (EOSF).

Employee funds, mutual associations and other solidarity-economy organizations apply it in full or in part, depending on their supervision level and their assets. If yours is a savings and credit cooperative, full SARLAFT applies regardless of your size. You take deposits, lend, handle cash and report every month to the Financial Information and Analysis Unit (UIAF). Líderes APLA starts from your membership base: members, channels and branches.

Is your cooperative required to implement SARLAFT?

All supervised solidarity-economy organizations, even exempt ones, report to the UIAF. Supersolidaria may order full SARLAFT for any organization whose risk increases.

SARLAFT components in cooperatives

• Segmentation of risk factors: members, products, channels and jurisdictions.
• Know your member and the beneficial owner: onboarding, binding lists and periodic updates. Politically exposed persons (PEP) keep that treatment for two years after leaving office.
• Electronic consolidation: each member's transactions consolidated at least monthly to detect unusual ones.
• Principal and alternate Compliance Officer: must request confirmation of appointment from Supersolidaria within 30 days, and must hold the UIAF e-learning course certificate plus 90 hours of risk studies or two years of experience.
• Statutory audit: the statutory auditor verifies SARLAFT in the quarterly report to Supersolidaria.
• Training and record-keeping: annual training and training at onboarding; documents kept for five years (art. 96 of the EOSF).

ROS reports and deadlines with the UIAF

All reports are filed through the Online Reporting System (SIREL), according to the technical annexes to Title V.

A monthly products report is also required.

Red flags in savings and credit cooperatives

• Cash deposits structured below reporting thresholds and then transferred to third parties (a case from the GAFILAT (Financial Action Task Force of Latin America) 2025 Typologies Report).
• Loans prepaid in cash with no source of funds to explain it.
• Contributions or savings inconsistent with the member's declared economic activity.
• Members who refuse to update their information or to declare the source of their funds.

Penalties for failing to comply with SARLAFT

Each violation can cost the cooperative and its directors and officers Supersolidaria fines of up to 200 minimum wages, imposed repeatedly for as long as the violation continues (Law 454 of 1998, art. 36, secs. 6 and 7, and Decree 186 of 2004).

How Líderes APLA implements SARLAFT in your cooperative

1. Assessment: full SARLAFT, partial SARLAFT or minimum measures, plus a gap report.
2. Risk matrix: we segment the risk factors and measure inherent and residual risk.
3. Manual and code of conduct: for approval by the board of directors.
4. Reporting: ROS and monthly reports; AplaSoft screens restrictive lists and logs unusual transactions.
5. Training: for the Compliance Officer, the board and the branches, with e-learning courses.

This is a service within our AML/CTF Consulting in Colombia; circulars are in the regulations section and acronyms in the glossary.

Is a Supersolidaria inspection coming up, or has your supervision level changed? Request a free assessment of your cooperative's SARLAFT.

Updated: October 2026.