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Factoring · Colombia

SAGRILAFT for Factoring, Payroll Lending and MLM in Colombia

Colombia See also: Ecuador

SAGRILAFT for factoring companies supervised by Supersociedades

Factoring companies supervised by the Superintendence of Companies (Supersociedades) must implement full SAGRILAFT (Colombia's AML/CTF self-control and comprehensive risk management system) by virtue of their activity alone. Section 9.5.8 of chapter IX of the Basic Legal Circular (CBJ) requires it, with no revenue or asset threshold. External Circular 100-000020 of 2026 renamed SAGRILAFT 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) and added the Business Transparency and Ethics Program (PTEE) to it.

A factor buys invoices and other receivables before they fall due. If the instrument is fake or the funder's money is illicit, your company becomes the laundering channel. That is why Líderes APLA reviews every link in the chain: the invoice, who endorses it, who must pay it and who funds it.

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Is your factoring company required to implement SAGRILAFT?

Scenario	Condition or threshold	Supervisor	Regulation
Factor supervised by activity	Transactions of 394,695.3 tax value units (UVT) or more in the previous year, or more than 50 people	Supersociedades	Decree 1074 of 2015, art. 2.2.2.1.1.5, sec. 5; CBJ, sec. 9.5.8
Factor supervised by mandates	Specific mandates with third parties to purchase invoices, in the previous year or in force at year-end	Supersociedades	Decree 1074 of 2015, art. 2.2.2.1.1.5, sec. 6; CBJ, sec. 9.5.8
Payroll lending (libranza), multilevel marketing, SAPAC (commercial self-financing plan administrators) and livestock funds	By activity; payroll lending operators only if supervised	Supersociedades	CBJ, sec. 9.5.8
Any factor, supervised or not	Verify the origin of the instruments and report suspicious transactions	Supersociedades (supervision or inspection)	Law 1231 of 2008, art. 8

The supervision criteria are those of Decree 1074 of 2015. A supervised factor must register in the National Single Registry of Factors (RUNF) before operating, according to Official Letter 220-305308 of 2026. Companies already obligated have until May 31, 2027 to align (sec. 9.29).

SAGRILAFT components in factoring

Policy and manual: approved with senior management's written commitment (sec. 9.7).
Compliance Officer: has direct communication with the board of directors, is domiciled in Colombia and holds certified AML/CTF risk training, such as a 90-hour diploma course (sec. 9.9).
Counterparty due diligence: assignor, payer, funders and principals, with their beneficial owner; enhanced for politically exposed persons (PEP) (secs. 9.15 and 9.17).
Verification of instruments: origin, existence and authenticity of every instrument purchased (Law 1231 of 2008, art. 8, and sec. 8.52).
Controlled funding: shareholder contributions, bank loans, portfolio sales or third-party mandates; specific mandates may not exceed 10% of equity (sec. 8.47).
Record-keeping: supporting documents kept for ten years (art. 28 of Law 962 of 2005).

ROS reports and deadlines with the UIAF

Report	Filed with	Deadline
Suspicious transaction report (ROS)	Financial Information and Analysis Unit (UIAF), via SIREL, its online reporting system	Immediately, once the transaction has been classified (sec. 9.19)
Absence of suspicious transaction report (AROS)	UIAF, via SIREL	10 calendar days after a quarter with no reports
RUNF information	Supersociedades	Before operating and every year, with the financial statements

A ROS does not require proof of a crime and is not a criminal complaint. The principal and alternate Compliance Officers register with SIREL.

AML/CTF red flags in factoring and payroll lending

According to section 9.20 and the 2025 Typologies Report of GAFILAT (Financial Action Task Force of Latin America):

Invoices that appear fake, do not reflect a real transaction or are inflated.
Companies in the same group that invoice each other and discount invoices that are never paid.
Assignors with little capital, or legal representatives with no economic profile (straw men).
Money from abroad far exceeding exports, brought in with unsupported invoices.
Legal entities with no identifiable beneficial owner.

Penalties for failing to comply with SAGRILAFT

A factor that breaches article 8 of Law 1231 of 2008 becomes subject to grounds for dissolution. In addition, Supersociedades can fine the company, its directors and officers, the Compliance Officer and the statutory auditor (sec. 9.27). Fines reach up to 200 monthly minimum wages (Law 222 of 1995, art. 86, sec. 3) and are calculated in basic value units (UVB) (Law 2294 of 2023, art. 313).

How Líderes APLA implements SAGRILAFT at your factoring company

Assessment: we confirm whether your company is supervised, whether it is registered in the RUNF and what gaps it has against chapter IX.
Risk matrix and manual: as part of our AML/CTF consulting, by assignor, payer, instrument type, funder and jurisdiction.
Onboarding of assignors and payers: form, beneficial owner and restrictive list screening in AplaSoft, before disbursement.
Reporting: a protocol for origination to escalate a questionable invoice to the Compliance Officer; ROS and AROS via SIREL.
Training: for the Compliance Officer, the board of directors and the sales team, with e-learning courses.

Legal framework and acronyms: Colombian regulations and glossary.

Does your factoring company operate under third-party mandates, or does it need to align before May 2027? Request a free assessment of your factoring business: you will learn whether you are supervised and which gaps to close.

Updated: October 2026.

Frequently asked questions

Does every factoring company need a SAGRILAFT?

No: in Colombia, SAGRILAFT is mandatory only for factors supervised by Supersociedades. The rest verify their instruments and report suspicious transactions (Law 1231 of 2008).

What is the RUNF and who must register?

The RUNF is Supersociedades' National Single Registry of Factors. Supervised factors register before operating, free of charge, and update their registration every year.

Can a Compliance Officer serve several factoring companies?

Yes: a Compliance Officer can serve up to ten obligated entities that do not compete with each other (sec. 9.9.3), or an entire declared business group. The officer cannot be a director or officer, shareholder, statutory auditor or internal auditor of the factor.

Do I have to change my software to use AplaSoft?

No: AplaSoft runs in the cloud and integrates with other systems through an API.

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