SAGRILAFT for Real Estate and Construction Companies in Colombia

Implementing SAGRILAFT in the real estate and construction sector

Real estate agencies and companies that build buildings and civil works must implement SAGRILAFT (Colombia's AML/CTF self-control and comprehensive risk management system) or the Minimum Measures Regime. When they exceed its thresholds, this is required by chapter IX of the Basic Legal Circular (CBJ) of the Superintendence of Companies (Supersociedades). With External Circular 100-000020 of 2026, that chapter merges the former SAGRILAFT and the Business Transparency and Ethics Program (PTEE) into 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).

Property holds its value, accepts installment payments and makes it possible to hide the real buyer. If your construction company exceeds the thresholds, it may be obligated even if Supersociedades does not supervise it. That is why Líderes APLA builds the system project by project: who reserves the unit, who pays and who signs the deed.

Is your real estate or construction company required to implement SAGRILAFT?

What counts are the figures at the previous year-end, in basic value units (UVB). A company crossing the threshold for the first time must implement by the following May 31 (sec. 9.28). Companies already obligated have until May 31, 2027 to align (sec. 9.29).

SAGRILAFT components in the real estate sector

• Risk matrix by project: by counterparty, property type, sales channel and area.
• Due diligence on buyers and investors: the counterparty and its beneficial owner, with enhanced due diligence for politically exposed persons (PEP).
• Control of cash and third-party payments: cash is a risk factor (sec. 9.16.1). The company defines its normal pattern and flags anything that deviates from it.
• Off-plan sales and assignments: monitoring of off-plan reservations and assignments by the buyer before delivery.
• Compliance Officer: a principal and an alternate, domiciled in Colombia, with one year of risk experience (sec. 9.9.2). The legal representative, shareholders and statutory auditor cannot hold the role (sec. 9.9.3).
• Annual report and updates: the officer reports to the board every year and proposes adjustments at least every two years (sec. 9.9.5). Data on high-risk buyers is updated every year, and on all others every two years (sec. 9.15.1).

Reports and deadlines with the UIAF and Supersociedades

Under minimum measures, the legal representative registers with SIREL and is responsible for both reports, which are kept confidential from the buyer.

Money laundering red flags in real estate and construction companies

The Supersociedades catalog of risk transactions for real estate agents includes, among others:

• A buyer reserves the unit and pays the down payment, but asks for the deed to be issued in a third party's name or assigns the property before delivery.
• Cash payments with no record of who pays, or split over very short periods.
• Deeds recorded at a value very different from the real one.
• Buyers with no interest in price or terms, in a hurry to close.
• Companies whose only activity is holding property, or buyers with no apparent financial capacity.

Penalties for failing to comply with SAGRILAFT

If your real estate company does not implement SAGRILAFT or leaves it on paper, Supersociedades can fine it, as well as 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 UVB (Law 2294 of 2023, art. 313).

How Líderes APLA implements SAGRILAFT at your real estate company

1. Assessment: CIIU, figures in UVB, applicable regime and gaps against chapter IX.
2. Matrix by project: each tower or development with its sales channels; policy and manual, as part of our AML/CTF consulting.
3. Buyer onboarding: form via link, beneficial owner and restrictive list screening in AplaSoft.
4. Reporting: unusual transactions escalated from the sales office; ROS and AROS via SIREL.
5. Training: for the Compliance Officer, senior management, treasury and sales offices, with e-learning courses. Regulations and acronyms: Colombian regulations and glossary.

Launching a project, or need to align your system before May 31, 2027? Let's review your construction or real estate company together: the initial assessment is free.

Updated: October 2026.