SAGRILAFT for jewelers and precious metals traders
Companies that manufacture jewelry, mine gold or trade in precious metals and stones apply SAGRILAFT (Colombia's AML/CTF self-control and comprehensive risk management system) if they exceed thresholds set by the Superintendence of Companies (Supersociedades). External Circular 100-000020 of 2026 renamed 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) in chapter IX of its Basic Legal Circular (CBJ). Depending on its size, a company applies the full system or the Minimum Measures Regime.
External Circular 100-000020 treats dealers in precious metals and stones as designated non-financial businesses and professions (DNFBPs, or APNFD in Spanish). High value per gram, easy transport and the use of cash expose them to money laundering and terrorist financing. If your jewelry business buys gold, every gram needs an origin you can prove: which mine, smelter or individual it comes from and how it was paid for. That is where Líderes APLA starts.
Is your jewelry business or trading company required to implement SAGRILAFT?
| Scenario | Condition or threshold (December 31 of the previous year) | Supervisor | Regulation |
|---|---|---|---|
| Full system | Supervised or controlled by Supersociedades, CIIU (Colombia's ISIC-based industry code) 4662, 3211, 2421 or 0722, and revenue or assets of 3,696,762 UVB or more | Supersociedades | CBJ, ch. IX, sec. 9.5.2 |
| Minimum Measures Regime | Same CIIU codes, with revenue of 369,676 UVB or more, or assets of 616,127 UVB or more | Supersociedades | CBJ, ch. IX, sec. 9.6.2 |
| Gold exporters or importers, smelters and international trading companies | Report to the UIAF (Colombia's Financial Information and Analysis Unit) by activity, with no threshold | UIAF; Supersociedades | UIAF Res. 363 of 2008 |
The CIIU codes cover wholesale trade in metals, jewelry manufacturing, the precious metals industry and gold mining. Falling below these figures in basic value units (UVB) does not release you: sec. 9.30 keeps the obligation in place for two years under the full system or one year under minimum measures.
SAGRILAFT components in jewelry and precious metals
- Supplier due diligence: the seller of gold, gems or scrap, their beneficial owner and the origin of the material.
- Know your customer: who is really paying and for what purpose, with enhanced due diligence for politically exposed persons (PEP).
- Cash control: sec. 9.16.1 requires defining how cash is handled and its normal patterns.
- Retail sales: proportionate due diligence thresholds are set and unusual transactions are monitored (sec. 9.16.2).
- Compliance Officer: the full system requires a principal and an alternate. Under minimum measures, the legal representative is responsible.
ROS reports and deadlines with the UIAF
| Report | Filed by | Deadline |
|---|---|---|
| ROS (suspicious transaction report) | Every obligated entity, via SIREL (the UIAF's online reporting system) | Immediately |
| AROS (absence of suspicious transaction report) | Compliance Officer or legal representative | 10 calendar days after each quarter with no ROS |
| Match with binding lists | Legal representative, to the UIAF and the Attorney General's Office (Fiscalía) | Upon identifying the asset or person |
| Gold purchases and sales, imports or exports | Entities obligated under UIAF Res. 363 of 2008 | Every four months, within 10 calendar days after the cutoff |
ROS and AROS: sections 9.19 and 9.21.4. Gold reports: UIAF technical annexes.
Red flags in the jewelry and precious metals trade
The sector's Supersociedades catalog of risk transactions includes, among others:
- Mineral sellers not listed in the Single Registry of Mineral Traders (RUCOM).
- Gold claimed to come from an area with no mining titles or mines.
- Frequent exports declared as «gold waste and scrap» with no royalty payments or justification.
- At the counter, customers who pay for a piece in cash, split it across several cards or come back over several days to complete the payment.
- Buyers with no interest in the certificate of authenticity or the price.
- Transactions with border mining regions where the state has little presence.
Penalties for failing to comply with SAGRILAFT
An obligated jewelry business that fails to comply risks 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 company, its directors and officers, the Compliance Officer and the statutory auditor (sec. 9.27).
How Líderes APLA implements SAGRILAFT at your jewelry business
- Applicability assessment: CIIU, revenue and assets determine full system, minimum measures or gold reporting.
- Risk matrix: by counterparty, product, channel and geographic area, with a focus on mining regions.
- Manual and policies: due diligence on metal suppliers, cash handling and ROS and AROS procedures.
- Restrictive lists: metal suppliers and customers screened in AplaSoft, with date and time stamps.
- Training: for the Compliance Officer, the board and the purchasing, sales and cashier teams, with online courses.
Part of our AML/CTF Consulting in Colombia; see the regulations and the glossary.
Do you smelt, cut or sell gold and gems? Find out which regime applies to your jewelry business, at no cost and with no obligation.
Updated: October 2026.
Frequently asked questions
Is a small jewelry store required to implement SAGRILAFT?
How long must I keep supporting documents for purchases and sales?
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