Search for:
AML & Financial Services Regulatory

Colombia: Chambers of commerce and foreign non-profit entities have until 2025 to implement their PTEE and SAGRILAFT

By , , and 2 Mins Read

In brief

The Superintendence of Companies, through its External Circular No. 100-000003 of April 23, 2024 (hereinafter the “Circular”), extended the deadlines for the Chambers of Commerce and Foreign Non-Profit Entities (in its acronym in Spanish “ESALs”) to implement the Integral Self-Control and Risk Management System of money laundering, terrorism financing and financing of the proliferation of weapons of mass destruction (hereinafter SAGRILAFT) and Business Transparency and Ethics Programs (hereinafter PTEE). The new deadlines is 31 May 2025.

Comments

  • The Chambers of Commerce and the Foreign ESALs have until 31 May 2025 and not until 31 August 2024 to implement a PTEE and a SAGRILAFT under the conditions established in Chapters X and XIII of the Basic Legal Circular of the Superintendence of Companies.
  • Once the above deadline has been met, the Chambers of Commerce and Foreign ESALs must implement their SAGRILAFT and PTEE no later than May 31 following their creation.
  • The Superintendence of Companies will provide the necessary mechanisms for attention, training and support to guide the right implementation of the SAGRILAFT and PTEE.

Additional Information

Do not hesitate to contact us in case you have any questions or require our advice.

For more details regarding the obligation of Chambers of Commerce and Foreign ESALs to implement a SAGRILAFT and PTEE, please consult this link. The Circular can be consulted at this link.

Click here to read the Spanish version.

Categories:
Author

Carolina Pardo joined Baker McKenzie in 1994 and is a Partner of the Firm since 2008. She is currently a member of the Global Steering Committee for the Firm’s TMT industry group and of the Global Steering Committee for the Firm’s Investigation, Compliance and Ethics Group. She was a member of the Global Steering Committee for the Firm’s Global Antitrust and Competition from 2016 and until 2020 and is currently a member of the Latam's Antitrust Steering Committee.
She graduated as a lawyer and a specialist in International Contracts Law from Universidad de los Andes in Bogotá. She obtained a LL.M. with emphasis in International Private Law and Competition Law from the London School of Economics and Political Science.
Over 25 years, she has advised major national and international clients on matters related to compliance with data protection, competition and consumer law rules. She has represented clients in investigations and submissions related to data protection and competition matters in Colombia and has successfully coordinated and prepared white paper proposals to national authorities on behalf of major industrial groups in Colombia.
In 2016 Global Competition Review selected her as one of the 100 most influential women in antitrust. The last two Superintendents of Industry and Commerce have selected Carolina as a Non-Governmental Advisor to the Colombian Antitrust Regulator.

Author

Angelica Navarro is a partner in Baker McKenzie's Bogota office. She served as an advisor to the superintendent of Industry and Commerce on antitrust and merger control. Prior to that, she was an adviser to the director of the National Protection Unit, where she was in charge of the formulation and execution on protection and human rights programs. Previously, she worked as an associate at a legal services firm and an in-house attorney from the Mexichem Colombia company. She was selected by Global Competition Review, along with clients and colleagues to be included in the 2017, 2018, 2019, 2020, 2021 and 2022 Who's Who Legal: Competition – Future Leaders publication as one of the most outstanding lawyers in the right of free competition under 45 years of age. Angelica was also recognized by Legal 500 in 2017, 2018, 2019, 2020 and in 2021 as a "Next Generation lawyer" in competition law.

Author

Carlos Ignacio Arboleda is a Lawyer graduated from Pontificia Universidad Javeriana in Bogota. He holds a post-graduate course in Competition Law and Free Trade from the same University and earned an LL.M. degree from the University of Chicago.
Carlos has 10 years' professional experience as external counsel to national and international companies in antitrust and competition matters.

Author

Luis Alberto Castell is a Lawyer from the Pontificia Universidad Javeriana in Bogotá, with a specialization in Competition and Free Trade Law from the same university and a Master of Laws (LLM) in International Business from Queen Mary University of London.
Luis has more than 10 years of experience. He began his professional practice in the financial sector and has been specializing in the fields of competition law and corporate compliance. He was an advisor to the Superintendent of Industry and Commerce on matters related to antitrust and mergers and was part of the specialized group for the protection of competition in public procurement processes (Bid Rigging) of said entity. He was also part of Shop IV on Mergers of the Federal Trade Commission (FTC) of the United States of America as an International Fellow.
For more than three years he has been part of the Corporate Compliance team at Baker McKenzie, handling matters related to personal data protection, corporate compliance (prevention of corruption and prevention of money laundering and terrorist financing) and competition.

Related Posts