SAGRILAFT and PTEE: what they mean for your company

In Colombia, the Superintendence of Companies requires certain businesses to adopt internal compliance programmes to prevent legal risks. Two of the main mandatory systems are SAGRILAFT and PTEE, addressing specific needs: preventing money laundering, terrorist financing and corruption in business. Established in Chapters X and XIII of the Superintendence’s Basic Legal Circular, these programmes seek to ensure that companies conduct business transparently, ethically and without links to unlawful activities.

SAGRILAFT is the Spanish acronym for the Self-Control and Comprehensive Risk Management System for Money Laundering, Terrorist Financing and Financing of the Proliferation of Weapons of Mass Destruction. In essence, it is a set of policies, procedures and controls implemented by a company to identify, assess, manage and mitigate the risk of being used for money laundering or terrorist financing. Through SAGRILAFT, an organisation defines its risk factors, applies preventive measures such as customer and supplier due diligence, and establishes mechanisms to detect unusual or suspicious transactions that could indicate unlawful activity. A key component is the Compliance Officer, who advises the company, leads the system, monitors its operation and reports suspicious transactions to the competent authorities, such as the UIAF.

PTEE stands for the Business Transparency and Ethics Programme. It aims to prevent corruption and promote an ethical culture within the company and its business relationships. A well-designed PTEE includes a clear code of conduct, anti-corruption policies covering matters such as gifts or interaction with public officials, internal reporting procedures for misconduct, accounting controls ensuring financial transparency, and regular ethics training for employees. The aim is for everyone in the organisation to act with integrity and for the company to minimise the risk of bribery, fraud and other corrupt conduct. In other words, PTEE helps a company “do the right thing” and comply with legislation such as the transnational anti-bribery law, Law 1778 of 2016.

Who must implement SAGRILAFT and PTEE?

Not every company must adopt these systems. Only certain companies fall within the scope of these obligations under size and activity criteria. The Superintendence has defined financial thresholds and sectors to determine the obligation:

• SAGRILAFT applies mainly to medium-sized and large companies in specific sectors under the Superintendence’s supervision. Examples include real estate or mining companies with annual revenue above 60,000 minimum wages; legal or accounting services firms with revenue above 30,000 minimum wages; vehicle trading businesses (auto parts) with revenue above 130,000 minimum wages; building construction companies with more than 100,000; and generally companies in other sectors with annual revenue above 160,000 minimum wages. This means that, if a company exceeds its sector’s threshold at year-end, it must begin implementing SAGRILAFT the following year.

• PTEE obligations originally arose for companies involved in international business. Following Law 1778 and subsequent regulations, supervised companies with significant assets and transactions with foreign counterparties became subject to the requirement. For example, a company with total assets above 40,000 statutory monthly minimum wages that carried out one or more international transactions worth at least 100 statutory monthly minimum wages during the previous year must adopt a Transparency and Ethics Programme. The measure seeks to prevent transnational bribery and other unlawful practices among companies with a presence or business outside Colombia. In 2020, the Superintendence considerably expanded the number of companies subject to PTEE, reducing the required asset and revenue thresholds and including emerging sectors, such as businesses handling cryptoassets, within the scope of the rule.

In summary, large companies or those with heightened risks due to their sector or international activity are the main businesses required to implement SAGRILAFT and/or PTEE. However, companies not legally obliged to do so can voluntarily adopt these programmes as good practice. A voluntary PTEE can provide added value: many customers, partners and investors prefer organisations with strong integrity policies, increasing trust in business relationships.

Why compliance matters and the consequences of failure

Implementing SAGRILAFT and PTEE is more than a box-ticking exercise; it is an investment in a company’s sustainability and reputation. These systems help prevent the company from being used for unlawful purposes, protect it from scandals and penalties, and align it with international standards of responsible business. In practice, a company with sound compliance systems can detect warning signs early — such as unusual financial transactions or requests for improper payments — and act to prevent offences. It also demonstrates to business partners and authorities that the company has zero tolerance for corruption and money laundering.

By contrast, ignoring these obligations carries serious risks. The Superintendence has the power to investigate and sanction companies that are required to have SAGRILAFT or PTEE but fail to implement them adequately. Fines can be substantial. Under the rules, companies whose transparency and ethics programmes are not up to date could face penalties of up to 200,000 statutory monthly minimum wages (SMLMV). Although this is the theoretical maximum and usual fines tend to be lower, supervision has recently become stricter.

In conclusion, compliance with SAGRILAFT and PTEE is both a legal obligation and a sound business decision. It helps avoid fines and reputational damage while creating safer, more ethical business environments. Companies required to implement these systems should seek support from professionals experienced in corporate compliance. Specialist advice facilitates effective design, adoption and monitoring, helping the company remain within the law and protecting its future against money laundering, terrorist financing and corruption risks.