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SAGRILAFT and PTEE 2025: Obligated Companies, Deadlines, and Consequences of Non-Compliance

In 2025, Colombian companies must continue strengthening their regulatory compliance systems through the implementation of two key mechanisms: the Self-Control and Comprehensive Risk Management System for Money Laundering and Terrorism Financing (SAGRILAFT) and the Business Transparency and Ethics Program (PTEE). Both systems are mandated by the Superintendence of Companies (Superintendencia de Sociedades) and are intended to prevent illicit activities, promote corporate integrity, and safeguard business reputation.

At Trébol Jurídico, we provide a clear and concise overview of which entities are required to implement these systems, the applicable deadlines, and the risks of non-compliance.

What are SAGRILAFT and PTEE?

  • SAGRILAFT: An internal compliance framework designed to identify, assess, control, and monitor risks related to money laundering, terrorism financing, and the proliferation of weapons of mass destruction. Its implementation includes policies, procedures, client due diligence, transaction monitoring, and ongoing staff training.
  • PTEE: A set of principles, rules, and actions aimed at fostering a corporate culture based on ethics, transparency, and integrity. The program seeks to prevent acts of corruption, bribery, conflicts of interest, and other behaviors detrimental to sound corporate governance.

These two systems are complementary and allow companies to demonstrate their commitment to regulatory compliance, corporate social responsibility, and organizational sustainability.

Who is required to implement them in 2025?

The following entities must implement both SAGRILAFT and PTEE, depending on their business activity, revenue, or legal nature:

  • Companies supervised or controlled by the Superintendence of Companies.
  • Companies with revenues or assets equal to or greater than 40,000 times the current legal monthly minimum wage (SMMLV) — approximately COP $52 billion for 2024.
  • Companies receiving contributions in virtual assets exceeding 100 SMMLV.
  • Companies engaged in high-risk activities, such as:
    • Precious metals trading
    • Construction
    • Real estate services
    • Legal, accounting, or audit services
    • Vehicle trade
    • Technology or financial services

Also required to comply:

  • Chambers of Commerce in Colombia
  • Foreign Non-Profit Entities (Entidades Sin Ánimo de Lucro Extranjeras – ESALES) with permanent business operations in Colombia

2025 Implementation Deadlines

According to the Superintendence of Companies, the updated deadlines are:

  • Currently obligated companies: must update and implement both SAGRILAFT and PTEE by March 31, 2025.
  • Newly obligated companies in 2025: must submit their implementation plan by June 30, 2025.
  • Chambers of Commerce and ESALES: must implement both systems by May 31, 2025.
  • Entities that become obligated after May 31, 2025: must implement both systems no later than May 31 of the year following their creation.

These deadlines were confirmed by External Circular 100-000003 of April 23, 2024, which amended Circular 100-000004 of October 4, 2023, allowing a reasonable transition period for entities to meet the required administrative and operational standards.

Consequences of Non-Compliance

Failure to implement SAGRILAFT and PTEE in a timely and proper manner may lead to serious legal, financial, and reputational consequences, including:

  • Investigations and sanctions by the Superintendence of Companies
  • Monetary fines and administrative measures
  • Disqualification from contracting with the government or with companies that require compliance
  • Loss of trust from business partners, clients, and investors
  • Exposure to fraudulent operations or misuse of the company for illicit purposes

Benefits of Implementing SAGRILAFT and PTEE

Beyond mere regulatory compliance, adopting these systems provides substantial advantages:

  • Strengthens organizational culture based on ethics and transparency
  • Reduces legal and financial risks
  • Enhances corporate reputation
  • Increases trust among clients, partners, and authorities
  • Identifies and corrects risky or vulnerable internal practices

Conclusion

The implementation of SAGRILAFT and PTEE is both a legal obligation and a strategic opportunity for companies in Colombia. It enables businesses not only to comply with regulatory standards set by the Superintendence of Companies but also to reinforce transparency, risk management, and long-term organizational sustainability.

At Trébol Jurídico, we are committed to promoting awareness of these regulatory obligations so that companies can make informed decisions aligned with Colombia’s legal framework.

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