The SARLAFT challenge in receivables recovery: what to do when payment comes from a third party
In receivables recovery, every payment counts. But there is one scenario that can turn good news into a serious problem: when the money is paid not by the debtor, but by a third party who appears out of nowhere and without a clear explanation.
Oversight of the origin of funds in Colombia is increasingly strict. In 2024 alone, the UIAF (Colombia’s Financial Information and Analysis Unit) received more than 600 alerts for possible money laundering operations, and authorities have tightened the traceability of every transaction. In that context, accepting a third-party payment without verifying it stops being an administrative detail: it is a risk your company takes on without realizing it.
At Trébol Jurídico, we explain what SARLAFT requires in these cases and how to protect your receivables without slowing down your recovery.
Why does a third-party payment raise red flags?
SARLAFT —the System for the Administration of the Risk of Money Laundering and Terrorism Financing— is built on a simple idea: you must know your counterparty and understand where the money you receive comes from.
A payment made by a third party is one of the most widely recognized warning signs, because it is one of the most common ways to introduce funds of questionable origin into an operation that, on paper, looks flawless. If you apply those funds without documenting anything, you may end up linked —without knowing it— to a chain you do not control.
A nuance is worth noting here: this is not about distrusting everyone who pays on someone else’s behalf. A parent company covering its subsidiary, or a partner settling an obligation, are legitimate situations. The problem is not the payment itself, but applying it without understanding it or leaving a trace.
Warning signs worth reviewing before applying the payment
None of these situations, on its own, implies a problem. But when several of them coincide, the prudent move is to review before accepting the money:
- A third party with no apparent connection to the debtor settles the entire debt, unexpectedly.
- The payment arrives split across several accounts or different people.
- You are offered payment in cash or through channels that are hard to trace.
- The payer has a profile inconsistent with the amount, or appears on restrictive lists (OFAC, UN).
- There is pressure to close quickly and without providing supporting documents.
What to do when the payment comes from a third party
Beyond the regulation itself, these are concrete actions any receivables team can apply:
- Verify the relationship between the payer and the debtor. A written authorization explaining the link already counts as valid support.
- Request a declaration of the source of funds for significant amounts, just as you would when onboarding a new client.
- Screen the payer against restrictive lists (OFAC, UN) before applying the payment.
- Document the entire process. Verification that is not recorded has no evidentiary value if you ever need to prove that you acted in good faith.
- Report any unusual transaction to your compliance officer. The report protects your company; it does not incriminate it.
If your company does not yet have a structured SARLAFT program, or needs to adjust it, that support is best provided by your accountant, your statutory auditor, or your compliance officer.
The Trébol Jurídico approach: recovering without passing the risk on to you
At Trébol Jurídico, we specialize in strategic corporate receivables recovery. An essential part of our methodology is that every debtor entering our collection process first passes through an internal money laundering and terrorism financing (ML/TF) prevention filter.
This is not a formality. It is a deliberate decision that allows us to operate transparently and ensure that the money we recover for you arrives clean and traceable, without creating additional risk for any of the parties.
In summary
A payment that comes from a third party is not, in itself, a problem. The problem is applying it without understanding or documenting it, in an environment where control over the origin of money grows stricter by the day.
Knowing your counterparty, verifying the source of funds, and relying on a specialized ally is not a crisis measure: it is how you protect your company’s liquidity and assets while recovering what you are owed.
Want to know how to apply these criteria in your receivables process? Contact us at Trébol Jurídico and protect your recovery from the very first peso.
📞 Trébol Jurídico — Strategic Corporate Receivables Recovery
