On July 2, 2026, the Colombian Superintendency of Companies (Superintendencia de Sociedades) issued External Circular 100-000020, which comprehensively updates the Basic Legal Circular and introduces the new Chapter IX – Self-Control and Risk Management System for ML/TF/PF and LC/TB (Sistema de Autocontrol y Gestión de Riesgos LA/FT/FP y C/ST). This landmark regulatory reform consolidates into a single normative framework all obligations previously divided between the SAGRILAFT (anti-money laundering and counter-terrorism financing) and the PTEE (transparency and anti-corruption program), creating a unified system addressing money laundering, terrorism financing, proliferation of weapons of mass destruction, local corruption, and transnational bribery.

Key changes include: (i) adoption of the Basic Value Unit (UVB) as the new calculation basis for applicability thresholds and sanctions; (ii) expanded scope of obligated entities to expressly include confederations of chambers of commerce and foreign non-profit organizations with permanent operations in Colombia; (iii) mandatory specific and detailed policies on gifts, political contributions, donations, lobbying, government contracting, and codes of ethics; (iv) an obligation to update Due Diligence annually for high-risk counterparties (previously every two years); and (v) the inclusion of new economic sectors under the Minimum Measures Regime, including the pharmaceutical and infrastructure/construction industries.

Obligated entities currently complying with External Circulars 100-000016 of 2020, 100-000011 of 2021, and 100-300000 of 2024 must align their systems with the new framework no later than May 31, 2027. During the transition period, currently implemented systems remain valid. The reduction of the minimum permanence period (from three to two years for the System, and one year for the Minimum Measures Regime) and the Superintendency's authority to mandate implementation at any time for non-obligated entities reflect a more proactive and preventive supervisory posture.