News Flash – External Circular 100-000020 of 2026

On July 2, 2026, the Superintendency of Corporations issued External Circular 100-000020, which adopts a new Basic Legal Circular and comprehensively amends the regulatory framework applicable to the prevention of:

• Money laundering (LA)
• Terrorism financing (FT)
• Financing of the proliferation of weapons of mass destruction (FP)
• Corruption and transnational bribery (C/ST)

Repeal of Previous Regulations

 The new circular repeals and replaces the following External Circulars:

• 100-000016 of 2020 (SAGRILAFT – Chapter X)
• 100-000011 of 2021 (PTEE – Chapter XIII)

Important Changes

 SAGRILAFT and PTEE are consolidated into a single instrument titled: “LA/FT/FP and C/ST Self-Regulation and Risk Management System,” contained in Chapter IX of the new Basic Legal Circular.

• The term “obligated company” is changed to “obligated entity.”
• The acronym FPADM (Financing of the Proliferation of Weapons of Mass Destruction) is simplified to FP.
• With regard to the financial thresholds that determine the system’s scope of application, the Current Legal Monthly Minimum Wage (SMLMV) will no longer be used as the reference unit; instead, Basic Value Units (UVB) are adopted.
• The Colombian Confederation of Chambers of Commerce (CONFECÁMARAS) is included as an obligated entity.
• Under the Minimum Measures Regime, several sectors that were not previously covered are also incorporated:
  • The pharmaceutical sector (ISIC 2011 codes 2100, 3250, 4645)
  • The manufacturing sector
  • The mining and energy sector
  • The vehicle trade sector (ISIC codes 4511, 4512, G4541), which is also subject to the full system when it exceeds the respective threshold
  • Monitoring: Minimum frequency of once per year for high-risk counterparties. Minimum frequency of once every two years for medium- or low-risk counterparties.
• Regarding transparency and business ethics, mandatory policies must be established, such as those covering: the delivery and offering of gifts or benefits to third parties, political contributions, donations, travel and lodging expenses, and the filing and preservation of documents.
• The appointment of a deputy compliance officer is required; this individual must meet the same qualifications and requirements established for the principal compliance officer.
• Compliance officers must demonstrate and update their knowledge of ML/TF/FP and C/ST risk management at least once every three (3) years, in addition to demonstrating a minimum of one (1) year of professional experience in positions related to regulatory compliance in ML/TF/FP and C/ST risk management activities. Training is validated through formal education programs—specializations or master’s degrees—or through informal education programs, that is, “certificate programs provided they have a minimum duration of ninety (90) hours” with a direct and specific relationship to the subject matter.

Differences from the Previous Regulation

 Previously: two parallel systems (SAGRILAFT – Chapter X / PTEE – Chapter XIII).

• Problem: duplication of obligations, bodies, and reporting requirements.
• Now: a comprehensive approach that manages all risks jointly.

Transition Period and Recommendations

• Regulated entities must make the required adjustments to the new system by May 31, 2027.
• During the transition period, the current systems will remain valid.

Peña Mancero Abogados offers support in the integration of systems and implementation of the necessary adjustments to ensure compliance with the new obligations within the established deadline.