PM Legal News – July 2026

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.

Public Works for Taxes in Bogotá: An Opportunity to Turn Your Tax Burden into Tangible Impact

Companies seeking to maximize the value of their social investment and strengthen their relationships with communities now have an innovative alternative for fulfilling part of their tax obligations: the “Works for Taxes” (Obras por Impuestos) program.

“Works for Taxes” is an alternative mechanism through which companies can pay a portion of their taxes in Colombia by carrying out projects that help reduce socioeconomic disparities. This mechanism does not reduce companies’ tax burden, but it can generate specific benefits.

In Bogotá, the “Works for Taxes” program can facilitate the creation of partnerships between companies, local communities, and the District. Furthermore, it allows for a more efficient and transparent use of tax revenues, as these funds are channeled toward specific public works projects. In this way, companies’ tax contributions become more visible and tangible.

At our firm, we assist domestic and international companies in structuring, feasibility studies, negotiation, and execution of projects under this scheme, helping them manage the legal, regulatory, and contractual risks that arise throughout the process.

What Are “Works for Taxes”?

The “Works for Taxes” program is a mechanism that allows individuals and legal entities to allocate a portion of their taxes to the financing and implementation of projects that contribute to social development and the closing of socioeconomic gaps.

Although this mechanism does not reduce the tax burden, it does allow the funds that a company is required to pay to be channeled into specific projects that are visible to the beneficiary communities.

In Bogotá, this program has become particularly significant due to its ability to coordinate efforts among the private sector, communities, and district agencies to promote projects with high social impact.

Key Considerations for Companies

Companies interested in participating should keep in mind that:

• The projects are funded with private resources contributed by taxpayers.
• The taxpayer assumes full responsibility for implementation.
• Regulatory supervision is required.
• Cost overruns are not reimbursed.
• The project must address the District’s needs and interests.
• The taxpayer may enter into contracts under its own contracting regime.

These characteristics make adequate legal, tax, and contractual planning essential from the project’s initial stages.

How does the process work?

A company’s participation in the mechanism involves several stages:

1. Identification of the project, whether it is an existing initiative or a proposal from the taxpayer.
2. Project structuring, including the definition of scope, costs, risks, and timeline.
3. Management of the feasibility study with the relevant district authority.
4. Approval and allocation of the quota by the relevant authority.
5. Formalization of the contract and project execution.

Each of these stages requires careful legal analysis to ensure compliance with regulatory requirements and minimize contingencies during implementation.

Two ways to participate

Trust (Fiducia) Option

Under this option, the company deposits a portion of the tax it was required to pay into a separate trust fund and receives a certificate that it may use at a later date.

Agreement (Convenio) Option

Under this program, the taxpayer enters into an agreement with a district government agency, carries out the project using their own funds, and receives, in return, District Territorial Renewal Certificates (TRTD), which they may later use to pay district taxes (property tax, vehicle tax, and ICA).

Current Opportunities in Bogotá

The District Secretariat for Social Integration (SDIS) currently has a portfolio of six projects spread across twenty neighborhoods in Bogotá. These projects focus on two main areas: providing social services to vulnerable populations and adapting infrastructure to be inclusive for people with disabilities.

These initiatives represent an opportunity for companies that want to make a measurable social impact while actively participating in the city’s development.

How can we help?

Our firm provides comprehensive advisory services to companies at every stage of Works-for-Taxes projects, including:

• Eligibility analysis and participation strategy.
• Legal and contractual structuring of the project.
• Regulatory due diligence.
• Negotiation of agreements and implementation contracts.
• Risk management and regulatory compliance.
• Support during project execution and supervision.
• Dispute resolution and claims handling.