On December 6, 2024 the Superintendence of Companies issued External Circular No. 100-300000 of 2024 (the “Circular”) that modifies numerals 4.4 and 4.5 of Chapters X and XIII of the Basic Legal Circular of the Superintendence of Companies (“BLC”) updating the requirements established to implement Self-Control and Risk Management Systems for Money Laundering, Terrorism Financing and the Financing of the Proliferation of Weapons of Mass Destruction (ML/TF/FPWMD) (“SAGRILAFT” by its acronym in Spanish) and Transparency and Business Ethics Programs (“PTEE” by its acronym in Spanish) in the Chambers of Commerce and in the Foreign Non-Profit Organizations with permanent businesses in Colombia (“Foreign NPO”).
The modification was made considering differences in size and income of the Chambers of Commerce and Foreign NPO, with the objective to rule the obligation to implement these programs with a risk-based approach for the obligated entities, as follows:
