The Superintendence of Companies clarified that consortiums are not required to implement Corporate Ethics Programs nor Self-Control and Risk Management System against Money Laundering and Terrorism Financing.

By means of Legal Concept No. 220-132332 of December, 2019, the Colombian Superintendence of Companies indicated that article 23 of Law 1778, 2016, that sets the obligation to implement an Ethical Corporate Program, only applies to: (i) companies under the Superintendence’s surveillance or control, and (ii) that comply with the criteria of international businesses, total income, total assets, or employees, established in the law. Accordingly, such obligation does not apply to consortiums.

Also, the Superintendence clarified that the obligation to implement a Self-Control and Risk Management System against Money Laundering and Terrorism Financing (SAGRLAFT) only applies to: (i) companies under the Superintendence’s surveillance or control, and (ii) that comply with the criteria of total income established to the corresponding economic sector which the company belongs to. Therefore, such obligation does not apply either to consortiums