External Circular No. 100-000004 of April 9, 2021
The Superintendence of Companies has extended the deadline to implement SAGRILAFT and dictated other provisions
The Superintendence of Companies (the “Superintendence”) enacted the External Circular No. 100-000004 of April 9, 2021 (the “Circular”) by means of which it was extended the deadline to adopt a System of Integral Risk Management for Money Laundering, Terrorism financing and financing of the proliferation of mass-destruction weapons (“SAGRILAFT”), established in External Circular 100-000016, 2020, until August 31, 2021.
In addition, the Circular included other modifications to the SAGRILAFT, including the following ones:
Branch of a Foreign Company: When the entity obliged to adopt SAGRILAFT is a branch of a foreign company, it would be the corporate body of the parent company (i) the one designating the Compliance Office and (ii) to who the Compliance Officer must submit it reports.
Evidence of the registration at SIREL: When submitting the communication to the Superintendence of Companies regarding the appointment of the Compliance Officer, along with other documents, it must be sent a copy of the document evidencing that the Compliance Officer has been registered before the SIREL managed by the UIAF.
Incompatibility of the Compliance Officer: The incompatibility of the Internal Auditor to be appointed Compliance Officer, does not extend to those who support the activities of the internal audit or control bodies.
Domiciled in Colombia: The Compliance Officer must be domiciled in Colombia.
Author: Raúl Vargas I [email protected] I Corporate Law