On March 6, 2025, the Superintendence of Transportation issued Resolution No. 2328, which: (i) amends Chapter 6, Title V of the Single Circular on Infrastructure and Transportation; (ii) repeals Resolution No. 74854 of December 21, 2016; and (iii) establishes the mandatory implementation of the Anti-Money Laundering and Counter-Terrorism Financing Risk Management System (SARLAFT), replacing the previous Prevention and Control System (SIPLAFT).

I. OBLIGATED ENTITIES

One of the main changes introduced by this Resolution is the expansion of the scope of obligated entities. Previously, the obligation to implement SIPLAFT applied exclusively to companies authorized to provide ground freight transportation services.

With Resolution No. 2328, the obligation is extended to companies under the supervision, oversight, and control of the Superintendence of Transportation, including those listed below:

1. Companies authorized to provide public freight transportation services, using any mode: maritime, rail, river, air, or road.
2. Companies authorized to provide public passenger transportation services, using any mode: maritime, rail, river, air, or road.
3. Transportation infrastructure concessionaires whose corporate purpose includes the operation, maintenance, and/or management of public service infrastructure or related services.
4. Special transportation companies.
5. Mixed transportation companies operating at a national level.
6. Comprehensive Driver Support Centers.
7. Driving Schools.
8. Vehicle Diagnostic Centers.
9. Driver Recognition Centers.
10. Companies authorized to provide cable car transportation services.
11. Multimodal transportation operators (national or international).
12. Companies authorized to dismantle private and public vehicles.
13. Port companies, whether concessioned or certified.
14. Port operators.

II. CONTENT OF SARLAFT

SARLAFT must be designed and implemented in accordance with the nature, size, geographic location, and internal and external context of the company, among other characteristics. The system must include the following components:

• Risk Management Policy: This must align with the company’s structure and operations.
• SARLAFT Procedures Manual: This document must describe, in an orderly and systematic manner, the guidelines and procedures for managing ML/TF/FPADM risks.
• SARLAFT Code of Ethics and Conduct: The code must aim to foster a strong compliance culture within the company.

III.RESPONSIBLE PARTIES FOR SARLAFT IMPLEMENTATION

• Shareholders Meeting or Board of Directors: Responsible for approving SARLAFT and appointing the compliance officer.
• Legal Representative: Must ensure the availability of resources and provide support to the compliance officer.
• Compliance Officer: Leads the implementation, updating, and monitoring of SARLAFT.
• Statutory Auditor: Must report potential inconsistencies and deficiencies in the SARLAFT in the annual report.

IV. COMPLIANCE OFFICER PROFILE

The compliance officer must:
(i) reside in Colombia;
(ii) have education and experience in ML/TF/FPWMD risk management; and
(iii) have completed the UIAF training course.

The compliance officer must not be part of the management or statutory auditing bodies.

V. SUSPICIOUS TRANSACTION REPORTING

Unusual or suspicious transactions must be reported immediately to the UIAF.

VI. SANCTIONS

Failure to comply with the Resolution may result in sanctions imposed by the Superintendence of Transportation. Penalties vary by sector:

Sector	Range of Sanctions
Ground Transportation	From 1 to 700 SMMLV
River Transportation	From 1 to 1,000 SMMLV
Maritime Transportation	From 1 to 1,500 SMMLV
Rail Transportation	From 1 to 1,500 SMMLV
Air Transportation	From 1 to 2,000 SMMLV

VII. IMPLEMENTATION DEADLINE AND TRANSITION PERIOD

Companies that acquire the status of obligated entities will have eight (8) months from the issuance of the Resolution — that is, until November 6, 2025 — to comply.

Entities that were already required to implement a compliance system must update it to SARLAFT within the same timeframe. At Lloreda Camacho & Co., we have the experience and technical expertise to support companies in the transportation sector with the design, update, or implementation of their SARLAFT. If your company is included in the list of obligated entities or wishes to prepare for a potential inspection, please do not hesitate to contact our Compliance team.

Author: Alejandra Villada