Information framework

The United Nations International Convention for the Suppression of the Financing of Terrorism of 1999 determined the need to create measures to prevent and counteract the financing of terrorists directly or indirectly and committed States to demand criminal, civil or administrative responsibility from those who finance terrorist activities.

For its part, the Financial Action Task Force – FATF[1] – designed forty (40) recommendations in 1990 and subsequently established nine (9) special recommendations against the financing of terrorism. Subsequently, in 2012 they were reviewed, and international standards on the fight against Money Laundering and the financing of terrorism (ML/FT) were issued with flexible measures according to the nature of the risks.

All these United Nations conventions and conventions through various laws and rulings of the Constitutional Court have been ratified by Colombia, in order to confront criminal activities related to money laundering and the financing of terrorism, within which find:

  • Vienna Convention of 1988.
  • United Nations Convention for the Suppression of the Financing of Terrorism of 1999.
  • Palermo Convention of 2000.
  • Mérida Convention of 2003.


General Policies

Specific policies

Know Your Customer Policy

Supplier knowledge and linkage policy

Shareholder knowledge policy


Internal Reports

External Reports


Sagrilaft Committee

The Company will have a SAGRILAFT Committee with responsibilities for monitoring the different cases that respect the risks of ML/FT/FPDAM in the operation of the Company and will give rise to a summons at the time required by some of the parties that make it up. .

The Committee will be made up of the general manager, the administrative director and the Compliance Officer; and the different areas of the Company will be summoned, as appropriate, if necessary.

  • The Committee may be convened at any time at the request of the Compliance Officer in order to analyze unusual or suspicious operations.
  • Approve the objective criteria and establish the procedures and bodies responsible for determining and reporting suspicious operations.
  • Receive reports on suspicious and unusual operations found in SAGRILAFT monitoring and make decisions regarding them.
  • Rule on the points of the ML/FT/FPADM issue related to the reports of the Internal Audit and/or Statutory Auditor if presented and follow up on the observations or recommendations adopted, leaving the express record in the respective minutes.
  • This must evaluate the effectiveness and compliance of SAGRILAFT, in order to determine the deficiencies and their possible solutions to the identified gaps.


Any employee or third party who suspects money laundering or terrorist financing activity in the Company must immediately notify the Compliance Officer, via email: