Colombia's financial intelligence and supervisory authorities have moved decisively to tighten anti-money laundering (AML) controls across multiple business sectors. Companies that overlooked incremental regulatory changes in prior years now face materially higher exposure. The cost of non-compliance – in fines, suspended banking relationships, and reputational damage – has grown in parallel with the expanded reach of Colombian AML legislation.
Colombia's updated AML rules, effective from the start of 2025. Expand know your customer (KYC) and beneficial owner disclosure obligations to a broader set of obligated entities. This includes non-financial businesses operating above defined revenue and transaction thresholds. Companies must file updated beneficial owner registers, refresh customer due diligence records, and appoint a compliance officer within the deadlines set by the relevant supervisory authority. Failure to meet these requirements exposes companies to administrative sanctions and, in serious cases, restriction of access to the Colombian financial system.
This alert explains what has changed, which companies are affected, and the concrete steps that international businesses operating in Colombia must take without delay.
What changed – and when it takes effect
Colombian AML legislation has been progressively reformed to align with Grupo de Acción Financiera de Latinoamérica (GAFI – the Latin American Financial Action Task Force) recommendations. The 2025 update introduces several changes of direct relevance to companies with Colombian operations.
First, the scope of obligated entities has been expanded. Previously, AML duties fell primarily on banks, insurance companies, and regulated financial intermediaries. The updated rules now extend to real estate companies, legal services providers, accountants, trust administrators. Additionally, certain categories of commercial importers and exporters. There. Annual revenue or transaction volumes exceed the thresholds set by the Superintendencia Financiera de Colombia (Colombian Financial Superintendency) and the Unidad de Información y Análisis Financiero (UIAF. Financial Information and Analysis Unit).
Second, the rules governing beneficial owner disclosure have been significantly strengthened. Any natural person holding – directly or indirectly – a material ownership interest or exercising effective control over a Colombian legal entity must be registered and verified. The definition of control has been widened to capture indirect shareholding structures and arrangements that convey economic benefit without formal ownership.
Third, debida diligencia (due diligence) requirements for bank account opening and ongoing customer monitoring have been enhanced. Financial institutions are now required to conduct enhanced scrutiny for clients whose structures involve foreign holding companies, nominee arrangements, or complex cross-border ownership chains. Companies seeking to open a bank account or maintain a credit facility with a Colombian bank should expect more detailed document requests and longer onboarding timelines.
Fourth, correspondent banking relationships with foreign institutions are subject to new documentation standards. Colombian banks must apply risk-based controls that their foreign counterparties are now expected to mirror. International businesses transacting through Colombian correspondent banking channels need to verify that their own compliance documentation meets the updated standards.
The primary compliance deadline for existing obligated entities to update their registers and internal procedures was set at the first quarter of 2025. For newly captured categories of non-financial obligated entities, a grace period was granted, with full compliance required by mid-2025. Companies that have not yet acted are already in breach.
Which companies are affected
The updated rules capture a wide range of business categories. An international company operating in Colombia should assess its exposure across four primary dimensions.
Sector: Financial institutions, insurance companies, leasing entities, and capital markets intermediaries remain the core obligated group. They are joined by real estate developers and brokers, dealers in high-value goods (luxury items, vehicles. Additionally, art). Legal and accounting service providers advising on corporate transactions. Additionally, customs agents or logistics companies handling significant import and export flows.
Revenue and transaction thresholds: Non-financial businesses fall within scope when their annual turnover or individual transaction values exceed levels defined by supervisory circular. The thresholds differ by sector and are indexed in Colombian pesos. International companies should obtain a current threshold table from their Colombian counsel, as the figures are subject to periodic adjustment.
Ownership structure: Any company with a layered shareholding structure, a foreign parent, or arrangements involving trusts or foundations must complete a full beneficial owner mapping exercise. The UIAF's updated guidance makes clear that opaque structures are a priority risk category. Companies that rely on nominee shareholders or directors face additional scrutiny.
Banking and credit relationships: Any company that maintains a bank account in Colombia, holds a credit facility with a Colombian financial institution, or processes payments through the Colombian financial system is directly affected. Banks are now required to request updated KYC documentation from all existing corporate clients on a risk-tiered schedule.
For a detailed assessment of how these rules interact with capital markets activity in Colombia, see our analysis of capital markets services in Colombia.
To receive an expert assessment of your company's AML exposure in Colombia, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
Companies that have not yet reviewed their Colombian compliance posture should act on the following items without delay.
- Map all beneficial owners: Identify every natural person who holds a direct or indirect ownership interest above the applicable threshold, or who exercises effective control. Document the ownership chain with supporting corporate records.
- Update the beneficial owner register: File updated information with the competent Colombian authority. Where the company is supervised by the Colombian Financial Superintendency, use the dedicated reporting channel. Non-financial obligated entities must register through the UIAF's platform.
- Appoint or confirm a compliance officer: Colombian AML legislation requires each obligated entity to designate a responsible officer. Verify that this appointment is current, properly documented, and the officer has completed required training under the applicable supervisory guidelines.
- Refresh KYC files for all counterparties: Review client and supplier files against the updated due diligence standards. Enhanced scrutiny applies to counterparties with foreign structures, politically exposed persons, or links to high-risk sectors.
- Review bank account and credit facility documentation: Proactively contact your Colombian banking relationships and provide updated corporate documentation, beneficial ownership certificates, and any additional KYC materials requested under the new standards.
Engaging a lawyer in Colombia with cross-border AML experience is the most efficient path to closing compliance gaps quickly. Our banking and finance services in Colombia cover the full range of AML compliance requirements for international businesses. For a comparison of how Colombia's AML obligations interact with those of other jurisdictions, our alert on AML updates in the United States provides a useful cross-border reference point.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm in Lisbon advising business clients across 46 jurisdictions. As a law firm in Colombia and across Latin America, we assist international companies, financial institutions, and investors with AML compliance, KYC frameworks, beneficial owner mapping, and banking regulatory matters. Our team combines Portuguese civil law expertise with English common law tradition, giving us the dual-tradition perspective that cross-border compliance work demands. Our Americas practice covers correspondent banking compliance, credit facility structuring, and engagement with the UIAF and Colombian Financial Superintendency. Practitioners across our network have advised on AML matters in both civil law and common law systems. To discuss your company's compliance obligations in Colombia, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.