The Superintendence of Companies issued Circular Letter 100-000003 on April 23, 2024, with the purpose of amending Circular Letter 100-000004 dated October 4, 2023, specifically regarding the deadlines for the implementation of the Money Laundering, Financing of Terrorism, and the Proliferation of Weapons of Mass Destruction Self-control and Integral Risk Management System-SAGRILAFT and the Transparency and Business Ethics Program (PTEE) by Chambers of Commerce and Foreign Non-Profit Entities (ESALES) with permanent operations in Colombia.

Considering the human, financial, and administrative resource requirements needed to implement these risk management Systems, a transition period has been established to allow Chambers of Commerce and ESALES with permanent operations in Colombia, as new obligated parties, to fully comply with the administrative instructions and other requirements. The new deadlines are as follows:

Deadlines:

• Chambers of Commerce and Foreign Non-Profit Entities with permanent operations in Colombia that are currently under the supervision of this Superintendence must implement the SAGRILAFT and PTEE according to the terms of Chapters X and XIII of the Legal Basic Circular of this Entity, no later than May 31, 2025.
• Once the previous deadline has elapsed, Chambers of Commerce and Foreign Non-Profit Entities with permanent operations in Colombia must implement the SAGRILAFT and PTEE no later than the following May 31 after their creation, in accordance with the provisions of section 7.1. of Chapter X and section 9 of Chapter XIII.

It is worth noting that, from the entry into force of Circular Letter 100-000003 dated April 23, 2024, Chambers of Commerce and Foreign Non-Profit Entities (ESALES) with permanent operations in Colombia have until May 31, 2025, to adjust and implement a SAGRILAFT and a PTEE, as established in Chapters X and XIII of the Legal Basic Circular. During this transition period, the Superintendence of Companies will not require compliance with the obligations associated with both systems.