SAGRILAFT & PTEE
Understand our local regulations to ensure proper business conduct worldwide.
Dear customer, supplier, employee, or business associate,
Colombia adheres to the recommendations of the FATF (Financial Action Task Force), the global body leading efforts to combat money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction.
Accordingly, C.I. FLORES DE APOSENTOS S.A.S. implements the Colombian system known as SAGRILAFT with all our clients, which aims to prevent risks related to money laundering, terrorism financing, and the proliferation of weapons of mass destruction. In addition, we apply the PTEE program, which is designed to prevent acts of corruption and transnational bribery.
What is SAGRILAFT?
It is the System of Self-Control, Prevention, and Comprehensive Risk Management Against Money Laundering and Terrorism Financing and Financing of the Proliferation of Weapons of Mass Destruction.
It is regulated in Colombia by: External Circular N° 100-000016 | External Circular N° 100-000004
SAGRILAFT: Sistema de Autocontrol y Gestión del Riesgo Integral de Lavado de Activos, Financiación del Terrorismo.
What is PTEE?
It is the Business Transparency and Ethics Program that aims to identify, detect, prevent, manage, and mitigate Corruption Risks or Transnational Bribery Risks that may affect the company.
It is regulated in Colombia by: Circular N° 100-0000011 | Circular N° 100-0000012
PTEE: Programa de Transparencia y Ética Empresarial.
Terms used in SAGRILAFT & PTEE:
ALERT SIGNAL: Qualitative or quantitative indicators that allow identifying behaviors that deviate from the parameters.
UNUSUAL OPERATION: Amount or characteristics that do NOT relate to economic activity, which due to their number, amounts, or particular characteristics, deviate from the criteria and parameters.
SUSPICIOUS OPERATION: an operation that, according to the customs and practices of the activity in question, could not be reasonably justified.
Predicate Offenses Related to Money Laundering
Money laundering is a criminal act committed by an individual or group with the purpose of obtaining large sums of money. These actions are defined in Article 323 of the Colombian Penal Code, which outlines the offense of money laundering and everything it encompasses.
In other words, anyone who acquires, safeguards, invests, transports, converts, manages, or handles money derived from illicit activities related to predicate offenses is committing the crime of money laundering.
Smuggling of Migrants:
Facilitating the irregular entry into or exit from a country of one or more individuals, with the intent of obtaining personal monetary or material gain.
Extortion:
Forcing or coercing someone to do, tolerate, or refrain from doing something through violence or intimidation, in order to obtain an unlawful benefit for oneself or a third party.
Aggravated Kidnapping (for Extortion):
The act of seizing, abducting, detaining, or hiding a person with the intent of obtaining a benefit, profit, or advantage—whether monetary or otherwise—in exchange for their release, or to force someone to act or refrain from acting.
Human Trafficking:
The recruitment, transportation, or harboring of individuals within or outside the national territory for the purpose of exploitation, such as forced prostitution, forced labor, or coerced begging.
Illicit Enrichment:
The unjustified or unsupported increase in a person’s wealth, typically resulting from illegal activities.
Rebellion:
The use of arms to attempt to overthrow the national government or alter the existing constitutional or legal regime.
Manufacturing, Trafficking, and Possession of Firearms or Ammunition:
Engaging in the trafficking, manufacturing, transportation, storage, sale, supply, possession, or keeping of firearms for personal defense, their essential parts, accessories, or ammunition without authorization from the competent authority.
Smuggling:
The import or export of goods into or out of the national territory without paying customs duties or through illegal means.
Misuse of Funds Collected from the Public:
Occurs when the director or manager of a company regulated by the Financial Superintendency uses funds collected from the public, without legal authorization, to gain control over other entities or companies.
Terrorism Financing:
Providing, collecting, managing, or storing funds, or promoting, supporting, or sustaining illegal national or foreign armed groups or their members.
Conspiracy to Commit a Crime:
When two or more individuals join together with the intent to commit one or more criminal offenses.
Crimes Against Public Administration:
Includes embezzlement of public funds, extortion by a public official, bribery, improper contracting, influence peddling, and malfeasance in office.
Drug Trafficking or Possession:
The manufacturing, possession, commercialization, processing, or storage of any narcotic, psychotropic substance, or synthetic drug as defined by law, without the required legal authorization.
Report any suspicious activity that violates SAGRILAFT and PTEE at any time and anonymously through the following channels:
Ethics Line: lineaetica@aposentos.com.co
Colombia’s Anti-Corruption – PACO (secretariatransparencia.gov.co)
Transactional Bribery Reporting Channel – Corporate Economic Affairs (supersociedades.gov.co)
