On March 6, 2025, the Superintendency of Transportation issued Resolution 2328 of 2025, which modifies Chapter 6 of Title V of the Single Circular on Infrastructure and Transportation, imposing the mandatory use of SARLAFT for a wide range of companies in the transportation sector, replacing the previous SIPLAFT.
Resolution 2328 of 2025 represents a regulatory milestone: it requires companies in the transport sector in Colombia to incorporate a robust and efficient system for the prevention of money laundering, terrorist financing, and arms proliferation (SARLAFT). With the elimination of SIPLAFT and the relaxation of the Compliance Officer profile, the aim is to democratize access to these mechanisms, even for smaller companies.
This resolution applies to multiple supervised entities, including:
- Public freight and passenger transport companies (land, sea, rail, river, air).
- Special and mixed transporters.
- Infrastructure concessionaires.
- Multimodal operators.
- Port companies and operators.
- Automotive diagnostic centers, driving schools, and driver testing centers.
- Cable transport companies.
- Vehicle dismantling companies.
The main objective of this resolution is to prevent the transport sector from being used for illicit activities such as smuggling, drug trafficking, money laundering, terrorist financing, or weapons proliferation, by strengthening internal controls with regulations aligned with international standards such as FATF and GAFILAT.
Companies have eight months from the date of notification or authorization, which sets November 6, 2025, as the deadline for implementation.
Implementation must consider at least the following:
- Clear ML/TF/FP risk management policy, tailored to the business model.
- Procedures manual, code of ethics, risk matrix (identification, probability and impact analysis, preventive/detective/corrective controls, monitoring).
- Organizational structure with:
- Compliance Officer, flexible profile (technician, technologist, or professional with training in ML/TF/FP, with the possibility of external hiring), responsible for design, monitoring, audits, and reports to the FIU.
- Approval of the system by the board of directors or highest corporate body, allocation of resources, and oversight of supervision.
- Constant monitoring and immediate reporting of suspicious transactions to the UIAF, including reporting “Absence of STR” when appropriate.
- Ongoing training, internal dissemination, and education on compliance culture, as well as technological support tools.
- Due diligence (knowledge of the customer/supplier), CDD/EDD procedures, identification of counterparties and beneficial owners.
- Periodic audits and a focus on continuous improvement of the system.
The Superintendency created a specific Oversight Committee to validate the effective implementation of SARLAFT, using monitoring tools. Non-compliance may result in penalties such as fines, suspension, or even revocation of the license to operate.
Companies that comply fully not only mitigate legal and reputational risks, but also strengthen their position as reliable players in a global environment that is increasingly demanding in terms of transparency and ethical standards.
* * *
The key to thriving in this new global order will be to anticipate, adapt, and take advantage of the opportunities that arise in a multipolar world.
At CID-Pro Consulting, we are committed to helping our clients navigate this complex environment by providing strategic analysis and solutions tailored to their needs.
Related posts
