Compliance and anti-corruption
Business ethics programs, anti-money-laundering (SAGRILAFT) and whistleblowing channels.
Companies answer for what their officers, employees and intermediaries do. Law 1778 of 2016 makes legal entities liable for transnational bribery, and Law 2195 of 2022 broadened the sanctionable conduct and strengthened the duty to adopt a business transparency and ethics program. The Superintendence of Companies (Superintendencia de Sociedades) also requires SAGRILAFT, a self-control and risk-management system against money laundering and terrorism financing, from companies above certain thresholds or in supervised sectors.
We design and implement these programs according to each company's size, sector and actual exposure, so that they work in practice and not only on paper. We support the compliance officer and the board of directors when an alert, a whistleblower report or an inquiry from the authority arises.
When an internal investigation requires it, we work in coordination with our employment, corporate and litigation practices.
What we do
- Risk assessments covering corruption, transnational bribery and money laundering.
- Design and implementation of the Business Transparency and Ethics Program (PTEE, for its Spanish acronym).
- Design and implementation of SAGRILAFT: manuals, risk matrices and know-your-counterparty procedures.
- Drafting of codes of ethics and of policies on gifts, conflicts of interest and dealings with public officials.
- Design and operation of whistleblowing channels and internal investigation protocols.
- Internal investigations into suspected fraud, bribery or misappropriation, with preservation of evidence.
- Integrity due diligence on partners, suppliers, distributors and acquisition targets.
- Training for boards of directors, officers and compliance officers.
- Handling of inquiries, inspection visits and sanction proceedings before the Superintendence of Companies.
- Anti-corruption and compliance clauses in contracts with third parties.
Questions we answer
- Is my company required to have SAGRILAFT or a business transparency and ethics program?
- We received an anonymous report against a manager. How do we investigate without exposing the company?
- What is the company's liability if an intermediary pays a bribe abroad on our behalf?
- Can I give gifts or invitations to public officials at the entities we have contracts with?
- What should the board of directors review in the compliance officer's report?
- A client is asking us to sign an anti-corruption representation. What are we agreeing to?
Let's talk
Tell us the decision you have to make. We reply the same business day.
Write to us