New SARLAFT regulation for foreign exchange professionals: What you need to know

The resolution expressly repeals Resolution 061 of 2017 and Resolution 029 of 2020, consolidating a more robust, updated, and internationally aligned regulatory framework into a single normative body.

This new regulation is not merely an update but a strategic response aligned with the international standards of the Financial Action Task Force (FATF). Its goal is to harmonize risk management practices of exchange professionals with the demands of the financial sector. In this way, DIAN moves away from a "what to do" model to adopt a "how to do it" approach, based on evidence and technical focus, implying a comprehensive and documented risk management process.

The main changes introduced by Resolution 210 regarding the SARLAFT are as follows:

Scope of application

The SARLAFT-FPWMD is mandatory for all natural or legal persons authorized and registered as exchange professionals with DIAN. Its implementation must cover every foreign currency purchase or sale transaction, regardless of the channel used (establishment, at home, or electronic).

Stages of the SARLAFT-FPWMD

This system must be structured based on four fundamental stages: identification, measurement, control, and monitoring.

• Identification: involves recognizing the risks inherent to the activity, considering factors such as type of client, product, distribution channel, and geographic jurisdiction.

• Measurement: evaluates the probability and impact of the identified risks, establishing levels such as high, medium, or low.

• Control: preventive and detection measures are designed to mitigate risks, including the creation of early warning alerts.

• Monitoring: involves periodically reviewing the system's effectiveness and conducting documented self-assessments at least every six months.

The SARLAFT-FPWMD must include policies, procedures, documentation, organizational structure, control bodies, technological infrastructure, dissemination strategies, and a training plan. All of this must be properly documented and kept up to date, with records that demonstrate the system’s implementation and operation. Exchange professionals must retain these documents for the legal retention period.

Types of customer Due Diligence (CDD)

One of the pillars of the system is customer knowledge. Depending on the type of transaction, amount, or risk profile, a Due Diligence category will be applied:

• General: for common transactions, includes verification of identity, origin and destination of funds, economic activity, and contact information.
• Enhanced: applies to Politically Exposed Persons (PEP) or clients from high-risk countries according to FATF. Requires approval from senior management and intensified monitoring.
• Simplified: for border zones or amounts less than USD 500, includes minimum but sufficient requirements to verify identity and economic activity.
• Amount-Intensified: applies to transactions equal to or greater than USD 10,000 or its equivalent. Requires extensive documentation, rigorous monitoring, and if unable to comply, rejection of the transaction and ROS reporting.

Due Diligence is also required for Internal Clients, focusing on verifying the suitability of employees, partners, and contractors, as well as the origin of contributions and links to PEP.

Mandatory Reports

The foreign exchange professional is legally obliged to report to the UIAF any suspicious transaction (STR) that he/she detects in the course of his/her activity. The report must be immediate and may include attempted, rejected or completed transactions. In addition, international sanctions lists (UN, FATF) must be followed up and possible links with illicit activities must be reported to the Prosecutor's Office, using the electronic channels provided.

Training and the essential role of the compliance officer

Training on the SARLAFT-FPWMD is mandatory and must be conducted at least twice a year, including new employees from the start of their employment.

The Compliance Officer is the central figure in the implementation and oversight of the SARLAFT-FPWMD. They must act autonomously, have the support of the legal representative, and serve as the direct channel for reports to the UIAF. Their role is vital to ensure the system’s effectiveness and to avoid sanctions. Without this active role, compliance becomes a mere formality. This role should be supported by control bodies such as the Statutory Auditor or Internal Audit, who will verify the effective execution of the system and escalate any findings.

Penalties for Non-Compliance

Failure to comply with these obligations may result in cancellation of the registration, fines, and sanctioning processes by DIAN. Failure to apply Due Diligence, omission of reports, use of unauthorized channels, or lack of supporting documentation are grounds for infringement.

Conclusion

The SARLAFT-FPWMD is not merely a regulatory requirement but a fundamental tool to safeguard operations and manage risks with a technical and strategic approach. DIAN has raised the standards of compliance, now requiring solid evidence, effective traceability, and rigorous adaptation to each entity’s risk profile.

It is imperative to review and update the SARLAFT policy in accordance with the new provisions. Moving from formal compliance to proactive risk management has become an unavoidable obligation. Adopting measures responsibly and with a preventive outlook is essential to ensure the sustainability and credibility of the business in the long term.

How can we help you?

At Forvis Mazars, we have a team of highly skilled professionals experienced in complying with Resolution 210 of 2025, related to SARLAFT for foreign exchange professionals. Our deep knowledge of the sector and the requirement for implementing this regulation enables us to provide comprehensive and effective support.

If you require assistance with the implementation or compliance with the obligations established in this resolution, please do not hesitate to contact us through the email addresses provided. We will gladly analyze your situation and find the best way to offer you the support you need.