Legal and compliance
LEGAL

SAGRILAFT

Anti-Money Laundering & Counter-Terrorism Financing

Effective date: January 2025

Endustar has implemented a Self-Control and Risk Management System for Money Laundering and Terrorism Financing (SAGRILAFT) in compliance with Colombian law. This system establishes policies, procedures, and controls designed to prevent, detect, and report any operation related to money laundering or terrorism financing.

ARTICLE 01

Regulatory Framework

Our SAGRILAFT complies with: Law 1121 of 2006, Law 1453 of 2011, Circular Externa 100-000016 of 2020 (Superintendence of Companies), and recommendations from the Financial Action Task Force (FATF/GAFI).

ARTICLE 02

Risk Management

We implement a risk-based approach that includes: identification of risk factors (clients, products, channels, jurisdictions), measurement of exposure levels, control through documented procedures and internal policies, and continuous monitoring of business relationships and transactions.

ARTICLE 03

Due Diligence

All business partners, clients, and counterparties undergo Know Your Customer (KYC) and Know Your Supplier (KYS) verification processes, including identity verification, sanctions list screening, adverse media checks, and beneficial ownership identification.

ARTICLE 04

Compliance Officer

Endustar has designated a Compliance Officer responsible for the administration, implementation, and effectiveness of the SAGRILAFT. This officer reports directly to senior management and is authorized to escalate suspicious activities to the relevant authorities (UIAF).

ARTICLE 05

Training & Awareness

All employees receive regular training on anti-money laundering regulations, red flag indicators, and reporting procedures. Training is mandatory and documented as part of our compliance program.