Key takeaways

• Colombia recently adopted a new anti-corruption law (Law 1778), which created a regime of direct administrative liability for legal entities involved in transnational corruption.
• Law 1778 vests authority in the Superintendence of Companies to impose sanctions and fines up to US $40 million against legal entities registered in Colombia, as well as against foreign parent companies of Colombian subsidiaries and foreign subsidiaries of Colombian companies. The Superintendence may impose fines after an administrative investigation and without filing criminal charges before a court.
• The new law encourages self-reporting by waiving or reducing penalties for companies that cooperate with investigations and provide relevant evidence. Additionally, companies with strong compliance programs may benefit from reduced fines.