On August 19, 2016, the Superintendence of Companies issued a modification to the Basic Legal Circular (No. 100-000006), which, among other matters, regulated which companies, according to their economic sector, are required to adopt Self-control and Risk Management Systems against Money Laundering and Terrorist Financing (in Spanish, SAGRALAFT), to the extent that such companies meet all of the following criteria or requirements, per sector:

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Those companies that as of December 31, 2015 had fulfilled these criteria, have a maximum term of twelve (12) months as from September 1, 2016, to adopt, review and/or adjust their policy or system of prevention and risk management regarding Money Laundering and Terrorist Financing, so that such policy or system complies with the provisions set forth in the Basic Legal Circular (No. 100-000006).

Additionally, those companies obliged under the Basic Legal Circular (No. 100-000006) as from December 31, 2016, have a maximum term of twelve (12) months as from January 1 of the year following that in which the companies have met said criteria.

The Basic Legal Circular (No. 100-000006) contains a series of mandatory parameters, standards and minimum requirements that the SAGRALAFT of each company must comply with.

Failure to comply with this regulation can result in fines, successive or not, to be imposed by the Superintendence of Companies to the company and/or its officers, up to 200 minimum legal wages (COP$137,891,000, c. USD$45,900).