摘要:The States, in an attempt to comply with international conventions and recommendations of entities such as FATF, CICAD and GAFISUD, among others, have ordered administrative measures aimed at the prevention of money laundering. Later, these behaviours were raised to crimes. Thus the offence of failure to control was created in Colombia. In this essay, we will study these provisions, specifying the administrative and criminal responsibility of employees in the financial sector for infringing these provisions. We will furthermore propose some reforms in an attempt to obtain better efficiency for these rules.
关键词:Money Laundering;Sustaining Administrative Law;Failure to Control;Guarantor Position;Commission by Omission.;Lavado de activos;Derecho administrativo sancionador;Omisión de control;Posición de garante;Comisión por omisión