Editor’s notes

Colombia recorded modest growth in 2024, with its economy expanding by 1.7% following a 0.7% rise in 2023. Growth is expected to accelerate during 2025, with projections estimating an uptick of between 2.5% to 3.2% for the year. Optimistic forecasts are supported by strong domestic consumption — household spending accounts for 76.7% of GDP — underpinned by improved consumer confidence and easing inflation. Notably, confidence has remained solid despite rating agencies downgrading Colombia’s debt in June 2025.

On the corporate front, fixed investment continues to be sluggish. Much of the country’s fiscal strain has been attributed to the June 2022 election of Colombia’s first leftist president, former guerrilla Gustavo Petro. President Petro has presided over a fractious political environment, with ministerial resignations averaging more than one per month during the first half of 2025. Nevertheless, the government achieved a rare legislative success with its long-heralded labour reform — the cornerstone of President Petro’s presidential mandate — which finally passed in June 2025 after multiple failed attempts. The new law increases overtime pay and limits short-term contracts, among other provisions. Concurrently, Colombia’s lower house reapproved Petro’s pension reform bill — after a procedural redo ordered by the Constitutional Court — with a resounding 97–1 vote.

However, with elections scheduled for May 2026, and President Petro ineligible to run due to strict one-term limits, his success is likely to be short-lived. Market sentiment is decidedly upbeat heading into the end of 2025, with stronger-than-expected growth and the prospect of a more pro-business administration in 2026 encouraging investor confidence.

Colombia’s political instability has not deterred law firms from betting on its legal market. In what was undoubtedly the headline of the year, in July 2025 Spanish legal heavyweight Pérez-Llorca entered the country through a merger with leading domestic firm Gómez-Pinzón Abogados. The newly combined Ibero-American entity brings together 11 offices across eight countries and delivers significant multinational firepower to the local scene.

In December 2024, Baker McKenzie S.A.S. saw the exit of high-profile arbitration and litigation expert Claudia Benavides, former global chair of its dispute resolution group. Benavides departed together with Cristina Mejía to establish boutique firm Benavides Mejía Dispute Resolution. Senior associate Felipe González Arrieta — who was promoted to partner as part of the move — also joined the new firm.

Deloitte (Colombia) launched a compliance and white-collar crime practice in February 2024, following the hire of a team from CMM Estudio Legal. The new group includes department co-heads Alejandro Mejía — a founding partner of his former firm — and Freddy Navarrete. Senior associate Juan Pablo Coy, who serves as project leader of the corporate criminal law unit, and senior associate Maria Camila González also joined from the same firm.

Cuatrecasas established a new competition practice in late 2024 with the hire of partner Juan Sebastián Lombana, who joined in November from Novit Abogados, and senior associate Natalia Fernández, who arrived in September from Martínez Quintero Mendoza González Laguado & de la Rosa.

In February 2025, five Colombian boutiques from various legal disciplines combined to form a new platform, Signature Legal Group. The firms — Ibarra Abogados Rimon Law, MPV Abogados, Prias Cadavid Abogados, Quintero y Quintero Asesores, and Torrado Angarita & Pinzón Abogados — all retain their individual branding.

The arrival of an additional major Spanish firm has significantly disrupted the traditional order at the top of the Colombian market, which has long been dominated by a few stand-out powerhouses. Among the leading heavyweights, Brigard Urrutia remains an elite player, particularly in the banking, corporate, litigation and tax fields, among others. Other national full-service firms, many of whom also enjoy extensive international networks, include Philippi Prietocarrizosa Ferrero DU & Uría; Dentons Cardenas & Cardenas; Martínez Quintero Mendoza González Laguado & de la Rosa; Baker McKenzie S.A.S.; Posse Herrera Ruiz; and, we now add to this list, Pérez-Llorca.

A rung below the premier names sits a strong band of internationally oriented firms, long-serving national brands and more entrepreneurial up-and-coming offices, including Cuatrecasas; Garrigues; Holland & Knight; CMS Rodríguez-Azuero; Muñoz Tamayo & Asociados; Lloreda Camacho & Co.; Parra Rodríguez Abogados; Palacios Lleras; and Godoy. The market is also mature enough to support a sizeable band of boutique firms. Namely (and by practice area): Mendoza and Muñoz Aya Legal are recommended for banking and finance. For competition and antitrust, Ibarra Abogados Rimon Law (which is also a leader in international trade) and Esguerra JHR are highly sought after, while Bermúdez & Esguerra Abogados is noted for its focus on competition and TMT. On the white-collar and corporate compliance front, Jaime Granados Peña & Asociados Ltda, Jaime Lombana & Abogados and MPA/PDA Derecho Punitivo y Riesgos Corporativos are all premier firms. Transactional corporate specialists include Serrano Martínez CMA (which also specialises in competition). Key dispute resolution players in the arbitral sphere includes Suescún Abogados; Rincón Castro Abogados (which also handles international public law); and boutique Adell & Merizalde. On the energy front, Sanclemente Fernández Abogados S.A. and Angulo Martínez & Abogados are both highly regarded. The IP area is particularly well-represented with Cavelier, OlarteMoure, Castellanos & Co and Márquez-Robledo all leading names. Araújo Ibarra is a popular choice for international trade, while Álvarez Liévano, Laserna S.A.S., Godoy and Lopez & Asociados Abogados rank among the top tier for labour and employment. On the projects side, Durán & Osorio Abogados Asociados and Arrieta Mantilla & Asociados are go-to firms — both also specialise in public law. While not strictly a boutique in terms of size and practice scope, Pinilla González & Prieto Abogados’s firm-wide strength in real estate is formidable. Finally, Lewin & Wills, Abogados is widely hailed for its tax expertise, while international tax law and accountancy firm Forvis Mazars continues to expand its Colombian offering. Regional firms also comprise a key pillar of the market. Insurance player Tamayo Jaramillo & Asociados and dispute resolution specialist Arrubla Devis Asociados have risen beyond their local Medellín roots to become nationally renowned in their practice areas. Other non-Bogotá headquartered firms to note include Ariza & Marin, Contexto Legal S.A., UH Abogados, and VM Legal. Additionally, despite now being based in Bogotá, the originally Cali-based Advocat could also be considered part of this group.

News & Developments

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Dentons advises Bank Gospodarstwa Krajowego on US$60 million export financing to Molo Group for hotel complex in Turks and Caicos

Dentons has advised Bank Gospodarstwa Krajowego (BGK), the Polish development bank, on a long-term investment loan of up to US$60 million granted to the Molo Group, owned by the Slominski family. The financing will be used to build a hotel complex with 251 rooms and suites on Providenciales, the main island of the Turks and Caicos archipelago in the Caribbean. The buildings will be constructed from equipment and modules manufactured in Poland. “It has been a great pleasure and satisfaction to assist BGK with this prestigious financing transaction, supporting the expansion of Molo Group in their largest investment to date. This project not only promotes Polish exports but also features exceptional hotel developments in some of the most stunning locations in the Caribbean”, said Tomasz Zwoliński, partner in the Banking and Finance practice in Warsaw. The complex includes two modular hotels: the 4-star boutique Indigo hotel and the 5-star Kimpton hotel. Both brands are owned by the international IHG group. The Indigo hotel is scheduled for completion by the end of 2025, while the Kimpton is scheduled for completion in the first half of 2027. Tomasz Zwoliński supervised and led the cross-border project, advising on English and Polish law matters related to preparing, negotiating and signing the finance documents and securities, which covered five jurisdictions and involved collateral and mechanisms related to hurricane risk. He was supported by Jakub Zienkiewicz (counsel) and Kamil Bator (associate) from the Banking and Finance team in Warsaw. The transaction team also included partner Babette Märzheuser-Wood, Global Head of the Franchise Group, and Agnieszka Nagórska-Kordeczka (counsel), who advised on hotel franchise agreements. Dentons worked alongside teams from Griffiths & Partners, who served as Turks and Caicos counsel, and Massiah Law, acting as Gibraltar law counsel, both members of the Nextlaw referral network. About Dentons Across over 80 countries, Dentons helps you grow, protect, operate and finance your organization by providing uniquely global and deeply local legal solutions. Polycentric, purpose-driven and committed to inclusion, diversity, equity and sustainability, we focus on what matters most to you. dentons.com Media contact Lidia Adamczyk Communications, Marketing & Business Development Manager +48 513 045 352 [email protected]  
Dentons - May 18 2025
Press Releases

NATALIA ÁLVAREZ, NEW DIRECTOR OF THE ENVIRONMENTAL PRACTICE AT PGP

Colombian law firm Pinilla, González & Prieto Abogados announced the appointment of Natalia Álvarez as the new director of the Environmental Law and Public Services practice, after serving as a lawyer in this same area for 9 years. Natalia Álvarez is a lawyer from the Sergio Arboleda University, and has a master’s degree in environmental law from the Complutense University (Spain). She has worked for almost a decade as an associate attorney in the environmental area of ​​PGP and assumed the direction of this practice since May. Natalia also has experience as a researcher, teacher and consultant for international organizations such as the IUCN (International Union for Conservation of Nature). “In addition to strengthening relationships with our current clients, who are the pillar of our work, and whom I deeply thank for their trust, in this new stage we will focus on opening new doors and building alliances with a global perspective that includes sustainability as a central axis, maintaining our essence in urban environmental law and making a difference in public services advice in which we have solid experience and a track record,” says Álvarez. PGP's environmental practice has extensive experience in sectors such as infrastructure, construction, pharmaceuticals, floriculture, agribusiness, energy, mining and telecommunications, among others, integrating sustainability and responsibility into business development from a preventive approach. Among its specialties are the structuring of the environmental component in urban projects, the proper management of water resources, and obtaining environmental licenses, permits and authorizations in different activities and projects that may impact natural resources. Another of Natalia Álvarez's objectives will be to participate in discussion, formulation and adoption of public policies and environmental standards, to monitor the proliferation of regulations that impact various economic sectors in the country. “I consider this stage as an opportunity to reaffirm our commitment to continue building relationships based on solid and responsible results, providing a strategic vision to consolidate the firm as a leader in environmental legal solutions. I assume this commitment with great enthusiasm, and I am proud to lead a committed team that shares a clear vision of the importance of integrating sustainability, social impact and innovation with economic development seeking a positive impact in each project we undertake,” concludes the new director.  
Pinilla González & Prieto Abogados - October 17 2024

Corporate Executives in the Line of Fire

Leonor María Paulina Riveros Dueñ[email protected] is no secret that illegal armed groups have historically relied on a deplorable method of financing their criminal activities by coercing businesspeople into making payments under the explicit threat of severe consequences should they refuse. Such threats were, in many cases, carried out, including through acts of homicide.Unfortunately, the situation has worsened in a context in which 2025 is expected to be the worst year of the past decade in terms of the humanitarian consequences of the armed conflict in Colombia.[1] For companies, this is not merely a risk arising from past events, but one that stems from both the past and the present.The judicial response to this phenomenon has increasingly focused on prosecuting corporate executives for the offences of criminal conspiracy (concierto para delinquir) or financing terrorism, as applicable; or, even more concerning, for crimes committed by the illegal armed groups themselves under the doctrine of indirect perpetration through organised structures of power (autoría mediata en aparatos organizados de poder).The three jurisdictions dealing with these matters in Colombia—Justice and Peace, the Ordinary Criminal Justice System, and the Special Jurisdiction for Peace (JEP)—have progressively reinforced their respective approaches. Within the Justice and Peace jurisdiction, businesspeople are regarded as indirect perpetrators of crimes committed by armed groups, carrying the same criminal consequences as the direct perpetrators, based on the alleged functional support they provided to those organisations. Within the ordinary criminal justice system, criminal liability has been attributed to corporate executives on the grounds that they failed to report acts of extortion. As a result, members of boards of directors, chief executive officers, comptrollers and heads of security have been convicted of criminal conspiracy, as illustrated by the Chiquita Brands case. Meanwhile, the JEP opened Macro Case No. 8 – "Crimes committed by members of the public security forces, other state agents, or in association with paramilitary groups or civilian third parties." Through this decision, the JEP shifted from prioritising cases based on criminal conduct to prioritising them based on the actors involved. In doing so, it seeks to address what it considers to have been a criminal network involving members of the public security forces, other state agents, civilian third parties and paramilitary groups, once again relying on the doctrine of indirect perpetration through organised structures of power. To date, Colombian courts have rejected the traditional defence of irresistible duress, a legal doctrine which, in our view, clearly applies to these circumstances.As can be seen, the situation is exceptionally complex for corporate executives who were compelled to make payments to illegal armed groups, even where such payments were made under extortionate circumstances. Consequently, moving from the position of being victims of extortion to facing potential criminal liability for the most serious crimes against humanity is a matter of profound significance, both for those who found themselves in such unfortunate circumstances and for Colombian society as a whole.There is little doubt that judicial decisions of this nature will have an impact on Colombia's economic development and on incentives for investment. Unfortunately, the armed conflict in Colombia continues to intensify. Against this backdrop, the judiciary faces the considerable challenge of determining the appropriate legal treatment for such a complex situation. Business leaders, for their part, must carefully assess their exposure and be prepared for potential proceedings before the courts.
Riveros Bazzani Abogados

The FCPA Is Not Dead, but It Has a New Face

Andrés Eduardo Jiménez [email protected] February 2025, shortly after the beginning of President Trump's second administration, the United States Government issued an Executive Order suspending the initiation of new investigations by the Department of Justice (DOJ) under the Foreign Corrupt Practices Act (FCPA).A misunderstanding of both the Executive Order and the FCPA itself led many people—including some legal and compliance professionals—to claim that the FCPA had effectively come to an end or that U.S. companies now had a licence to engage in corrupt practices. Nothing could be further from the truth.What the Executive Order actually provided was that the DOJ should issue new guidance governing the initiation of FCPA investigations, and that, until such guidance was issued, the commencement of new investigations would remain suspended. That pause came to an end on 9 June 2025, when the new enforcement guidelines were released.The first point worth highlighting is that the new guidelines do not alter the statutory provisions of the FCPA that establish the DOJ's jurisdiction, including jurisdiction over U.S. issuers, U.S. legal entities and individuals, and the applicable territorial jurisdiction principles.What the guidelines do change is the type of cases that will receive the DOJ's attention under the current administration. The new priorities introduce organised crime and geopolitical considerations that had not previously been incorporated into the assessment of enforcement risks. This article highlights three significant developments arising from the U.S. Government's new criminal enforcement priorities.The first major development introduced by the 9 June 2025 guidelines is that, under the current administration, the FCPA will be used as a tool to combat cartels and transnational criminal organisations. According to the guidance, where such a connection is absent, investigations are unlikely to receive the same level of attention from the DOJ.The second significant development relates to U.S. national security. The guidelines identify critical minerals, deep-water ports, and other strategic infrastructure or critical assets as key sectors in which U.S. companies should be able to compete and secure business opportunities. The FCPA will therefore be used as a tool to address national security threats arising from the bribery of foreign public officials involving critical infrastructure or strategic assets.The third notable development is that prosecutors handling FCPA investigations are instructed to consider the likelihood—or lack thereof—that local authorities are both willing and able to investigate and prosecute the same conduct within their own jurisdictions.Why are these developments relevant for Colombian companies? It is evident that, after Mexico, Colombia remains a significant area of interest for the United States because of the presence of transnational criminal organisations that are priorities for U.S. law enforcement. Many large companies operate in regions far from the country's major urban centres, where criminal organisations continue to exert various forms of pressure on businesses.The FCPA's new approach introduces additional risk factors that companies should incorporate into their compliance risk identification and management processes. Failing to consider these new dimensions may prove extremely costly if those risks ultimately materialise.
Riveros Bazzani Abogados