By means of legal opinion  2023006729-003-000 del 7 de marzo de 2023, 

the Superintendence of Finance of Colombia (hereinafter, the "SFC") answered a consultation on whether the representative offices of foreign reinsurers are required to have an external auditor. 
In this regard, the SFC made the following considerations:

1. The national financial legislation establishes a special legal regime for representative offices, by virtue of which they must "be in charge of a private person appointed by the foreign institution and may only provide the services that the National Government establishes through general rules”.

2.    The representative offices of foreign reinsurers may only operate in the acceptance or assignment of reinsurance liabilities; therefore, they are not authorized to act, directly or indirectly, in the procurement of insurance.
3.    The representative offices of foreign reinsurers are not a legal entity different from the foreign institution they represent, nor a branch thereof in Colombia.
4.    The representative offices of foreign reinsurers supervised by the SFC "do not exercise, per se, a reinsurance activity (...)".
5.    Article 79 of Decree 663 of 1993 provides that entities supervised by the SFC must have an external auditor. However, the representative offices of foreign reinsurers, due to the nature of their activity, are not required to have an external auditor:

"The nature of the activities and services authorized to the representative offices of foreign financial, reinsurance, and securities market institutions (which are limited to the promotion and advertising of the respective institution or of the services that constitute its social purpose) compared to the scope of the functions of an external auditor in Colombia, leads to the conclusion that with respect to the representative offices of these foreign institutions, the obligation to have the aforementioned control and inspection body is not mandatory." (Underlining and bold outside the text).
 

If you wish to consult the legal opinion  2023006729-003-000, click here.