The Colombian tourism sector reported continued growth metrics through the third quarter of 2025, driven by air traffic volume and the influx of foreign visitors.

Between January and September 2025, Colombia registered 4,875,830 non-resident visitors, according to figures released by Migración Colombia and the Office of Economic Studies (OEE) of the Ministerio de Comercio, Industria y Turismo (MinCIT).

Air traffic data from the Aeronáutica Civil indicates that 37 million passengers traveled on regular flights between January and August 2025. This volume represents a 2% increase compared to the same period in 2024 and an 18.6% increase relative to 2023.

Of the total passenger volume, 20.9 million passengers flew on domestic routes, while 16.2 million were on international routes. The 7.3% increase in international traffic over the 15.1 million recorded in 2024 reflects the expansion of the country’s air connectivity, says the ministry.

In August 2025, 4,998,176 passengers were mobilized on regular flights, including 2.8 million domestic and 2.18 million international passengers. This monthly total was a 0.1% increase from August 2024 and a 14.6% increase compared to August 2023.

Geographically, El Dorado Airport in Bogotá processed 69% of all international passengers. The primary international hubs following Bogotá were the José María Córdova International Airport in Rionegro (Medellín) and the Rafael Núñez International Airport in Cartagena.

International Visitor Composition and Source Markets

The 4.87 million non-resident visitors recorded from January to September 2025 included 3,467,026 foreign nationals, 1,191,475 Colombian residents living abroad, and 217,329 international cruise ship passengers.

While the total number of non-resident visitors showed a 4.2% reduction compared to 2024, the specific segment of foreign non-residents increased by 4.5% during the nine-month period. Foreign non-resident arrivals have accumulated a 14.8% growth relative to 2023 figures.

The US remained the largest source market, accounting for 22.7% of the total foreign visitors. Other principal source countries were Mexico (11.4%), Ecuador (7.6%), and Peru (5.2%).

In terms of arrival points, Bogotá received 38.5% of foreign non-resident visitors, followed by the departments of Antioquia (26.9%) and Bolívar (16.7%). These departments continue to concentrate the majority of international tourism activity in the nation.

The September figures indicate sustained international engagement with Colombia and the continued activity of the country’s air travel sector. The increased foreign visitor count and expanded air traffic volume correlate with regional economic activity.

Collective Mining Ltd. (NYSE: CNL) (TSX: CNL) announced October 29, 2025, that assay results from thirteen diamond drill holes at the Apollo system have returned a high-grade gold equivalent intercept and expanded the system’s western side. The company, which is focused on exploration projects in Caldas, Colombia, is also planning a substantial 2026 drill campaign.

The reported diamond drill holes targeted internal model gaps within the top 1,000 vertical meters of the Apollo system, which is part of the company’s Guayabales Project. Drilling on the western side of the Apollo system intersected high-grade mineralization, expanding that section by up to 50 meters.

Figure 1: Plan View of the Apollo System Highlighting Infill Drill Holes in this Release (CNW Group/Collective Mining Ltd.)

Drill Hole Results and Western Expansion

Key intercepts include:

486.00 meters at 2.01 g/t gold equivalent from 54.10 meters downhole (APC-141).

144.30 meters at 2.08 g/t gold equivalent from 324.45 meters downhole (APC105-D5). This intercept is cited as the one that expanded the Apollo system westward by up to 50 meters at an elevation of 1,450 meters above sea level (MASL).

These results are expected to improve the internal block model grades, extend the mineralized volume, or upgrade confidence in the estimation.

Drill holes from Pad 30 cut mineralization beginning near surface, including:

APC-141: 486.00 meters at 2.01 g/t gold equivalent from 54.10 meters downhole.

APC-147: 84.55 meters at 2.04 g/t gold equivalent from surface.

Drill holes from mother hole APC-105D at Pad 18 extended the volume of the mineralized Apollo breccia body up to 50 meters horizontally and 140 meters vertically toward the southwest margin.

Ongoing Exploration and 2026 Plans

Figure 2: Plan View and Section Highlighting the New Western Expansion of the Apollo System (CNW Group/Collective Mining Ltd.)

The company has completed approximately 142,000 meters of diamond drilling to date across the Guayabales and San Antonio projects, with 102,000 meters at Apollo. Numerous drill holes are awaiting assay results.

Ten drill rigs are currently operating across the company’s properties:

Guayabales Project: Six rigs are in operation. One rig is moving to conduct expansion drilling at the outcropping tungsten, gold, silver, and copper zone. Two rigs are performing infill drilling at Apollo (1,500 MASL to 1,000 MASL elevations). Two deep capacity rigs are focused on expanding the high-grade Ramp Zone at depth (below Apollo), and one rig has started drilling at Target X.

San Antonio Project: Four rigs are targeting the Pound zone, which has previously intersected a shallower zone of gold and silver-rich, intermediate sulphidation sheeted veins and a deeper gold-copper porphyry system.

Collective Mining is finalizing plans for an 80,000 to 100,000-meter drilling campaign in 2026 across the Guayabales and San Antonio projects. The company anticipates completing a maiden resource estimate for the Apollo system in the fourth quarter of 2026.

Figure 3: Plan View of the San Antonio Project’s Pound Target with Visual Descriptions of Drill Holes SAC-24, SAC-25, and SAC-26, all of Which Cut Potentially Significant Mineralization. Assay Results are Pending (CNW Group/Collective Mining Ltd.)

Headline photo: Plan View of the San Antonio and Guayabales Projects Highlighting the Pound Target and the Apollo System (CNW Group/Collective Mining Ltd.)

LATAM Airlines Group (NYSE: LTM) and Visa (NYSE: V) have concluded the six-month renovation of their co-branded VIP Lounge at El Dorado International Airport (BOG) in Bogotá. The facility, which remained operational during the one-year planning and six-month execution period, offers a revised environment for the airline’s frequent and premium passengers.

The redesign focused on increasing capacity and integrating elements of Colombian culture, as well as advancing the airline’s sustainability objectives.

“With this renovation, we aim for passengers to experience a space designed to meet their travel needs. Each area is conceived to reflect what we are: an evolving airline connected to its environment,” stated Erika Zarante, CEO of LATAM Airlines Colombia.

The renovation included structural and material changes intended to optimize the passenger experience. Key design elements include translucent metal dividers, influenced by the design of the Santiago de Chile lounge, a copper curtain, an artisanal piece crafted by Colombian artist Lizarazo, was retained from the previous design, serving as an exercise in aesthetic continuity and sustainability. Additionally, local artisans crafted the palm-woven Iraca lamps, which the airline states is a commitment to local production.

Approximately 70% of the seating and furnishings were updated for improved comfort, including the co-working areas, via a materials reutilization process. The facility also incorporated new motion-sensor faucets and other materials with a low environmental impact. A metallic structure lamp, weighing an estimated 400 kilograms, was installed over the buffet area, positioning the space as a central feature of the lounge. The redesign provided an unobstructed view of the runway for departing passengers.

The lounge’s food and beverage program was also updated to align with Colombian culinary traditions. The menu rotates every two weeks and features regional dishes such as calentado, carne con salsa cartagenera, aborrajados, and volcán de arequipe. A separate “Coffee Break” space is dedicated exclusively to the country’s coffee production. During peak hours, an exclusive offering, including gourmet meatballs and omelets, is available to passengers.

The lounge has been positioned by the airline as a leader in waste management within the group’s network. It currently reports an 88% recycling rate, with 12% of its total waste directed to landfills. The facility accommodates an average daily demand of 700 to 800 passengers, with future plans to evolve toward a multi-space format similar to the airline’s Signature lounges in Santiago, Lima, and Miami.

The renovation follows a period of growth for the carrier’s Colombian subsidiary. During the third quarter of 2025, LATAM Airlines Colombia transported an estimated 7.9 million passengers across its 18 domestic and seven international routes.

In the cargo sector, the company reported a 43% market share, moving 99.5 tons internationally and 22.7 kilotons domestically. The loyalty program, LATAM Pass, continues to expand its base, reporting 4 million active members.

Fitch Ratings announced a revision and affirmation of the national credit quality and market risk sensitivity ratings for a series of Collective Investment Funds (FIC) managed by Fiduciaria Bancolombia S.A.. Fiduciaria Bancolombia is the trust and asset management arm of Bancolombia S.A. (NYSE: CIB, BVC: CIBEST), one of the largest financial institutions in Colombia and Central America.

The rating action included an upgrade for one fund and the affirmation of ratings for six others. The ratings assigned by Fitch do not constitute an opinion on the probability of the application of extraordinary liquidity management measures or the funds’ redemption risk.

Key Rating Factors

The foundation for the affirmation and revision of the ratings rests on the current profile of the FIC’s asset portfolios, investment strategies, and management policies.

Credit Quality Assessment

The credit quality ratings are derived from the weighted average credit quality of each FIC’s portfolio, with specific focus on the quality and diversification of instruments and counterparties, as well as the established investment limits. All FICs maintained a Weighted Average Credit Quality Factor (WACF) consistent with the ‘AAAf(col)’ national rating, the highest designation on the scale.

The upgrade of the FIC Renta Fija Plus credit quality rating to ‘AAAf(col)’ was attributed to the sustained stability in the investment portfolio’s credit profile. This stability led to a consistent reduction in the fund’s WACF, bringing it within the required range for the ‘AAAf(col)’ rating.

Market Risk Sensitivity

The market risk sensitivity ratings are based on the average duration of the funds, calculated by the Weighted Average Rating Factor (WARF), and the fund’s sensitivity to spread risk (MRF).

Sensitivity to Future Rating Actions

Downgrade Factors

A downgrade in the FIC’s credit quality ratings could occur if the portfolio undergoes significant changes in composition or if investment strategies are modified to increase the WACF, reflecting a lower credit quality. This applies to all FICs with the exception of those rated at Df(col), which is the minimum national scale rating.

Similarly, a downgrade in market risk sensitivity could result from significant changes in portfolio composition, duration, or spread risk, or if modifications to investment strategies increase the MRF and reflect greater sensitivity to market risk. The potential for the use of financial leverage is also a factor considered in the sensitivity assessment.

Upgrade Factors

The credit quality ratings for all FICs and the market risk sensitivity ratings for FIC Fiducuenta, FIC Fiduexcedentes, and FIC Renta Liquidez are the highest on the national scale. Therefore, a further positive rating action is not possible for these specific funds.

The market risk sensitivity rating for FIC Fidurenta and Plan Semilla could be reviewed for an upgrade if their MRF remains consistently below the thresholds established by Fitch for their current ratings.

Bancolombia S.A. Subsidiaries

Bancolombia S.A. (NYSE: CIB, BVC: CIBEST) is the parent company of a financial group with operations across Latin America. The group, now formally operating under the holding structure Grupo Cibest S.A., manages a broad range of businesses.

Key subsidiaries within the corporate structure include:

• Banistmo (Panama)
• Banco Agrícola S.A. (El Salvador)
• Grupo Agromercantil Holding (GAH), which includes Banco Agromercantil de Guatemala (BAM)
• Valores Bancolombia S.A. Comisionista de Bolsa (Securities Brokerage)
• Banca de Inversión Bancolombia S.A. Corporación Financiera (Investment Banking)
• Compañía de Financiamiento Tuya S.A. (Financial Services, Retail Credit)

Colombian exporters are now able to submit electronic applications for the Tax Refund Certificate (CERT) following the launch of a dedicated platform. The application, which became operational on October 27, 2025, is managed by the Directorate of Foreign Trade, an agency of the Ministry of Commerce, Industry and Tourism (MinCIT).

Housed within the Ventanilla Única de Comercio Exterior (VUCE) single window system, the electronic application process is the result of collaboration between the Colombian government and private sector stakeholders. Access to the application is available via the following address: https://www.vuce.gov.co/servicios/certificado-de-reembolso-tributario.

Exporters seeking the CERT recognition are required to input data including their legal name, Tax Identification Number (NIT), export destination(s), and the specific tariff subheadings for goods or the International Standard Industrial Classification (ISIC) codes for services. These and other procedural requirements are formalized under Resolution 212, dated August 25.

The CERT provides financial incentives for targeted export sectors such as pharmaceutical, food, automotive, machinery, and shipbuilding.

CERT Program Overview

The CERT, which was activated in May, is a mechanism intended to diversify and boost exports of industrial goods with higher value-added, as well as knowledge-based services. The mechanism’s stated objectives include promoting investment, production, and job creation. The CERT is scheduled to be in effect for exports executed in 2025 and 2026.

Under the CERT, exporters are reimbursed for a portion of the indirect taxes paid during the production of goods or the provision of services that are subsequently exported.

Goods that have undergone a more substantial production or transformation process are eligible for a reimbursement equivalent to 3% of the Free On Board (FOB) export value. This tier covers approximately 5,000 tariff subheadings across sectors such as pharmaceutical, food, automotive, machinery, and shipbuilding. Exports of services that incorporate technology and innovation qualify for a 2% reimbursement on the exported value. Service categories covered under the program include professional services, health services, education, and specialized maintenance.

The CERT is not applicable to exports originating from or destined for Free Zones, nor for goods and services shipped to member countries of the Andean Community—Bolivia, Ecuador, and Peru—or to Venezuela.

Prior to the application’s launch, the Colombian government, in coordination with ProColombia, trade associations, and private sector representatives, completed the instrument’s activation and dissemination. This effort included training sessions conducted with associations such as the National Association of Foreign Trade (ANALDEX), the National Association of Businessmen of Colombia (ANDI), the Colombian Federation of Logistics Agents in Foreign Trade (FITAC), and the Association of Banking and Financial Institutions of Colombia (Asobancaria), engaging approximately 300 participants. The development and implementation of the CERT application also involved technical testing and support from financial market intermediaries.

Photos courtesy MinCIT

Suzhou, China based BioDlink (1875.HK) announced the inaugural international shipment of its bevacizumab injection biosimilar to Colombia. The shipment was conducted in partnership with Jinan, China based Kexing BioPharm (SHA:688136), the company’s licensee for emerging markets. This initial distribution follows the marketing approval granted to the product by the Colombian National Institute for Surveillance of Medicines and Foods (INVIMA) in July 2025. The drug is targeted for use in cancers such as lung and colorectal, which are classified by the International Agency for Research on Cancer (IARC) GLOBOCAN 2022 as being among the top three cancer-related causes of death in Colombia.

The therapy is used to treat various cancers, including colorectal and lung cancer.

The shipment to Colombia was dispatched approximately two months after receiving the regulatory authorization. Bevacizumab is a monoclonal antibody that targets vascular endothelial growth factor (VEGF), a factor involved in blood vessel formation. The therapy is used in the treatment of various cancers, including metastatic colorectal cancer (mCRC) and metastatic or recurrent non-squamous non-small cell lung cancer (nsNSCLC). Industry estimates indicate that global sales for bevacizumab injection reached $8.5 billion USD in 2023.

The arrival of the initial shipment in Colombia marks the execution of the companies’ commercial strategy for the region. The Colombian cancer burden is characterized by patterns aligning with bevacizumab’s indications, with 11,163 colorectal cases and 7,196 lung cases reported out of 117,620 new cancer cases in 2022, according to IARC GLOBOCAN 2022.

Manufacturing and Global Strategy

BioDlink’s manufacturing facilities, spanning 50,000 square meters, have undergone five audits by an EU Qualified Person (QP) for antibody drugs and antibody-drug conjugates (ADCs) over the past four years without any critical defects being reported. The company states that its quality system has supported over 100 clinical projects, providing development, clinical filings, and manufacturing services in global markets including Europe and the US.

The partnership operates under an international commercialization agreement signed in early 2022, establishing a framework where BioDlink focuses on manufacturing and supply chain management while Kexing BioPharm leverages its distribution network for market access in emerging regions. Kexing BioPharm, which holds the global license for the bevacizumab injection in emerging markets, has achieved Good Manufacturing Practice (GMP) certification for the product in China, Colombia, Brazil, Argentina, Egypt, Indonesia, Pakistan, and Thailand. In collaboration with BioDlink, Kexing BioPharm has initiated regulatory filings in 35 countries. GMP certification in Brazil, Colombia, and Argentina covers South America’s three most populous countries.

BioDlink reports that its international focus remains on emerging markets, including South America, South Asia, Southeast Asia, and Africa.

Above photo courtesy Kexing Biopharm

Aris Mining Corporation (TSX: ARIS; NYSE-A: ARMN) announced the immediate appointment of Brigitte Baptiste to its Board of Directors.

Baptiste is a Colombian biologist and academic recognized for her work in biodiversity conservation, sustainable development, and inclusion. She currently holds the position of Rector at Universidad Ean in Bogotá. Baptiste previously served as the Director of the Alexander von Humboldt Institute for Research on Biological Resources, Colombia’s national biodiversity research center. Her background includes engagement with environmental and social policy across Latin America, and she is a member of international advisory panels focused on climate action.

Ian Telfer, Chair of the Aris Mining Board, noted that the appointment is consistent with the company’s objectives related to environmental science, biodiversity management, and inclusive leadership, intending to apply this expertise to its mining operations in Colombia and Guyana.

Aris Mining was founded in September 2022 as a gold mining company focused on South America. The company’s business model combines generating cash flow from existing production with growth driven by asset expansions, exploration, and development projects.

Above photo: Brigitte Baptiste speaking at the Colombia Gold Summit (photo: Loren Moss)

Medellin’s municipally owned business incubator Ruta-N has announced the selection of 25 companies—a mix of startups and scaleups, to form the inaugural cohort of Medellín Next, an initiative focused on the expansion of high-impact, technology firms into international markets.

The application process attracted 65 companies from sectors including technology, energy, financial services, health, education, and agroindustry. This level of participation reflects the current activity within the city’s entrepreneurial ecosystem.

The 25 selected companies will access a comprehensive set of support services. These services include strategic diagnostics, customized mentorship from high-level experts, pitch training, and connections to international investment and market networks. Carolina Londoño Peláez, Executive Director of Ruta N, confirmed the formation and support process is scheduled to last two months.

The initial cohort includes firms such as Erco, B2Chat S.A.S, Somos Internet, Hacku, and Netux, along with 20 additional companies. The complete list of participants is available on the Ruta N website.

Selection Criteria

Carolina Londoño Peláez, Executive Director of Ruta-N (photo courtesy Ruta-N)

To be eligible for Medellín Next, companies were required to demonstrate a specific level of operational maturity and market traction, including:

• A validated business model, with a product or service already generating sales in the market.
• Minimum annual invoicing of $1 million USD in sales and revenue.
• A minimum full-time team of five employees.
• At least one active founder dedicated to the company full-time.
• A clearly defined growth and scalability plan.

Londoño Peláez stated that the program’s objective is to facilitate business scaling to establish Medellín as a high-impact technology hub in Latin America. The support services are structured to address areas essential for expansion, including strategic planning, financial strengthening, leadership, capital access, and internationalization.

Six individuals, including a 14-year-old minor, were detained in the Prado Centro neighborhood of Medellín following the successful liberation of a German national who had been held captive and extorted.

The joint operation, executed by units of the Gaula Metropolitano (Anti-Extortion and Kidnapping Group), a specialized division of the Policía Nacional de Colombia, alongside the City Government of Medellín and the Office of the Attorney General of Colombia, secured the victim’s release after 36 hours of confinement.

Six people, including a 14-year-old, were detained in Medellín’s Prado Centro after freeing a kidnapped German national. Photo credit: Medellín Mayor’s Office.

The six suspects—identified as four adults and two women among them, plus the adolescent—were arrested in flagrante delicto (in the act) and have been charged with several offenses, including aggravated extortionate kidnapping (secuestro extorsivo agravado), aggravated theft (hurto calificado), and the use of minors in committing crimes.

Details from the investigation indicate the German tourist was initially approached in the Parque Lleras sector—a known hub for tourism and nightlife. Two women allegedly accosted the victim and subsequently took her to the property in Prado Centro, north of downtown Medellín, where she was held. During the confinement, the assailants reportedly stripped the victim of personal belongings valued at over €2,000 and initiated financial demands to the victim’s family contacts in Germany.

The multi-agency response was activated after an official alert was received from the German Embassy in Bogotá. Personnel from the City Government of Medellín and the Gaula units of the Metropolitan Police of the Aburrá Valley quickly instituted a focused search and rescue protocol.

During the intervention, several of the victim’s personal items were recovered, and four cellular telephones were seized for forensic analysis. The detained individuals have been transferred to the custody of the competent judicial authorities, under the purview of the Office of the Attorney General of Colombia, to commence the formal prosecution process.

Video headline credit: Medellín Mayor’s Office.

Colombia’s Superintendence of Industry and Commerce (SIC), the country’s data protection and market regulator, has ordered the “immediate and definitive closure” of all data processing operations in Colombia for World Foundation (formerly Worldcoin Foundation) and Tools for Humanity Corporation.

The sanction, detailed in Resolution 78798 of October 3, 2025, concludes a seven-month investigation into the companies’ practice of collecting sensitive biometric data from thousands of Colombians.

The companies began operations in Colombia in the first half of 2024, deploying “Orb” devices to capture biometric images of individuals’ irises. This data was used to create a “World ID” and, according to the SIC, was obtained by offering economic compensation.

President Gustavo Petro commented on the sanction via his account on the social network X: “Excellent. In Colombia, the right to habeas data exists. You own your data. Sensitive data like the iris of the eyes cannot be handed over simply for money, without knowledge of the use that will be given to it. For this practice, the operations of these companies were closed.”

The SIC investigation determined that this quid pro quo—offering money for biometric data—invalidated the legality of the consent obtained. The agency found that the economic incentive “conditioned the will” of data holders, preventing them from making a “free, spontaneous, or voluntary” decision as required by Colombian law.

The agency labeled the resulting consent an “uninformed and premature decision”.

SIC Findings and Legal Basis

The 76-page resolution details multiple, cascading violations of Colombia’s Statutory Law 1581 of 2012, which governs the constitutional right to habeas data, or the right of citizens to control their personal information.

Under Colombian law, biometric data, such as an iris scan, is classified as “sensitive data”. The processing of such data is expressly prohibited by default, with narrow exceptions, such as obtaining explicit, prior, and informed authorization from the user.

The SIC’s Directorate of Personal Data Protection Investigations found that the companies failed to meet this standard on several fronts:

• No Legal Authorization: The investigation concluded that the authorization formats used did not comply with the “principle of liberty” and other legal requirements. For example, several forms and processes presented to users were in English, not in Spanish, Colombia’s official language.
• Inadequate Policies: The companies’ data treatment policies were not adapted to Colombian law. The SIC noted that while Worldcoin’s policies included “adendas” (addendums) with specific, often stricter, rules for regions like the European Union, Japan, Argentina, and Peru, no such addendum was created for Colombia.
• Insufficient Security Measures: The resolution states that the companies failed to demonstrate “appropriate and effective” security measures for the sensitive data collected. The company’s 2021 Information Security Policy did not specifically cover the processing of biometric data.
• Lack of Transparency: The SIC found that Worldcoin failed to inform users about its Secure Multi-Party Computation (SMPC) protocol, a system where iris codes are fragmented and stored by third parties. This protocol was not disclosed in consent forms until December 2024, despite being in use since May 2024. The agency also raised concerns about the security risks and oversight of the third parties (including universities and other companies) storing these data fragments.
• Incomplete Data Deletion: The regulator found that the companies’ consent forms informed users that their “iris code” or “proof of singularity” would not be deleted, even if the user requested the deletion of their images. The SIC argued this proves the data is never fully suppressed, as it must be retained to check for duplicate registrations, a fact not clearly communicated to users.

The foundation and company were founded by tech billionaire Sam Altman, and pay people small amounts of cryptocurrency to scan their eyes and create a unique, identifiable record. Some find this extremely creepy and say it takes advantage of the poor & gullible. Altman is also the CEO of OpenAI, maker of ChatGPT.

The Sanction and Company Response

The SIC’s resolution imposes two primary actions:

Immediate and Definitive Closure: An order for the “immediate and definitive closure” of any operation in Colombia that involves the treatment of personal data.

Data Suppression: An order for World Foundation and Tools for Humanity to “suppress” all sensitive personal data, including all iris codes, from all databases, repositories, or servers where they are stored. This applies to all data collected in Colombia since the beginning of their operations.

The companies are required to submit a report from an external entity certifying the complete elimination of this data within one month of the resolution being executed.

World Foundation Response

In an official statement, World Foundation announced it would pursue legal appeals against the sanction. The company described the resolution as “preliminary and of the first instance” and asserted that its legal appeals “have a suspensive effect,” which it claims allows it to “continue operating in a normal and legal manner.”

The company contended that the SIC’s findings are “incomplete” and “based on outdated policies and technologies.”

World Foundation also clarified its position, stating that it does not store biometric data and that user consent is “confirmed at multiple stages” of the verification process. It further stated that the Worldcoin token is “additional and is completely separate from the verification process.”

The company said it hopes to establish an “open dialogue with the SIC to clarify how this important technology works.”

The SIC’s resolution also noted that the companies’ legal counsel had previously attempted to nullify the administrative proceeding, alleging “improper notification” of the initial investigation. The SIC rejected these motions, ruling that the companies had already responded to official inquiries using the same email addresses, thereby constituting “notification by conclusive conduct”.