--- title: "Panama (PA) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/panama/ source_html: /jurisdictions/panama/index.html description: "Financial integrity intelligence for Panama (PA): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: c717ab32a96ca33f49408ff42c840f39b5a7724d46368ed09e14f145876aee93 generator: "fe-fleet/md-twin@1.0" --- # Panama (PA) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Panama PA Domains covered 7 of 8 Sources 151 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Clean Tier: B Risk direction: Stable Enablement vs enforcement: Mixed Panama exited the FATF grey list in October 2023 and the EU high-risk third-country list in June 2025. More AML law criminalises laundering broadly and created a non-public UBO registry (Law 129/2020) under Superintendencia/UAF supervision, but domestic ML prosecution remains weak, professional-enabler oversight (CSPs, lawyers) is uneven, and no comprehensive VASP/crypto law is in force. Key deficiencies - Non-public beneficial ownership registry limits third-party/journalistic verification of nominee-shareholder structures - Weak domestic prosecutorial capacity for complex professional-enabler money-laundering cases, exemplified by the 2024 mass acquittal in the Panama Papers trial - No comprehensive virtual-asset service provider (VASP) AML/CFT statute in force after the 2022 crypto bill was vetoed for insufficient controls - Ship registry (Panama flag) remains a preferred reflagging destination for vessels exiting sanctioned or scrutinised flags despite an active de-flagging campaign - Colon Free Zone transaction data remains incompletely integrated with customs systems, sustaining trade-based money-laundering exposure Recent developments (18m) - EU Commission delisted Panama from the AML high-risk third-country list, effective June 2025 - Panama's courts acquitted all 28 defendants in the Panama Papers money-laundering trial (July 2024), and Panama's new president publicly dismissed the ICIJ investigation as a 'hoax' - Panama Maritime Authority accelerated de-registration of sanctioned shadow-fleet tankers (approx. 128 vessels flagged for cancellation by March 2025, at least 70 already removed) - A former senior Mossack Fonseca executive, Christoph Zollinger, was set for trial in Germany (March 2026) on tax-evasion/criminal-organisation charges tied to Panama-based offshore structures - UNODC, with Canadian government support, ran a January 2026 high-level training for Panamanian regulators (Ministry of Economy and Finance, UAF, Attorney General's Office) on virtual-asset AML/CFT supervision Brief ## Lead signal #### Lead Signal Panama's financial-integrity picture this cycle is dominated by the collision of two separate forces acting on the same flag registry and the same supervisory perimeter. On 21 October 2026, the US Treasury's Office of Foreign Assets Control designated a Panama City resident and a Panama/Greece-based maritime manager under Executive Order 13902 for facilitating Iranian petroleum exports via a shadow fleet, effective that date. The designation blocks the property of the listed parties. In the days that followed, the Panama Maritime Authority initiated proceedings to cancel the registration of seven Panama-flagged vessels caught up in this and related October 2026 OFAC actions. Read together, these two developments continue a pattern this monitor has tracked for some time: Panama's flag registry responds to US sanctions designations after the fact, cancelling registrations once a vessel has already been named, rather than screening ownership or beneficial control structures in a way that would catch the risk before a listing happens. The architecture question is not whether Panama de-registers sanctioned ships; it does, reliably. It is whether the registry's screening function operates upstream of designation at all, and nothing in the material gathered this cycle indicates that it does. Read full brief #### Lead Signal Panama's financial-integrity picture this cycle is dominated by the collision of two separate forces acting on the same flag registry and the same supervisory perimeter. On 21 October 2026, the US Treasury's Office of Foreign Assets Control designated a Panama City resident and a Panama/Greece-based maritime manager under Executive Order 13902 for facilitating Iranian petroleum exports via a shadow fleet, effective that date. The designation blocks the property of the listed parties. In the days that followed, the Panama Maritime Authority initiated proceedings to cancel the registration of seven Panama-flagged vessels caught up in this and related October 2026 OFAC actions. Read together, these two developments continue a pattern this monitor has tracked for some time: Panama's flag registry responds to US sanctions designations after the fact, cancelling registrations once a vessel has already been named, rather than screening ownership or beneficial control structures in a way that would catch the risk before a listing happens. The architecture question is not whether Panama de-registers sanctioned ships; it does, reliably. It is whether the registry's screening function operates upstream of designation at all, and nothing in the material gathered this cycle indicates that it does. Alongside the sanctions story, Panama's banking supervisor has moved independently to tighten its own obligated-entity perimeter. The Superintendencia de Bancos de Panama issued Acuerdo de Prevencion para Otros Sujetos Obligados Financieros No. 1-2026, dated 20 October 2026, which establishes a registration process bringing MICI-licensed empresas financieras (financial companies licensed by the Ministry of Commerce and Industry rather than by the banking regulator itself) within the SBP's AML-obligated-subject net under the base statute, Law 23 of 2015. Newly licensed firms get nine months to register; firms already operating get six. #### Other Developments A supervisory perimeter closes rather than opens. The SBP's Acuerdo No. 1-2026 is a structural move: it extends registration and AML-obligated-subject status to a category of financial company that previously sat under MICI licensing without a parallel AML registration requirement at the banking supervisor. This is the kind of architecture-level change that matters more than any single enforcement action, because it changes who is inside the regulatory perimeter going forward rather than punishing a single actor after the fact. The full text of the Acuerdo was not independently retrieved this cycle; the registration process and its timelines are known through Panamanian press coverage rather than the SBP's own publication, which leaves the precise scope of which empresas financieras fall inside the new requirement less than fully pinned down. The flag registry keeps reacting, not anticipating. The cancellation of seven vessel registrations in the wake of the October OFAC actions is enforcement-after-the-fact, not pre-emption. Reporting on the de-registrations describes a maritime authority responding to a list it did not generate and could not have anticipated, rather than a screening function that would have flagged the ownership or management links before a vessel was sanctioned. Taken over multiple cycles, this reactive posture is itself the finding: an absence of pre-designation screening in a jurisdiction that otherwise carries one of the world's largest open shipping registries is analytically significant in its own right, not merely a gap in the record. Panama remains off the FATF grey list, and nothing moved this cycle. Panama was removed from the FATF grey list in October 2023 and no plenary action affecting that status was found this cycle. This is a standing baseline fact rather than a new development, and it sits in tension with the designation activity above: an AML/CTF regime judged adequate enough to avoid increased monitoring from the FATF is nonetheless the jurisdiction repeatedly named in US sanctions-evasion designations tied to shipping. #### Cross-Monitor Connections The shadow-fleet designation and the related vessel de-registrations sit squarely at the intersection of this monitor's sanctions-architecture work and the conflict-finance and commodity-flow analysis tracked elsewhere in the fleet, given the Iranian petroleum-export nexus underlying the OFAC action. The state-capture angle on Panama's registry governance, and any state-level posture toward flag-of-convenience oversight, is a matter for the separate monitor covering state and institutional capture rather than for restatement here. #### Outlook The SBP's six-to-nine month registration windows under Acuerdo No. 1-2026 put a concrete compliance horizon in front of MICI-licensed empresas financieras, and the next cycle's research priority is retrieving the Acuerdo's own text to confirm the precise scope of covered entities rather than relying on secondary press description. On the sanctions side, the question worth continued attention is whether any additional Panama-flagged vessels or Panama-resident facilitators surface in follow-on OFAC or allied-jurisdiction designations tied to the same shadow-fleet network, and whether the Panama Maritime Authority's registration-cancellation response time narrows in future cycles, which would itself be a sign of improved upstream screening rather than pure reaction. Illustrative scenario for analytical orientation only. Forward motion on either front, were it to occur, would most plausibly show up first as a published SBP circular detailing the empresas financieras registration scope, or as a second wave of vessel cancellations following a subsequent OFAC action. Neither is asserted to be underway; both are offered only to orient what a continuing signal would look like. Not compliance advice, not a prediction, and not a statement of observed fact. Earlier periodic briefs (8) 4 Nov 2026 · fim-2026-11-01 #### Lead Signal Panama's financial-integrity picture is dominated by the collision of two separate forces acting on the same flag registry and the same supervisory perimeter. On 21 October 2026, the US Treasury's Office of Foreign Assets Control designated a Panama City resident and a Panama/Greece-based maritime manager under Executive Order 13902 for facilitating Iranian petroleum exports via a shadow fleet, effective that date. The designation blocks the property of the listed parties. In the days that followed, the Panama Maritime Authority initiated proceedings to cancel the registration of seven Panama-flagged vessels caught up in this and related October 2026 OFAC actions. Read together, these two developments continue a pattern this monitor has tracked for some time: Panama's flag registry responds to US sanctions designations after the fact, cancelling registrations once a vessel has already been named, rather than screening ownership or beneficial control structures in a way that would catch the risk before a listing happens. The architecture question is not whether Panama de-registers sanctioned ships; it does, reliably. It is whether the registry's screening function operates upstream of designation at all, and nothing in the material gathered indicates that it does. Alongside the sanctions story, Panama's banking supervisor has moved independently to tighten its own obligated-entity perimeter. The Superintendencia de Bancos de Panama issued Acuerdo de Prevencion para Otros Sujetos Obligados Financieros No. 1-2026, dated 20 October 2026, which establishes a registration process bringing MICI-licensed empresas financieras (financial companies licensed by the Ministry of Commerce and Industry rather than by the banking regulator itself) within the SBP's AML-obligated-subject net under the base statute, Law 23 of 2015. Newly licensed firms get nine months to register; firms already operating get six. #### Other Developments A supervisory perimeter closes rather than opens. The SBP's Acuerdo No. 1-2026 is a structural move: it extends registration and AML-obligated-subject status to a category of financial company that previously sat under MICI licensing without a parallel AML registration requirement at the banking supervisor. This is the kind of architecture-level change that matters more than any single enforcement action, because it changes who is inside the regulatory perimeter going forward rather than punishing a single actor after the fact. The full text of the Acuerdo was not independently retrieved; the registration process and its timelines are known through Panamanian press coverage rather than the SBP's own publication, which leaves the precise scope of which empresas financieras fall inside the new requirement less than fully pinned down. The flag registry keeps reacting, not anticipating. The cancellation of seven vessel registrations in the wake of the October OFAC actions is enforcement-after-the-fact, not pre-emption. Reporting on the de-registrations describes a maritime authority responding to a list it did not generate and could not have anticipated, rather than a screening function that would have flagged the ownership or management links before a vessel was sanctioned. Taken over multiple cycles, this reactive posture is itself the finding: an absence of pre-designation screening in a jurisdiction that otherwise carries one of the world's largest open shipping registries is analytically significant in its own right, not merely a gap in the record. Panama remains off the FATF grey list, and nothing moved. Panama was removed from the FATF grey list in October 2023 and no plenary action affecting that status was found. This is a standing baseline fact rather than a new development, and it sits in tension with the designation activity above: an AML/CTF regime judged adequate enough to avoid increased monitoring from the FATF is nonetheless the jurisdiction repeatedly named in US sanctions-evasion designations tied to shipping. #### Cross-Monitor Connections The shadow-fleet designation and the related vessel de-registrations sit squarely at the intersection of this monitor's sanctions-architecture work and the conflict-finance and commodity-flow analysis tracked elsewhere in the fleet, given the Iranian petroleum-export nexus underlying the OFAC action. The state-capture angle on Panama's registry governance, and any state-level posture toward flag-of-convenience oversight, is a matter for the separate monitor covering state and institutional capture rather than for restatement here. #### Outlook The SBP's six-to-nine month registration windows under Acuerdo No. 1-2026 put a concrete compliance horizon in front of MICI-licensed empresas financieras, and the next research priority is retrieving the Acuerdo's own text to confirm the precise scope of covered entities rather than relying on secondary press description. On the sanctions side, the question worth continued attention is whether any additional Panama-flagged vessels or Panama-resident facilitators surface in follow-on OFAC or allied-jurisdiction designations tied to the same shadow-fleet network, and whether the Panama Maritime Authority's registration-cancellation response time narrows in future cycles, which would itself be a sign of improved upstream screening rather than pure reaction. Illustrative scenario for analytical orientation only. Forward motion on either front, were it to occur, would most plausibly show up first as a published SBP circular detailing the empresas financieras registration scope, or as a second wave of vessel cancellations following a subsequent OFAC action. Neither is asserted to be underway; both are offered only to orient what a continuing signal would look like. Not compliance advice, not a prediction, and not a statement of observed fact. 3 Nov 2026 · fim-2026-11-03 #### Lead Signal Panama's two live signals sit on opposite ends of the enforcement spectrum, and both point the same direction: external pressure continues to do more work than domestic initiative in shaping the country's financial-integrity posture. On 21 October 2026, the US Treasury's Office of Foreign Assets Control designated Panama-resident individuals and a Panama/Greece-based maritime manager under Executive Order 13902, for facilitating Iran's petroleum shadow fleet. The designation blocks the property of the listed parties from the effective date. In parallel, Panama's Superintendencia de Bancos (SBP) issued Acuerdo de Prevencion para Otros Sujetos Obligados Financieros No. 1-2026 on 20 October 2026, establishing a registration process requiring MICI-licensed financial companies, empresas financieras, to register with SBP as AML-obligated financial subjects under Law 23 of 2015. Existing firms have six months to comply; newly licensed firms have nine. The SBP accord is a structural move: it extends the AML-obligated-subject perimeter to a category of firms previously supervised for licensing purposes by the Ministry of Commerce and Industry (MICI) but not formally folded into SBP's AML architecture. No new licence type is created; the accord instead closes a registration gap in an already-existing supervisory population. Read together, the OFAC action and the SBP accord describe a jurisdiction whose integrity architecture is still substantially reactive on the sanctions side and incrementally expanding on the domestic AML side, rather than one undergoing a single comprehensive overhaul. #### Other Developments Vessel de-registration continues on a reactive timetable. Following the OFAC designation, the Panama Maritime Authority has initiated proceedings to remove seven sanctioned vessels from the Panama flag registry. This is consistent with the registry's established pattern of responding to US sanctions action after the fact rather than screening for exposure in advance of designation, and it is the kind of enablement-adjacent signal that is more informative for its timing than for the individual vessels involved. The AML registration extension sits inside a broader incremental pattern. The Acuerdo No. 1-2026 registration requirement for empresas financieras is best read as the latest in a series of perimeter-tightening steps around newer or previously under-supervised financial-services categories, rather than as part of a single comprehensive legislative package. The instrument's own text was not directly retrieved; the finding rests on secondary Panamanian press coverage, and confidence is held at the probable tier pending primary-source retrieval of the SBP accord itself. #### Cross-Monitor Connections The Iran petroleum shadow-fleet designation and the associated flag-registry de-registrations connect directly to conflict-finance and commodity-flow monitoring: Panama's open registry has long been a structural node in shadow-fleet logistics, and the pattern of reactive de-flagging after each new sanctions round is itself a finding about the registry's screening posture rather than about any single vessel. The SBP registration accord is lower-salience for cross-monitor routing, since it concerns domestic AML-obligated-subject status rather than a cross-border enablement question, but it is relevant to any tracking of how Panama's financial-company licensing population is being folded into AML supervision over time. #### Outlook Two threads are worth holding separately going forward. First, whether the Panama Maritime Authority's vessel de-registrations keep pace with future OFAC rounds, or whether a backlog accumulates, will be a useful indicator of whether the registry's reactive posture is improving or merely continuing. Second, the compliance windows set by Acuerdo No. 1-2026 give a concrete marker: existing empresas financieras face a six-month registration deadline from the accord's entry into force, and newly licensed firms face nine months, so the mid-2027 window is when non-compliance, if any, would first become visible. Separately, Panama's long-pending fintech framework bill, Anteproyecto de Ley No. 314, remains at the proposed stage with an estimated effect date as scheduled for the second quarter of 2027; it would introduce licensing categories for virtual-asset service providers, payment companies and electronic-money issuers where none currently exists, but as a bill still before the National Assembly its passage and final form remain unresolved. 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Panama's anti-money-laundering posture is defined by a sharp divergence between sectors rather than by any single enforcement event. Suspicious transaction reports filed with the Unidad de Analisis Financiera (UAF) show bank-sector reports rising 11 percent year-on-year, from 1,117 to 1,237, across the January-to-September 2026 window, while real-estate-sector reports rose far more steeply, climbing from just 2 to 9 filings, a 350 percent increase off a very small base. At the same time, the national total of suspicious transaction reports fell 9 percent, from 1,603 to 1,462. Read together, these numbers describe a system in which detection intensity is reallocating toward banking and, from an extremely low starting point, toward real estate, even as aggregate volume contracts. The reallocation is structurally significant: a rising banking share suggests the formal financial sector is tightening its own filters, while the real-estate increase, though numerically small, signals the beginning of scrutiny in a sector regional evaluators have long identified as an enabler for layering proceeds through property purchases. The second structural thread is institutional rather than statistical. Panama now holds the 2026 Pro-Tempore Presidency of GAFILAT, the regional FATF-style body, and its Fifth Round mutual evaluation has been placed on the calendar for May 2028, positioned behind Costa Rica (November 2026), Honduras (May 2027) and Guatemala (November 2027). This round is explicitly effectiveness-weighted rather than built around a technical-compliance checklist, meaning Panama will need to demonstrate operational results on beneficial ownership, virtual assets, non-profit organisations and asset recovery rather than simply show that the relevant statutes exist. Panama's exit from the FATF grey list in October 2023 remains intact, but the leadership role it now holds raises the reputational stakes attached to how it performs under the new methodology. #### Other Developments Judicial enforcement in an organised-crime money-laundering case advanced. The Tribunal Superior de Apelaciones confirmed provisional detention for eleven individuals and house arrest for two more under Operacion Poseidon, a case combining organised-crime and money-laundering elements. The ruling was reported by a single quality press source, and the underlying court decision itself was not independently retrieved, so the finding should be read as a confirmed procedural step rather than a fully documented case history. The fintech and virtual-asset licensing perimeter remains unsettled. The Anteproyecto de Ley N.314, Panama's draft comprehensive financial-technology framework, together with three separate virtual-asset bills, remains without a scheduled first debate in the National Assembly. In parallel, the Superintendencia del Mercado de Valores has continued to issue non-general opinions concluding that certain non-custodial token schemes fall outside its licensing perimeter, effectively leaving those schemes without a dedicated supervisory home while the legislative process remains stalled. An International Monetary Fund Article IV mission reviewed risk-assessment approaches for virtual assets and virtual-asset service providers with the Superintendencia de Bancos de Panama in mid-October, indicating external interest in how Panama intends to close this gap even before domestic legislation advances. The obligated-subject registration base held steady at scale. UAF data put the count of registered obligated subjects at 16,805 across five supervisory bodies as of end-September 2026. This is an anti-money-laundering registration figure, not a beneficial-ownership register update, and should not be read as evidence of a parallel corporate-transparency development. #### Cross-Monitor Connections The unsettled fintech and virtual-asset licensing track connects directly to parallel digital-asset-market and payments-sector monitoring: the same Anteproyecto de Ley N.314 and the same Superintendencia del Mercado de Valores non-general opinions that leave token platforms outside a licensing perimeter from an anti-money-laundering perspective also define the commercial and prudential perimeter tracked elsewhere. The absence of a dedicated virtual-asset-service-provider supervisory regime is therefore a shared structural gap rather than a finding isolated to financial-crime risk alone, and the IMF's direct engagement with the banking supervisor on virtual-asset risk assessment is a signal likely to resurface in adjacent coverage of payments and market infrastructure. #### Outlook The most consequential date on the horizon remains May 2028, when Panama's Fifth Round mutual evaluation is expected, per the GAFILAT schedule reported by Panama's own Ministerio de Economia y Finanzas, with its effectiveness-weighted methodology. Between now and then, the diverging sectoral suspicious-transaction-report trend bears watching: whether the modest real-estate increase continues to build from its low base, and whether the national-level decline in total filings reflects genuine risk reduction or reduced reporting discipline outside banking, will matter to how Panama's effectiveness case looks when evaluators arrive. The fintech and virtual-asset legislative track is unlikely to resolve quickly; as scheduled, the Anteproyecto de Ley N.314 has no confirmed date for a first debate, and the regime is likely to remain in a legally permissive but administratively supervised state, anchored only in general AML registration with the UAF, through at least the near term. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Panama's financial-integrity posture this cycle is defined by a cybersecurity incident at the Unidad de Analisis Financiero (UAF), the countrys financial intelligence unit, which detected an information-security incident and temporarily suspended its technology platforms and services. The suspension disrupted suspicious-transaction-report (STR) intake from roughly 16,727 obligated subjects, with no stated restoration date at the time of reporting. This is probable, corroborated by a second independent outlet, though UAFs own communique confirmed the incident without technical detail. The episode lands against a backdrop in which Panama remains formally off both the FATF grey list (delisted October 2023) and the EU AML/CFT high-risk list (delisted July 2025), so the disruption reads as an operational shock to the reporting pipeline rather than a reversal of the structural delisting trajectory. Separately, Panama enacted Law No. 526 of 28 May 2026, an Economic Substance Law requiring entities within multinational groups that earn foreign-source passive income (dividends, interest, royalties, capital gains, real estate income) to demonstrate genuine economic substance in Panama or face a 15 percent flat tax on net taxable passive income starting FY2027. Entities supervised by the Superintendencia de Bancos de Panama (SBP), securities and insurance regulators, and the merchant marine sector are excluded. This is confirmed, drawing on a Tier-1 US State Department source corroborated by secondary commentary, and is best read as a transparency-adjacent measure targeted squarely at the separate designation Panama still carries: the EU's non-cooperative tax-jurisdictions list, which is distinct from the AML high-risk list Panama has already exited. #### Other Developments Gambling-sector suspicious-activity reporting rose sharply within the non-financial-sector category. UAF's own H1 2026 statistics recorded 839 STRs; gambling-related reports led the non-financial-sector category with an increase of 58 percent, ahead of lawyers, real estate and car sales. This is probable, drawn from press reporting of UAF's published statistics rather than independently retrieved primary data, and signals a widening AML footprint across non-financial obligated entities where gambling activity is concentrated. The SBP tightened bank-sanctioning criteria for AML/CFT/CPF non-compliance. The Superintendencia de Bancos approved a new norm setting clearer criteria for sanctioning banks that fail to comply with anti-money-laundering, counter-terrorist-financing and counter-proliferation-financing rules. This arrives alongside continued growth in the International Banking Centre's deposit base, reported at $121.866 billion, up 7.69 percent year on year. This is probable, based on press reporting of an SBP regulatory action whose primary Acuerdo text was not independently retrieved this cycle. Panama's dedicated VASP/PSP/EMI licensing bill remains unenacted. Draft Law No. 314 (Ley Marco Integral de Tecnologias Financieras), filed 13 January 2026, has not been enacted as of this cycle. This is confirmed via a Tier-1 source. In its absence, crypto-asset firms continue to operate under general AML registration requirements set by Law 23 of 2015, which remains the only binding compliance layer for the sector. #### Cross-Monitor Connections The gambling-sector STR increase documented by UAF's own statistics creates a direct overlap with advennt's gambling-regulation coverage: a 58 percent rise in gambling-related suspicious-activity reports is simultaneously an AML signal and a gambling-sector compliance signal, and the two readings should be held together rather than treated as separate findings. The UAF platform suspension also surfaces on the world-payments side as a sentinel-fed AML/CFT item; the substantive analysis of that incident belongs here, in financial integrity, with world-payments treating it as a cross-reference rather than re-analysing it. The unresolved status of Draft Law 314 is a shared watch item with crypto and world-payments monitors, both of which track the same bill's prospective VASP/PSP/EMI licensing categories; no monitor should treat its non-enactment as a finding specific to its own domain. #### Outlook The UAF's platform suspension is best read as a discrete episodic disruption rather than a structural regime change, but the absence of a stated restoration date means the operational gap in STR processing could persist into the next reporting period; a primary UAF technical statement or restoration confirmation would resolve this uncertainty. On the beneficial-ownership and enabler-jurisdiction tracks, the Economic Substance Law's FY2027 effective date gives Panama roughly a year to operationalise substance-demonstration requirements before the measure is tested in practice, and its stated aim of addressing the EU's non-cooperative tax list designation makes that list, rather than the AML high-risk list, the metric to watch for whether this reform registers externally. On crypto and digital assets, Draft Law 314 remains the single most consequential pending instrument for Panama's financial-integrity architecture; as scheduled for potential movement in Q4 2026, its continued non-enactment leaves VASP activity governed only by general AML registration under Law 23 of 2015. 12 Oct 2026 · fim-2026-10-11 #### Lead Signal Panama's financial-integrity architecture moved on two structural fronts this cycle rather than through a single headline enforcement action. The Superintendencia de Bancos de Panama (SBP) issued Acuerdo No. 1-2026 on 16 January 2026, repealing the decade-old Acuerdo 10-2015 and tightening know-your-customer, ultimate-beneficial-owner and remote-onboarding due diligence for banks and fiduciaries, with explicit risk-based identification duties attaching to holders of 10 percent or more of an entity. In parallel, Panama's economic-substance regime, introduced by Ley 526 of 28 May 2026 and regulated by Decreto Ejecutivo No. 32 of 2 September 2026, now requires multinational-group entities earning foreign-source passive income to demonstrate genuine local substance, including a resident director or staff, Panama-based strategic decision-making and a minimum of two in-person board meetings a year, or face a flat 15 percent tax on the passive income plus penalties. Read together, these are not incident-level findings but a coordinated narrowing of the structuring and onboarding channels that have historically defined Panama's role as an enabler jurisdiction. The backdrop against which both developments register is a standing AML/CTF regime that has itself been durable rather than reactive. Panama's framework rests on Ley 23 of 27 April 2015, as amended, and Decreto Ejecutivo 35 of 2022, with the SBP as sector supervisor and the Unidad de Analisis Financiero as financial intelligence unit. Panama has remained off the FATF list of jurisdictions under increased monitoring since October 2023 and off the European Union's list of high-risk third countries since 2025, and neither designation moved this cycle. The significance of the new onboarding and substance rules is therefore best read as incremental tightening layered onto an already-exited grey-list posture, not as a jurisdiction responding to renewed external pressure. #### Other Developments Electronic-funds-transfer supervision tightened. SBP Acuerdo No. 8-2026, signed 22 September 2026, imposes a new supervision and validation scheme for the movement of funds through electronic channels within national territory, reported via Panamanian press coverage of the primary regulatory act. The same dated action, Acuerdo No. 9-2026, defers the credit-adequation deadline originally set by Acuerdo 6-2026 to 31 March 2027, indicating the supervisor is sequencing implementation rather than relaxing the underlying standard. Fintech and virtual-asset licensing bill remains stalled. Anteproyecto de Ley 314, a comprehensive bill that would create dedicated licensing for virtual-asset service providers, payment service providers and electronic-money institutions under joint SBP prudential and UAF anti-money-laundering oversight, had completed its introduction phase in the Asamblea Nacional as of April 2026 reporting. No enactment or plenary-debate movement was found dated within the current research window, and the current legislative posture should be read with that dating gap in mind rather than as confirmed ongoing committee activity. Compliance-technology engagement continues at the regional level. SBP participated in a regional workshop, convened under the GAFILAT umbrella, on engagement with the private sector covering fintech, emerging technologies and anti-money-laundering and counter-terrorist-financing transaction identification. This is institutional dialogue rather than new supervisory guidance, and no RegTech rule change accompanied it this cycle. #### Cross-Monitor Connections The economic-substance regime under Ley 526/2026 and Decreto 32/2026 sits at the intersection of financial integrity and corporate-transparency policy more broadly watched by data-protection and payments monitors insofar as beneficial-ownership identification increasingly depends on the same digital-onboarding infrastructure SBP's Acuerdo No. 1-2026 now governs. The electronic-funds-transfer supervision introduced by Acuerdo No. 8-2026 also has a direct payments-infrastructure dimension, since the scheme applies to domestic fund movement through electronic channels used by the same bank and non-bank payment actors tracked under the payments-monitor's licensing and conduct modules. Neither connection constitutes a finding in financial integrity's own typology library this cycle; they are flagged here as routing signals for readers following the payments and corporate-transparency threads in parallel. #### Outlook The near-term marker to watch is whether Decreto Ejecutivo No. 32's economic-substance declarations begin producing measurable attrition in Panama's historical shell-structuring base, a question current reporting cannot yet answer because the regime commenced only in September 2026. On the fintech-licensing track, Anteproyecto de Ley 314 remains a multi-year proposition: committee review, two plenary debates and presidential assent would all still need to occur before Panama acquires its first dedicated virtual-asset and payment-institution licensing architecture, and the absence of confirmed movement this cycle means that timeline should be treated as unresolved rather than delayed. On the standing AML/CTF file, Panama's continued absence from both the FATF increased-monitoring list and the EU high-risk list remains the stable backdrop; the newly sequenced electronic-funds-transfer supervision and the deferred credit-adequation deadline under Acuerdos 8-2026 and 9-2026 suggest the supervisor is prioritising orderly phasing over rapid enforcement, a posture worth monitoring as the March 2027 deadline approaches. 4 Oct 2026 · fim-2026-10-04 #### Lead Signal Panama's financial-integrity posture this cycle is defined by a reinforcement of standing supervisory architecture rather than by new primary legislation. The Superintendencia de Bancos de Panama (SBP) issued Acuerdo No. 1-2026 on 27 January 2026, restating and sharpening the customer due diligence and beneficial-owner identification duties that Articles 112 to 114 of the Banking Law already impose on banks and fiduciaries, and tying those duties explicitly to United Nations Security Council freeze-list procedures. This is an architecture-level finding: the rule does not create a new obligation so much as it hardens the documentary and monitoring expectations sitting on an existing one, and it does so for the sector most exposed to correspondent-banking counterparty risk. Alongside this, Panama remains off the FATF grey list, a status unchanged since its October 2023 delisting and confirmed against the 19 June 2026 plenary roster of twenty-two listed jurisdictions. The second thread this cycle is structural rather than enacted: Draft Law 314, the Ley Marco Integral de Tecnologias Financieras filed on 13 January 2026, would create dedicated licensing categories for virtual-asset service providers, payment-service providers and electronic-money issuers under joint SBP oversight, replacing the current arrangement in which such firms operate under general AML registration alone pursuant to Law 23 of 2015. The bill remains unenacted, and the only support located this cycle for its content and status is Tier-3 legal commentary; no Tier-1 primary legislative text was retrieved, which caps confidence at Probable rather than Confirmed. #### Other Developments Supervisory tightening without new legislation. Acuerdo 1-2026 is best read as compliance-architecture maintenance: it gives banks and fiduciaries a sharper documentary standard for customer and beneficial-owner identification and for maintaining transaction-monitoring capability, including frozen-asset procedures tied to UN Security Council lists, but it operates within the existing Banking Law framework rather than extending it to new entity types. The VASP/PSP/EMI licensing gap persists. Firms offering virtual-asset, payment, or e-money services in Panama continue to rely on general AML registration under Law 23/2015 rather than any activity-specific licensing regime. Draft Law 314 is the vehicle proposed to close that gap, but its progress through the legislative process has not produced an enacted instrument this cycle, and the evidentiary base behind it remains thin. FATF status stable. Panama's continued absence from the FATF grey list is a confirmed, Tier-1-sourced fact, cross-checked directly against FATF's own list rather than inferred from commentary. There is no movement to report on EU high-risk-third-country status either, and nothing in this cycle's substrate suggests either list is under near-term review for Panama. #### Cross-Monitor Connections The Draft Law 314 licensing gap sits squarely on the FIM/WPM boundary: a jurisdiction with no activity-specific licensing perimeter for payment and e-money firms is, from a payments-market-access perspective, operating on bare AML registration, which is the same structural fact driving this cycle's World Payments Monitor findings on Panama. The absence of a dedicated VASP supervisory layer is also a standing input to the broader crypto-integrity tracker, since firms handling virtual assets in Panama are currently assessed against general AML registration rather than a sector-calibrated licensing test — a gap that persists until Draft Law 314, or something like it, is enacted. #### Outlook Absent enactment of Draft Law 314, Panama's AML/CTF architecture will likely continue to be reinforced incrementally at the supervisory-rule level — as Acuerdo 1-2026 illustrates — rather than through primary legislation extending licensing perimeters to new entity types. Whether the draft law advances remains uncertain on the evidence available this cycle; as scheduled, legislative movement would need Tier-1 confirmation before the current Probable-confidence assessment of its content and status could be upgraded. Panama's grey-list standing is not expected to shift absent a material change in FATF's own assessment process, which this cycle's sourcing does not indicate. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Panama presents this cycle as a jurisdiction where the sanctions-architecture picture and the beneficial-ownership picture point in different directions at once. Two 2026 OFAC actions implicate Panama-domiciled corporate officers and a Panama-flagged vessel as passive enabling nodes in foreign-directed illicit-finance networks, even as Panama itself remains off both the FATF grey list and the EU high-risk third-country list. On 26 June 2026, OFAC designated Panama City-based corporate officers, including individuals linked to Talent Bridge, S.A., under Executive Order 14098 for their role in a Sudan war-economy procurement and recruitment network. Separately, on 10 February 2026, OFAC identified the Panama-flagged bulk carrier BRILLIANCE, linked to Brilliance Maritime Ventures S.A., as blocked property under the Hizballah Financial Sanctions Regulations. Neither action designates Panama as a state actor; both illustrate the continued utility of Panama's corporate-registration and flag-registry infrastructure to sanctioned networks based elsewhere. #### Other Developments Beneficial ownership remains structurally non-public. Panama's beneficial-ownership regime under Law 129 of 17 March 2020 continues to operate as a private, non-public system: beneficial ownership is collected by resident agents and filed to the Superintendencia de Sujetos No Financieros (SSNF), with the register itself inaccessible to the public. This resident-agent-mediated, non-public filing structure is a long-standing professional-enablement feature of Panama's corporate-services sector and sits in some tension with the global direction of beneficial-ownership transparency reform. Against that general non-public posture, a narrower and more transparent step occurred in a specific sector: the Autoridad de los Recursos Acuáticos de Panamá (ARAP) published beneficial-ownership data for vessels in Panama's international fishing fleet ahead of the June 2026 Our Ocean Conference, embedding BO disclosure into vessel pre-registration for that fleet specifically. The contrast is instructive: where a sector-specific international commitment created pressure for transparency, Panama moved; where the general corporate-registry regime is concerned, non-public filing under Law 129 remains the operative model. Crypto and digital-asset oversight advances without a licensing regime yet in force. Panama continues to lack a comprehensive VASP or CASP licensing framework. Draft Law No. 314, a proposed fintech framework under review by the National Assembly, would create dedicated licensing for virtual-asset service providers, crypto-asset service providers, payment service providers and e-money issuers under joint supervision by the Superintendencia de Bancos de Panamá (SBP) and the Unidad de Análisis Financiero (UAF). In the interim, the SBP's Rule (Acuerdo) No. 1-2026, effective 27 January 2026, tightens AML/CFT documentary and customer-due-diligence obligations across all SBP-supervised entities, expressly revoking four prior rules including Rules 10-2015, 1-2013 and 8-2000. This is a general prudential tightening rather than a crypto-specific licensing instrument, and it applies to banks and other SBP-supervised entities pending any eventual enactment of Draft Law No. 314. #### Cross-Monitor Connections The Hizballah-linked, Panama-flagged vessel designation sits at the intersection of sanctions architecture and conflict finance: the same underlying development that anchors the D1 sanctions reading also touches on financing patterns connected to a designated terrorist organisation, though no independent conflict-finance-specific finding beyond this cross-reference was reached this cycle. The absence of a comprehensive VASP licensing regime, combined with an active legislative proposal to create one, is directly relevant to any parallel gambling-sector payment-restriction analysis for Panama, since both threads describe a jurisdiction moving from light-touch, general-registration-based oversight toward more instrument-specific supervision across financial-services verticals simultaneously. #### Outlook The structural question to watch is whether Draft Law No. 314 advances toward enactment or stalls, since Panama and Costa Rica are reported as the last two Central American jurisdictions without a dedicated VASP/PSP/EMI licensing regime. Separately, watch for whether Panama's non-public beneficial-ownership posture under Law 129 comes under renewed international pressure, given the contrast between the general corporate-registry opacity and the narrow transparency advance achieved in the fishing-fleet sector. Panama's stable position off both the FATF grey list and the EU high-risk list provides no near-term signal of listing risk, but continued use of Panama-domiciled entities and the Panama flag registry in OFAC designations is worth monitoring as a recurring enabling-layer pattern rather than an isolated event. 11 Aug 2026 · fim-2026-08-05 #### Lead Signal This cycle's lead signal for Pennsylvania is EagleBank's resolution of a decade-long Bank Secrecy Act and anti-money-laundering program failure through a Department of Justice non-prosecution agreement. EagleBank, operating as Eagle Bancorp, Inc., admitted it willfully failed to establish an AML/CFT program between 2010 and 2021, a period during which a father-son customer pair ran a check-kiting scheme for ten years. The resolution carries a fine of $9,057,821.62 plus forfeiture of $736,515, for a total exceeding $9.7 million. This is a confirmed, Tier 1, high-confidence finding, and it is read here architecturally rather than as an isolated incident: a decade-long absence of a functioning compliance program at a regulated bank, resolved through settlement rather than prosecution, is itself the structural signal, independent of the specific customer scheme it happened to surface. The three-pillar balance principle cautions against reading this only as an AML matter: a program failure of this duration at an institution of this scale carries latent counter-terrorist-financing and counter-proliferation-financing exposure that a settlement resolving only the pleaded AML facts does not fully surface, and that gap in visibility is itself part of the lead signal this cycle. #### Other Developments Pennsylvania closes its virtual-currency licensing gap. Act 7 of 2025 (SB 202) extends Money Transmitter Act licensure to virtual-currency transmission conducted for a fee, effective August 26, 2025, and the state simultaneously rescinded its prior non-binding Virtual Currency Statement of Policy at 10 Pa. Code Section 19.1a as redundant. Both developments are confirmed, high-confidence, Tier 1 findings, and together they represent a structural closure of what had previously been a licensing gap for fee-based virtual-currency transmission in the state. Deibler Brothers Novelty Company felony forfeiture. The Pennsylvania Office of Attorney General secured a felony conviction against Deibler Brothers Novelty Company for corrupt organizations tied to hundreds of illegal video gambling machines installed across the state, with a $3,000,000 forfeiture ordered. This is an assessed-confidence finding sourced to a single Tier 1 source without independent corroboration this cycle. Skill-games licensing and tax framework remains unresolved. The Pennsylvania General Assembly did not address skill-games licensing or taxation in the signed FY2026-27 budget, leaving the framework at consultation stage ahead of the October 13, 2026 enforcement-stay deadline. This is an assessed-confidence, cross-pillar finding, and it sustains the cash-intensive unlicensed-gambling exposure identified in the enabler-jurisdiction domain this cycle. #### Cross-Monitor Connections The Deibler Brothers matter and the unresolved skill-games legislative question sit at the intersection of this monitor's enabler-jurisdiction domain and parallel gambling-regulatory tracking maintained elsewhere in the fleet: the same underlying device population and the same October 13, 2026 deadline that drive the gambling-regulatory read are also the facts that sustain this cycle's domestic money-laundering-vector assessment. Similarly, Pennsylvania's virtual-currency licensing closure under Act 7 is a payments-adjacent development with direct relevance to any parallel payments-regulation tracking of the same statute; the licensing perimeter it establishes is the shared factual basis for both readings, even though this monitor's contribution is limited to the AML/enabler-exposure lens rather than a payments-market-structure assessment. #### Outlook Two dates anchor the outlook for Pennsylvania. The nearer-term structural question, Act 7's licensing perimeter, is now settled in text; the open question is whether the Department of Banking and Securities begins bringing enforcement or licensing actions under it, which would convert this cycle's structural finding into an operational track record. The more consequential date is October 13, 2026, when the Pennsylvania Supreme Court's stay on its skill-games ruling expires; whether the General Assembly enacts a licensing and taxation framework before that date will determine whether the domestic unlicensed-gambling enabler exposure identified this cycle persists, narrows, or is formally brought inside a regulatory and AML perimeter. Domain intelligence (D1–D8) #### Sanctions OFAC's action of 21 October 2026 designated a Panama City resident and a Panama/Greece-based maritime manager under Executive Order 13902 for roles facilitating Iranian petroleum exports through a shadow fleet, with the designation blocking the property of the listed parties effective that date. This is a confirmed primary-source finding, drawn from the Federal Register notice itself rather than secondary characterisation. The appropriate category here is comprehensive sanctions in the narrow sense that the underlying US sanctions programme against Iranian petroleum exports is a embargo-style regime; the designation itself is a listing action under that regime rather than a new sectoral measure. Continue reading The second half of the picture is the Panama Maritime Authority's response: proceedings to cancel the registration of seven Panama-flagged vessels caught up in this and related October 2026 designations. This is reported with probable confidence from a trade-press account rather than the Authority's own notice, and it describes a pattern that recurs across cycles - the flag registry acting after a vessel is named rather than screening for sanctions-exposed ownership or management in advance. No parallel EU or UK listing against the same parties was identified this cycle, which continues a divergence between the US sanctions programme and allied listing activity that this monitor has flagged as a standing watch item. The absence of a coordinated multilateral listing, set against the scale of Panama's open shipping registry, is itself worth noting: a jurisdiction that hosts one of the largest flag registries in the world is exposed to this kind of reactive cancellation pattern precisely because pre-designation screening does not appear to be occurring at the registry level. #### Outlook The registry's response time to the October designations, and whether any further Panama-flagged vessels or Panama-based facilitators are named in follow-on actions tied to the same Iranian shadow-fleet network, are the two threads worth tracking into the next period. A narrowing of the gap between designation and de-registration would be the first sign of improved upstream screening; continued strictly-reactive cancellation would confirm the standing pattern. Illustrative scenario for analytical orientation only: a plausible next step, if the pattern continues unchanged, is a further batch of cancellations following any additional OFAC listing naming Panama-flagged tonnage - this is offered to orient attention, not as a prediction. Not compliance advice, not a prediction, and not a statement of observed fact. Judgment: OFAC's 21 October 2026 designation of Panama-resident individuals and a Panama/Greece-based maritime manager for Iran shadow-fleet facilitation continues a pattern of Panama's flag registry responding reactively to US designations via vessel de-registration rather than pre-empting them. Probable #### Crypto, Digital Assets, and Financial Innovation The digital-asset regulatory environment directly relevant to Panama this cycle is defined by absence rather than by presence: Panama has no comprehensive virtual-asset service provider or crypto AML statute in force, following a 2022 presidential veto of a licensing bill on the grounds of inadequate AML controls. This leaves a live FATF Recommendation 15 supervisory-perimeter gap open for any virtual-asset activity conducted by or accessed through Panama-based operators, a gap that has now persisted for more than four years since the veto. Against that backdrop, the most concrete development this cycle is not legislative but institutional: UNODC, with backing from the Canadian government, delivered high-level AML and CFT training in January 2026 to the Ministry of Economy and Finance, the Unidad de Analisis Financiero and the Attorney General Office of Panama on virtual-asset supervision. This training signals capacity-building momentum within the regulatory apparatus of Panama, but it has not, as of this cycle, produced enacted legislation, and the underlying source for this training is tier-flagged at T3 in the cumulative source register despite the broader jurisdiction record generally reflecting stronger sourcing; the more conservative tier has been honoured per source-quality carry-through discipline. Continue reading Globally, frameworks such as the EU markets-in-crypto-assets regulation and the FATF virtual-asset standards set the structural direction for digital-asset regulation generally, and Panama sits outside both of those direct perimeters: the EU framework applies within the European Economic Area rather than to Panama, and the FATF virtual-asset standards function as an international benchmark against which the absence of Panamanian implementing legislation is measured rather than a directly binding instrument. This global backdrop is relevant to Panama primarily as the reference point against which the current legislative gap is assessed as a gap at all, rather than as a direct source of obligation. A key judgment carried by this baseline is that the absence of a VASP or crypto AML statute in Panama five years after the 2022 veto represents a persistent legal gap rather than a capacity deficit alone, given that continued international capacity-building support has not been matched by corresponding legislative action; this judgment is assessed at possible rather than assessed or high confidence, reflecting the inherent difficulty of distinguishing genuine capacity constraints from deliberate legislative inaction from outside sources alone. The customer typology most directly exposed by this gap is virtual-asset service provider counterparties dealing with Panama-linked crypto-asset operators, for whom the absence of a domestic supervisory perimeter means that counterparty due diligence cannot rely on any Panama-specific licensing or registration requirement. The research coverage this cycle did not extend to a primary retrieval of any Panamanian legislative record beyond secondary UNODC reporting on the training itself, and this is recorded as a gap rather than as an indication that no legislative activity is underway. It is also worth noting for cross-domain reference that the absence of a VASP AML statute compounds, rather than operates independently from, the beneficial-ownership opacity documented elsewhere in this brief: a virtual-asset operator structured through a Panamanian corporate vehicle with nominee shareholders would currently face neither a domestic VASP licensing requirement nor a publicly verifiable beneficial-ownership record, a compounding gap that obliged entities transacting with Panama-linked crypto counterparties should weigh cumulatively rather than assess each gap in isolation. This compounding condition is assessed at possible confidence given the absence of any documented instance this cycle in which it has been jointly exploited, though the structural conditions for such exploitation are independently well evidenced. The severity of this regulatory gap, considered independently of any specific scheme, is not assigned a preliminary rating in this brief, since no active scheme inventory entry specific to Panama-based virtual-asset laundering was identified this cycle; this itself is recorded as a gap rather than as reassurance of low risk. #### Outlook A prospective successor to the vetoed 2022 VASP legislation is recorded on the regulatory horizon with an expected date of 2027 and a multi-year uncertainty band, reflecting that no bill is currently tabled and that enactment remains a plausible but genuinely uncertain legislative outcome. Enactment of such legislation would bring Panama-based or Panama-accessed virtual-asset activity within the FATF Recommendation 15 supervisory perimeter for the first time since the 2022 veto, and would be the single most consequential development this domain could register in coming cycles. Absent that legislative step, the January 2026 UNODC and Canadian-backed training is best read as capacity-building in advance of a possible future legislative window rather than as a substitute for one. #### AML/CTF Regime This cycle's AML/CTF-regime signal is the same SBP Acuerdo No. 1-2026 already noted under the enabler-jurisdiction reading, here framed at the level of the regime as a whole. The Acuerdo extends the registration obligation under the base AML statute, Law 23 of 2015, to MICI-licensed empresas financieras, with six-month and nine-month compliance windows depending on whether the firm is already operating or newly licensed. The broader pattern this illustrates is incremental tightening: Panama's AML registration perimeter is being extended category by category to newer or previously peripheral financial-services types, rather than through a single comprehensive legislative overhaul of the regime. This is a probable-confidence reading, since the underlying instrument was captured through secondary press coverage rather than the SBP's own text. Continue reading Set against that incremental domestic tightening, Panama remains off the FATF grey list, having been removed in October 2023, with no plenary action affecting that status identified this cycle. The two facts sit together without contradiction but also without full resolution: an AML/CTF regime judged by FATF to warrant no increased monitoring is nonetheless the same jurisdiction whose flag registry is repeatedly responding to US sanctions designations after they are issued, as described under this cycle's sanctions signal. Whether the SBP's perimeter-tightening moves of this kind eventually extend to closing the gap between sanctions designation and registry response, or whether the two tracks - obligated-entity registration on one hand, flag-registry screening on the other - continue to develop independently of each other, is not resolved by the material available this cycle. #### Outlook The next marker for this domain is whether the SBP follows the empresas financieras registration move with comparable perimeter-tightening for other MICI-licensed or lightly-supervised financial categories, which would confirm the incremental-tightening pattern rather than a one-off measure. Illustrative scenario for analytical orientation only: a plausible continuation, if the pattern holds, would be a similar Acuerdo addressing another category of non-bank financial company later in the supervisory cycle - this is offered to orient attention only, not as an observed development. Not compliance advice, not a prediction, and not a statement of observed fact. Judgment: Panama's AML registration perimeter is being incrementally tightened around newer financial-services categories (empresas financieras) rather than through a single comprehensive overhaul; Panama remains off the FATF grey list. Probable Cumulative analysis D7 AML/CTF Regime Cumulative analysis · cross-cycle historical #### AML/CTF Regime Panama's AML/CTF architecture moved this cycle at the supervisory-rule level rather than through new primary legislation. The Superintendencia de Bancos de Panama issued Acuerdo No. 1-2026, dated 27 January 2026, which reinforces Banking Law Articles 112 to 114 obligations on banks and fiduciaries to document customer and beneficial-owner identification and to maintain transaction-monitoring capability, including frozen-asset procedures tied to United Nations Security Council lists. This text was retrieved directly from SBP's own publication, giving it Tier-1, Confirmed-tier support. The architecture-over-incident reading is that this is reinforcement of an existing statutory duty, sharpening documentary expectations rather than creating a new regulatory category or extending coverage to firms not already captured by the Banking Law. Panama's position relative to international list-based regimes is unchanged. The jurisdiction remains off the FATF grey list, a status confirmed directly against FATF's own list of jurisdictions under increased monitoring and unchanged since Panama's October 2023 delisting; the 19 June 2026 plenary roster of twenty-two listed jurisdictions does not include Panama. This is a Confirmed, Tier-1-sourced finding, cross-checked against the primary FATF source rather than inferred from secondary commentary. The three-pillar balance across AML, CTF and CPF findings is worth noting explicitly: this cycle's sourced material concentrates on the AML pillar (customer due diligence, beneficial-ownership identification, transaction monitoring), with the CTF dimension represented only through the UN Security Council freeze-list procedures referenced in Acuerdo 1-2026, and no CPF-specific signal with a Panama nexus identified. This is consistent with the general pattern in which AML generates more enforcement and rule-making volume than CTF or CPF, and the absence of CTF/CPF-specific movement this cycle should not be read as an assessment that those pillars are static in substance, only that no sourced finding addressing them specifically arose this cycle. The structural gap in Panama's broader financial-integrity perimeter — the absence of activity-based licensing for VASPs, PSPs and EMIs, addressed in the Crypto, Digital Assets, and Financial Innovation domain this cycle — bears on the AML/CTF regime insofar as those firms currently sit within general AML registration under Law 23/2015 rather than under a sector-calibrated supervisory structure comparable to the banking sector's. Acuerdo 1-2026 applies to banks and fiduciaries specifically; it does not extend to the VASP/PSP/EMI population, which remains the subject of the still-unenacted Draft Law 314. #### Outlook Panama's AML/CTF trajectory this cycle is one of incremental supervisory reinforcement within the existing Banking Law framework, not legislative expansion. Grey-list status is stable and, as scheduled, is not expected to shift absent a material change in FATF's own assessment process, which no source this cycle indicates is underway. The more consequential open question for Panama's broader financial-integrity architecture is whether Draft Law 314 is enacted, extending licensed supervision to the VASP/PSP/EMI population currently outside the banking-sector perimeter that Acuerdo 1-2026 reinforces. Cumulative analysis #### AML/CTF Regime Panama's AML/CTF architecture moved this cycle at the supervisory-rule level rather than through new primary legislation. The Superintendencia de Bancos de Panama issued Acuerdo No. 1-2026, dated 27 January 2026, which reinforces Banking Law Articles 112 to 114 obligations on banks and fiduciaries to document customer and beneficial-owner identification and to maintain transaction-monitoring capability, including frozen-asset procedures tied to United Nations Security Council lists. This text was retrieved directly from SBP's own publication, giving it Tier-1, Confirmed-tier support. The architecture-over-incident reading is that this is reinforcement of an existing statutory duty, sharpening documentary expectations rather than creating a new regulatory category or extending coverage to firms not already captured by the Banking Law. Panama's position relative to international list-based regimes is unchanged. The jurisdiction remains off the FATF grey list, a status confirmed directly against FATF's own list of jurisdictions under increased monitoring and unchanged since Panama's October 2023 delisting; the 19 June 2026 plenary roster of twenty-two listed jurisdictions does not include Panama. This is a Confirmed, Tier-1-sourced finding, cross-checked against the primary FATF source rather than inferred from secondary commentary. The three-pillar balance across AML, CTF and CPF findings is worth noting explicitly: this cycle's sourced material concentrates on the AML pillar (customer due diligence, beneficial-ownership identification, transaction monitoring), with the CTF dimension represented only through the UN Security Council freeze-list procedures referenced in Acuerdo 1-2026, and no CPF-specific signal with a Panama nexus identified. This is consistent with the general pattern in which AML generates more enforcement and rule-making volume than CTF or CPF, and the absence of CTF/CPF-specific movement this cycle should not be read as an assessment that those pillars are static in substance, only that no sourced finding addressing them specifically arose this cycle. The structural gap in Panama's broader financial-integrity perimeter — the absence of activity-based licensing for VASPs, PSPs and EMIs, addressed in the Crypto, Digital Assets, and Financial Innovation domain this cycle — bears on the AML/CTF regime insofar as those firms currently sit within general AML registration under Law 23/2015 rather than under a sector-calibrated supervisory structure comparable to the banking sector's. Acuerdo 1-2026 applies to banks and fiduciaries specifically; it does not extend to the VASP/PSP/EMI population, which remains the subject of the still-unenacted Draft Law 314. #### Outlook Panama's AML/CTF trajectory this cycle is one of incremental supervisory reinforcement within the existing Banking Law framework, not legislative expansion. Grey-list status is stable and, as scheduled, is not expected to shift absent a material change in FATF's own assessment process, which no source this cycle indicates is underway. The more consequential open question for Panama's broader financial-integrity architecture is whether Draft Law 314 is enacted, extending licensed supervision to the VASP/PSP/EMI population currently outside the banking-sector perimeter that Acuerdo 1-2026 reinforces. domain_sub_briefs · D7 · Cumulative analysis Standing baseline position Panama's AML/CFT regime rests on Ley 23/2015 (as amended) and Decreto Ejecutivo 35/2022, with SBP as supervisor and UAF as FIU. SBP Acuerdo No. 1-2026 (16 Jan 2026) repealed Acuerdo 10-2015 and tightened remote-onboarding due diligence, transaction-profile construction and risk-based UBO identification (10%+ holders) for banks and fiduciaries. Periodic updates (4) 3 Nov 2026 · fim-2026-11-03 #### AML/CTF Regime The operative development for Panama's AML/CTF regime is the Superintendencia de Bancos' Acuerdo de Prevencion para Otros Sujetos Obligados Financieros No. 1-2026, issued 20 October 2026, which establishes the registration process bringing MICI-licensed empresas financieras into the population of AML-obligated financial subjects under Law 23 of 2015. Existing firms are given six months to register from the accord's entry into force, and newly licensed firms nine months. Read at the regime level, this is a perimeter-extension measure rather than a rewrite of Panama's underlying AML framework. Law 23 of 2015 remains the core statute; the accord's function is to specify which categories of financial-sector actor must register as obligated subjects and on what timetable, closing a gap for a licensing category, empresas financieras under MICI, that sat outside SBP's AML-supervised population until now. This is consistent with how Panama has approached AML-regime development in recent cycles more broadly: incremental additions to the obligated-subject perimeter, triggered by specific gaps identified in particular financial-services categories, rather than a single comprehensive legislative overhaul of the AML/CTF framework as a whole. The three-pillar balance is worth noting explicitly here. This development falls squarely within the AML pillar; there is no material CTF (counter-terrorist-financing) or CPF (counter-proliferation-financing) content specific to this accord, and nothing in the material available indicates the accord was designed with a CTF or CPF rationale in mind, as distinct from the general AML-obligated-subject registration function it performs. This is a reasonable allocation for an accord of this type, but it means the CTF and CPF pillars of Panama's regime remain comparatively under-evidenced in the material, a pattern that recurs often enough in AML-architecture reporting generally to be worth naming rather than leaving implicit. On sourcing: the accord's own text, as published by SBP, was not directly retrieved, and the finding here rests on secondary press coverage from a Panamanian outlet. Confidence is accordingly held at the probable tier rather than confirmed, pending retrieval of the SBP's own gazette or circular text confirming the precise compliance windows, scope of covered entities, and any exemptions that the summary coverage may not capture in full. For registered financial companies and their supervisors, the structural significance is that Panama's AML-obligated-subject population continues to widen category by category, which has implications for how comprehensively AML/CTF obligations actually reach the full range of financial-services activity conducted in the jurisdiction at any given time, as opposed to how comprehensively the underlying statute appears to cover that activity on its face. #### Outlook The compliance windows set by the accord, six months for existing empresas financieras and nine months for newly licensed ones, mean that the mid-2027 period is when registration compliance under this specific measure will first become assessable. Separately, confirming the SBP's own published text of the accord remains an outstanding item that would move confidence in the precise obligation scope beyond the probable tier. Whether further obligated-subject categories are added in subsequent cycles, continuing the incremental pattern observed here, is the broader regime-level question to watch. Baseline-Tracked Domains with No Current-Cycle Escalation (1 of 8) - D8 Commercial Activity: Standing coverage — no activity this cycle. Regulatory horizon Proposed 2027 · ±multi_year ### Anteproyecto de Ley No. 314 — Ley Marco Integral de Tecnologías Financieras Would create dedicated licensing for VASPs, CASPs, PSPs and EMIs under joint SBP/UAF supervision, ending Panama's current reliance on general AML registration alone for virtual-asset businesses. [Asamblea Nacional de Panamá Source](https://www.superbancos.gob.pa/) Proposed 2027-Q1 · ±year ### Draft Law 314 (Ley Marco Integral de Tecnologías Financieras) VASP/PSP/EMI licensing Would create Panama's first dedicated licensing perimeter for virtual-asset service providers, payment-service providers and electronic-money issuers under joint SBP supervision, plus a formal regulatory sandbox. [Source](https://lexlatin.com/entrevistas/anteproyecto-ley-314-panama-regular-fintech-inversion) Proposed 2027-Q1 · ±multi_year ### Anteproyecto de Ley 314 (Ley Marco Integral de Tecnologías Financieras) Would introduce Panama's first dedicated VASP/CASP, PSP and EMI licensing and supervision architecture, a regulatory sandbox, and up to USD 2 million administrative fines. [Asamblea Nacional / SBP / UAF (prospective) Source](https://lexlatin.com/entrevistas/anteproyecto-ley-314-panama-regular-fintech-inversion) Proposed 2027-Q2 · ±year ### Anteproyecto de Ley N° 314 (Fintech Framework) Would introduce dedicated licensing categories for VASPs, PSPs and EMIs, aligned to FATF/OECD standards per its own Art. 1 stated objective. [Asamblea Nacional de Panamá Source](https://lexlatin.com/entrevistas/anteproyecto-ley-314-panama-regular-fintech-inversion) 4 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### SBP has extended AML registration duties to a new category of financial company, with firm compliance deadlines attached. MICI-licensed empresas financieras now fall within SBP's AML-obligated-subject net under Law 23 of 2015, with registration windows of six to nine months depending on licensing status. This changes the population of entities subject to registration-linked AML obligations in Panama. 1 evidence refs Compliance ### A new obligated-entity category has been created for MICI-licensed financial companies under SBP's October 2026 Acuerdo. The registration process and timelines are known through press coverage; the Acuerdo's own text, which would confirm precise scope, has not yet been retrieved. This represents a structural change to the obligated-entity perimeter rather than an isolated enforcement event. 1 evidence refs Legal ### OFAC designated Panama-resident and Panama/Greece-based parties for Iran shadow-fleet facilitation, effective 21 October 2026. The designation blocks property of the named parties under US sanctions authority. No parallel EU or UK listing of the same parties has been identified, continuing a divergence between the US sanctions programme and allied listing activity relevant to sanctions-nexus exposure assessments. 2 evidence refs Board ### Panama's flag registry continues to cancel vessel registrations only after US sanctions designations are issued. Seven vessel registrations were cancelled following October 2026 OFAC actions, continuing a reactive rather than pre-emptive pattern at the maritime registry. This is a structural exposure point for the jurisdiction's reputation as a flag state, set against Panama's continued absence from the FATF grey list. 2 evidence refs Risk ### An AML registration perimeter is closing around a previously lightly-supervised financial-company category while sanctions-designation risk persists in the maritime registry. The SBP's Acuerdo No. 1-2026 and the continued reactive vessel de-registration pattern represent two independent risk tracks within the same jurisdiction, developing on different timelines and under different regulators. 2 evidence refs Operations ### New registration deadlines apply to MICI-licensed empresas financieras under SBP's Acuerdo No. 1-2026. Operational screening and monitoring processes touching Panamanian empresas financieras counterparties may need to account for the new six-to-nine month registration windows once the Acuerdo's full scope is confirmed. 1 evidence refs Audit ### The underlying SBP Acuerdo text has not yet been independently retrieved, limiting verification of its precise scope. Current findings on the empresas financieras registration requirement rest on secondary Panamanian press coverage rather than the SBP's own publication, which is a documented evidentiary gap worth tracking for future verification. 1 evidence refs Scenario sketches ### Registry screening posture under continued designation pressure Illustrative only: should a further Iranian shadow-fleet-linked designation name additional Panama-flagged tonnage, the pattern observed this cycle suggests the Panama Maritime Authority would again move to cancel registrations only after the designation is issued, rather than in advance of it. A shift toward pre-designation screening, were it to occur, would most likely first appear as a public statement of enhanced ownership-screening procedure from the Authority rather than as a further batch of reactive cancellations. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change No material change found affecting PA specifically. T2 · EU AML Package / AMLA no_change PA is not an EEA/EU jurisdiction; AMLR/6AMLD/AMLA do not apply directly. T3 · FATF Grey List no_change Panama remains off the FATF grey list (removed October 2023); no plenary action this cycle found. T4 · Beneficial-Ownership Register Status no_change No change to Panama's RUBF beneficial-ownership register regime found this cycle. T5 · Crypto & Digital-Asset Integrity no_change No dedicated crypto/VASP licensing regime in force; no in-window material change found. T6 · Sanctions Regime Divergence watch Continuing US unilateral designations against Panama-flagged/resident parties with no parallel EU/UK listing found this cycle. Registers ### Enforcement actions - 27 Mar 2025 - 2 Dec 2024 - 23 Jan 2025 - 5 Jul 2024 - 1 Jun 2025 - 30 Jun 2026 - 6 Feb 2026 - 20 Oct 2026 - Panama Maritime Authority announced the cancellation of registration for vessels sanctioned by the US, its allies, or the UN, following a prior pledge to penalise blacklisted vessels; at least 70 tankers had already been removed by the announcement date. 27 Mar 2025 - Panama cancelled registration of six ships sailing under its flag after the UK blacklisted 30 vessels the prior week, carrying out what the Authority termed an 'expedited cancellation.' 2 Dec 2024 - Following OFAC's designation of 155 shadow-fleet tankers in January 2025 — the most extensive US action against the fleet to date — Panama's ship registry began de-listing 68 of the sanctioned vessels flying its flag. 23 Jan 2025 - Panama's courts concluded the high-profile Panama Papers money-laundering trial, with judge Baloisa Marquínez acquitting all 28 defendants over their alleged role in setting up shell companies used in Brazil- and Germany-linked bribery and corruption scandals, citing insufficient evidence and inadmissible electronic evidence. 5 Jul 2024 - GAFILAT issued a first enhanced follow-up report analysing Panama's progress addressing technical compliance deficiencies identified in its 2018 Mutual Evaluation Report, re-rating several FATF Recommendations while keeping Panama in the enhanced follow-up process. 1 Jun 2025 ### Sanctions changes - 23 Jan 2025 - 10 Jun 2025 - 26 Jun 2026 - 10 Feb 2026 - 21 Oct 2026 - OFAC designated 155 shadow-fleet tankers in January 2025, its most extensive single action against Russia's shadow fleet to date, including vessels flagged under Panama's registry, triggering Panama's de-flagging response. 23 Jan 2025 - The European Commission updated its delegated regulation listing high-risk third countries under AMLD IV, delisting Panama alongside Barbados, Gibraltar, Jamaica, the Philippines, Senegal, Uganda and the UAE, removing the requirement for EU obliged entities to apply enhanced due diligence specifically keyed to Panama's AML/CFT deficiencies. 10 Jun 2025 ### Regulatory horizon (register) - General Assembly skill-games licensing/tax framework unresolved - Anteproyecto de Ley No. 314 — Ley Marco Integral de Tecnologías Financieras - Draft Law 314 (Ley Marco Integral de Tecnologías Financieras) VASP/PSP/EMI licensing - Reglamento implementing Ley 527/2026 (gambling-sector AML/player-protection law) - Anteproyecto de Ley 314 (Ley Marco Integral de Tecnologías Financieras) - Draft Law No. 314 — Ley Marco Integral de Tecnologías Financieras - Anteproyecto de Ley N.314 (Ley Marco Integral de Tecnologías Financieras) - GAFILAT Fifth Round Mutual Evaluation of Panama - Anteproyecto de Ley N° 314 (Fintech Framework) - Panama's next FATF/GAFILAT Mutual Evaluation under 5th round methodology - Next GAFILAT enhanced follow-up report on Panama AML/CFT reforms - Prospective Panama VASP/crypto AML legislation - Zollinger Mossack Fonseca-linked trial in Cologne, Germany ### Active schemes - [HIGH] Panama flag-of-convenience reflagging for shadow-fleet tankers - [HIGH] Nominee-shareholder and private-foundation BO opacity - Colon Free Zone trade-based laundering / peso exchange - Hizballah revenue generation via Panama free-trade zones Sources - [Panama's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-panama-aug-2019.html) - [https://www.federalregister.gov/documents/2026/07/01/2026-13279/notice-of-ofac-sanctions-actions](https://www.federalregister.gov/documents/2026/07/01/2026-13279/notice-of-ofac-sanctions-actions) - [https://www.federalregister.gov/documents/2026/02/13/2026-02913/notice-of-ofac-sanctions-action](https://www.federalregister.gov/documents/2026/02/13/2026-02913/notice-of-ofac-sanctions-action) - [https://www.fatf-gafi.org/en/countries/detail/Panama.html](https://www.fatf-gafi.org/en/countries/detail/Panama.html) - [https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [https://www.superbancos.gob.pa/en/node/1652](https://www.superbancos.gob.pa/en/node/1652) - [https://www.superbancos.gob.pa/en/node/](https://www.superbancos.gob.pa/en/node/) - [https://fmm.com.pa/beneficial-owner-registry-in-the-republic-of-panama/](https://fmm.com.pa/beneficial-owner-registry-in-the-republic-of-panama/) - [https://globalfishingwatch.org/success-story/panama-publishes-ultimate-beneficial-ownership-data-for-its-international-fishing-fleet/](https://globalfishingwatch.org/success-story/panama-publishes-ultimate-beneficial-ownership-data-for-its-international-fishing-fleet/) - [https://www.superbancos.gob.pa/documentos/regulacion/acuerdos_otros_sujetos/2026/Acuerdo_01-2026.pdf](https://www.superbancos.gob.pa/documentos/regulacion/acuerdos_otros_sujetos/2026/Acuerdo_01-2026.pdf) - [https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [https://lexlatin.com/entrevistas/anteproyecto-ley-314-panama-regular-fintech-inversion](https://lexlatin.com/entrevistas/anteproyecto-ley-314-panama-regular-fintech-inversion) - [https://www.mef.gob.pa/wp-content/uploads/2020/10/Ley-23-de-27-de-abril-de-2015.pdf](https://www.mef.gob.pa/wp-content/uploads/2020/10/Ley-23-de-27-de-abril-de-2015.pdf) - [https://www.mondaq.com/income-tax/1844388/reglamento-de-sustancia-econ%C3%B3mica-decreto-ejecutivo-no-32](https://www.mondaq.com/income-tax/1844388/reglamento-de-sustancia-econ%C3%B3mica-decreto-ejecutivo-no-32) - [https://globallawexperts.com/panama-fintech-law-2026-draft-law-no-314-sbp-rule-1-2026-licensing-aml-and-bank-access/](https://globallawexperts.com/panama-fintech-law-2026-draft-law-no-314-sbp-rule-1-2026-licensing-aml-and-bank-access/) - [https://www.laestrella.com.pa/economia/la-sbp-refuerza-la-seguridad-bancaria-y-concede-prorroga-a-regulacion-de-creditos-CA26401267](https://www.laestrella.com.pa/economia/la-sbp-refuerza-la-seguridad-bancaria-y-concede-prorroga-a-regulacion-de-creditos-CA26401267) - [https://www.state.gov/reports/2026-investment-climate-statements/panama](https://www.state.gov/reports/2026-investment-climate-statements/panama) - [https://globallawexperts.com/sbp-rule-12026-panama/](https://globallawexperts.com/sbp-rule-12026-panama/) - [https://www.infobae.com/panama/2026/08/19/panama-endurece-sanciones-para-los-bancos-que-no-cumplan-con-las-normas-de-prevencion-de-blanqueo-de-capitales/](https://www.infobae.com/panama/2026/08/19/panama-endurece-sanciones-para-los-bancos-que-no-cumplan-con-las-normas-de-prevencion-de-blanqueo-de-capitales/) - [https://www.infobae.com/panama/2026/06/30/un-ciberataque-golpea-a-la-uaf-la-entidad-que-rastrea-operaciones-sospechosas-en-panama/](https://www.infobae.com/panama/2026/06/30/un-ciberataque-golpea-a-la-uaf-la-entidad-que-rastrea-operaciones-sospechosas-en-panama/) - [https://nexo.la/uaf-incidente-seguridad-antilavado-2026/](https://nexo.la/uaf-incidente-seguridad-antilavado-2026/) - [https://sbcnoticias.com/panama-apuestas-uaf-2026-reporte/](https://sbcnoticias.com/panama-apuestas-uaf-2026-reporte/) - [https://kpmg.com/us/en/taxnewsflash/news/2026/06/panama-economic-substance-passive-income.html](https://kpmg.com/us/en/taxnewsflash/news/2026/06/panama-economic-substance-passive-income.html) - [Infobae Panamá](https://www.infobae.com/panama/2026/10/24/alertas-por-operaciones-sospechosas-aumentan-en-bancos-e-inmobiliarias-en-panama/) - [compliance.com.co](https://www.compliance.com.co/risks-international-evaluacion-mutua-gafilat-colombia-2029/) - [Infobae Panamá](https://www.infobae.com/panama/2026/08/13/panama-se-alista-para-la-quinta-ronda-del-gafi-con-el-reto-de-probar-resultados-contra-el-blanqueo/) - [Regxplora](https://platform.intelligence.regxelerator.com/updates/0918d1558e8bad0b3c8806e83e94d6b742d2c2af17bfe0728f142dda38c0f43d/superintendencia-de-bancos-de-panama-superintendency-of-banks-of-panama-reviews-banking-resilien) - [La Estrella de Panamá](https://www.laestrella.com.pa/panama/nacional/que-paso-hoy-en-panama-estas-son-las-noticias-destacadas-del-20-de-octubre-HF26671237) - [Ministerio de Economía y Finanzas de Panamá (MEF)](https://www.mef.gob.pa/2026/07/panama-fortalece-la-agenda-regional-contra-el-blanqueo-de-capitales/) - [Metro Libre](https://www.metrolibre.com/economia/nuevo-acuerdo-regula-registro-de-empresas-financieras-ante-la-sbp-IL26965058) - [OFAC / Federal Register (via Daily Federal)](https://www.dailyfederal.com/article/ofac-adds-panama-linked-individuals-firms-and-vessels-to-sdn-list-1242) - [SAFETY4SEA](https://safety4sea.com/panama-moves-to-deregister-seven-ofac-sanctioned-ships/) - [KnowYourCountry](https://www.knowyourcountry.com/panama) - [LexLatin](https://lexlatin.com/entrevistas/anteproyecto-ley-314-panama-regular-fintech-inversion) - [Panama](https://www.fatf-gafi.org/en/countries/detail/Panama.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [Countries / Jurisdictions](http://www.fatf-gafi.org/countries/#Panama) - [Jurisdictions under Increased Monitoring - 19 June 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [High-Risk Jurisdictions subject to a Call for Action - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-february-2026.html) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [Jurisdictions under Increased Monitoring - 27 October 2023](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Increased-monitoring-october-2023.html) - [FATF changes its grey listing criteria to further focus on risk](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-grey-listing-criteria.html) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [The Panama Papers: Exposing the Rogue Offshore Finance Industry - ICIJ](https://www.icij.org/investigations/panama-papers/) - [1 United States Department of the Treasury Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/advisory/advis23.pdf) - [Panama's measures to combat money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-panama-2018.html) - [Panama's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-panama-aug-2019.html) - [2026_30enero_panama_activos_virtuales](https://www.unodc.org/ropan/en/Noticias/2026_30enero_panama_activos_virtuales.html) - [Narco-a-lago: Money Laundering at the Trump Ocean Club, Panama | Global Witness](https://www.globalwitness.org/en/campaigns/corruption-and-money-laundering/narco-a-lago-panama/) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [FinCEN Advisory - Issue 23 | FinCEN.gov](https://www.fincen.gov/resources/advisories/fincen-advisory-issue-23) - [Businesses that have not complied with the money laundering regulations (2025 to 2026) - GOV.UK](https://www.gov.uk/government/publications/businesses-not-complying-with-money-laundering-regulations-in-2018-to-2019/businesses-that-have-not-complied-with-the-money-laundering-regulations-2025-to-2026) - [Russia's war of aggression against Ukraine: Council sanctions 41 vessels of the Russian shadow fleet - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/18/russia-s-war-of-aggression-against-ukraine-council-sanctions-41-vessels-of-the-russian-shadow-fleet/) - [EU sanctions against Russia: questions and answers - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia-explained/) - [Russian Oil Ships Hunt for New Flags to Hide From Sanctions - Bloomberg](https://www.bloomberg.com/news/articles/2025-01-23/russian-oil-ships-hunt-for-new-flags-to-hide-from-sanctions) - [Dark Fleet: Panama Registry Set to Remove 128 Ships As US Tightens Sanctions - Bloomberg](https://www.bloomberg.com/news/articles/2025-03-27/dark-fleet-panama-registry-set-to-remove-128-ships-as-us-tightens-sanctions) - [European Ships Keep Russia’s Shadow Fleet Afloat | OCCRP](https://www.occrp.org/en/investigation/european-ships-keep-russias-shadow-fleet-afloat) - [EU adopts 20th package of sanctions against Russia - Finance](https://finance.ec.europa.eu/news/eu-adopts-20th-package-sanctions-against-russia-2026-04-23_en) - [SANCTIONS ADVISORY - Guidance for Shipping and ...](https://ofac.treasury.gov/media/934236/download?inline=) - [Russia's war of aggression against Ukraine: Council sanctions 9 shadow fleet enablers - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2025/12/15/russia-s-war-of-aggression-against-ukraine-council-sanctions-9-shadow-fleet-enablers/) - [Timeline - EU sanctions against Russia - Consilium](https://www.consilium.europa.eu/en/policies/sanctions-against-russia/timeline-sanctions-against-russia/) - [UK clamps down on shady networks supplying Putin’s illegal war with new sanctions package - GOV.UK](https://www.gov.uk/government/news/uk-clamps-down-on-shady-networks-supplying-putins-illegal-war-with-new-sanctions-package) - [Cyprus, Ghana and Kenya join growing list of countries to create beneficial ownership registries - ICIJ](https://www.icij.org/investigations/panama-papers/cyprus-ghana-and-kenya-join-growing-list-of-countries-to-create-beneficial-ownership-registries/) - [U.S. Launches a Beneficial Ownership Registry | OCCRP](https://www.occrp.org/en/news/us-launches-a-beneficial-ownership-registry) - [Panama Papers: US to Force Banks to Identify Shell Company Owners | OCCRP](https://www.occrp.org/en/news/panama-papers-us-to-force-banks-to-identify-shell-company-owners) - [U.S. Beneficial Ownership Information Registry Now Accepting Reports | FinCEN.gov](https://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports) - [Directory of Open-Source Registries: Panama](https://globenetwork.unodc.org/globenetwork/en/directory-of-open-source-registries/panama.html) - [Guidance on Beneficial Ownership of Legal Persons](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html) - [Frequently Asked Questions | OCCRP](https://www.occrp.org/en/openlux/frequently-asked-questions) - [Treasury Department won’t enforce beneficial ownership rule under the Corporate Transparency Act - ICIJ](https://www.icij.org/inside-icij/2025/03/treasury-department-wont-enforce-beneficial-ownership-rule-under-the-corporate-transparency-act/) - [Catalogue of Research Databases | OCCRP ID](https://id.occrp.org/databases/) - [Beneficial Ownership Data is Critical in the Fight Against Corruption | OCCRP](https://www.occrp.org/en/project/beneficial-ownership-data-is-critical-in-the-fight-against-corruption) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/fur/GAFILAT-Spanish-1st-FUR-Panama.pdf) - [PREVENCIÓN DEL LAVADO DE DINERO Una Guía para Empresas de Servicios Monetarios](https://www.fincen.gov/system/files/shared/mlp_spa_prevention_guide.pdf) - [Reglamento de la Ley Contra el Lavado de Dinero u Otros ...](https://www.unodc.org/documents/archive/imolin/Guatrlcd.pdf) - [1 La Red de Control de Delitos Financieros (FinCEN) del](https://www.fincen.gov/system/files/2026-01/FinCEN-Advisory-CMLN-Spanish.pdf) - [Redes chinas de lavado de dinero (CMLN)](https://www.fincen.gov/system/files/2026-01/FinCEN-FTA-CMLN-Spanish.pdf) - [Anexo Para facilitar el suministro de información sobre la ...](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup2/2022-November-7-11/Panama_Responses_to_Questionnaire_on_BOT_Regimes_SP.pdf) - [LEY GENERAL DE BANCOS CAPÍTULO O TÍTULO](https://www.unodc.org/documents/archive/imolin/Vzleydb.pdf) - [El Departamento del Tesoro emite históricas órdenes bajo una nueva y poderosa facultad para combatir el fentanilo | FinCEN.gov](https://www.fincen.gov/news/news-releases/el-departamento-del-tesoro-emite-historicas-ordenes-bajo-una-nueva-y-poderosa) - [La República Bolivariana de Venezuela](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/CFATF-FUR-Sp-Venezuela-2025.pdf.coredownload.inline.pdf) - [Reglamento de la Ley contra el Lavado de Dinero y de Activos](https://www.unodc.org/cld/en/document/slv/2000/reglamento_de_la_ley_contra_el_lavado_de_dinero_y_de_activos.html) - [Panama Country Guide | Elliptic](https://www.elliptic.co/country-guides/panama) - [2025_24enero_Panama_LavadoDeActivos](https://www.unodc.org/ropan/en/Noticias/2025_24enero_panama_lavadodeactivos.html) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [From trading bans to total embrace, a global guide to crypto regulation](https://www.icij.org/investigations/coin-laundry/cryptocurrency-regulations-global-explainer/) - [2025 LATAM Crypto Adoption: Latin America Emerges as Crypto Powerhouse](https://www.chainalysis.com/blog/latin-america-crypto-adoption-2025/) - [Panama President Laurentino Cortiz Won't Sign Crypto Law in Current Form - Bloomberg](https://www.bloomberg.com/news/articles/2022-05-19/panama-president-will-refuse-to-sign-crypto-law-in-current-form) - [Targeted Update on Implementation of the FATF Standards on Virtual Assets and](https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/2025-Targeted-Upate-VA-VASPs.pdf.coredownload.pdf) - [FATF urges stronger global action to address Illicit Finance Risks in Virtual Assets](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2025.html) - [Counter Narcotics Trafficking Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/counter-narcotics-trafficking-sanctions) - [OFAC Sanctions Fentanyl Trafficking and Crypto Laundering Network](https://www.chainalysis.com/blog/sinaloa-cartel-fentanyl-trafficking-crypto-laundering-may-2026/) - [Counter Narcotics and Counter Terrorism Designations and Designation Updates; Cyber-related Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250814) - [OFAC Sanctions Tracker: How Sanctions Impact Crypto Crime - Chainalysis](https://www.chainalysis.com/blog/ofac-sanctions/) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [2026 Crypto Crime Report – Illicit Crypto Trends & Typologies | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/2026-crypto-crime-report) - [Home | Office of Foreign Assets Control](https://ofac.treasury.gov/) - [Blog - Chainalysis](https://www.chainalysis.com/blog/) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Financial Action Task Force of Latin America (GAFILAT)](https://www.fatf-gafi.org/en/countries/global-network/financial-action-task-force-of-latin-america--gafilat-.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Outcomes FATF Plenary, 22-24 October 2025](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-october-2025.html) - [FIRST ENHANCED FOLLOW-UP REPORT OF PANAMA](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GAFILAT-1st-FUR-Panama.pdf.coredownload.inline.pdf) - [Panama's measures to combat money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-panama-2018.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Panama Papers trial concludes with all defendants acquitted of money laundering - ICIJ](https://www.icij.org/investigations/panama-papers/panama-papers-trial-concludes-with-all-defendants-absolved-of-money-laundering-charge/) - [Panama’s new president labels Panama Papers a ‘hoax’ as experts voice concerns about money laundering acquittals - ICIJ](https://www.icij.org/inside-icij/2024/07/panamas-new-president-labels-panama-papers-a-hoax-as-experts-voice-concerns-about-money-laundering-acquittals/) - [Panama Papers trial begins with denials eight years after historic tax evasion exposé - ICIJ](https://www.icij.org/investigations/panama-papers/panama-papers-trial-begins-with-denials-eight-years-after-historic-tax-evasion-expose/) - [Mass prosecution forces Mossack Fonseca back into the spotlight in Panama - ICIJ](https://www.icij.org/investigations/panama-papers/mass-prosecution-forces-mossack-fonseca-back-into-the-spotlight-in-panama/) - [Tax evasion & ICIJ reporting: governments recoup millions](https://www.icij.org/investigations/panama-papers/hundreds-of-millions-more-dollars-recouped-by-governments-after-icij-investigations/) - [Panama Papers: Former Pakistan PM Sharif Sentenced To 10 Years - ICIJ](https://www.icij.org/investigations/panama-papers/former-pakistan-pm-sharif-sentenced-to-10-years-over-panama-papers/) - [Swiss lawyer from Panama Papers firm to face court on tax evasion charges - ICIJ](https://www.icij.org/investigations/panama-papers/swiss-lawyer-from-panama-papers-firm-to-face-court-on-tax-evasion-charges/) - [Inside the Fall of Mossack Fonseca - The Panama Papers](https://www.occrp.org/en/panamapapers/inside-the-fall-of-mossack-fonseca) - [Mossack Fonseca Archives - ICIJ](https://www.icij.org/tags/mossack-fonseca/) - [Panama Bars Six Ships From Flying Its Flag After UK Sanctions](https://www.bloomberg.com/news/articles/2024-12-02/ships-sanctioned-for-hauling-russian-oil-can-t-use-panama-s-flag) - [2024 UAFE de Ecuador y UIF de Peru unen fuerzas en la lucha contra delitos ambientales a traves de la colaboracion regional en inteligencia financiera](https://www.unodc.org/peruandecuador/es/noticias/2021/2024-uafe-de-ecuador-y-uif-de-peru-unen-fuerzas-en-la-lucha-contra-delitos-ambientales-a-traves-de-la-colaboracion-regional-en-inteligencia-financiera.html) - [Naciones Unidas le apunta a fortalecer la capacidad de las Unidades de Inteligencia Financiera (UIF) en su lucha contra el lavado de activos](https://www.unodc.org/colombia/es/comunicados/com3809.html) - [Panama's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/fur-panama-aug-2019.html) - [UAFE de Ecuador y UIF de Perú unen fuerzas en la lucha contra delitos ambientales a través de la colaboración regional en inteligencia financiera](https://www.unodc.org/rocol/es/noticias/peru/uafe-de-ecuador-y-uif-de-per-unen-fuerzas-en-la-lucha-contra-delitos-ambientales-a-travs-de-la-colaboracin-regional-en-inteligencia-financiera.html) - [Panama - Financial Action Task Force (FATF)](https://www.fatf-gafi.org/countries/n-r/panama/) - [Panama](https://data.un.org/en/iso/pa.html) - [94 Unidades de Inteligencia Financiera (UIFs) se reúnen en Cartagena](https://www.unodc.org/colombia/es/comunicados10/com36_jun22.html) - [capacitacionuafchile](https://www.unodc.org/colombia/es/press/capacitacionuafchile.html) - [Money Laundering vulnerabilities of Free Trade Zones](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/ML%20vulnerabilities%20of%20Free%20Trade%20Zones.pdf) - [1 FinCEN Advisory United States Department of the Treasury](https://www.fincen.gov/system/files/advisory/advisu9.pdf) - [Subregional Meeting on Trade-based Money Laundering](https://www.unodc.org/ropan/en/subregional-meeting-on-trade-based-money-laundering.html) - [United States Department of the Treasury Financial Crimes Enforcement Network](https://www.fincen.gov/system/files/advisory/advis23a.pdf) - [FinCEN Advisory](https://www.fincen.gov/sites/default/files/advisory/advis23.pdf) - [Advisory Withdrawal - Issue 23A | FinCEN.gov](https://www.fincen.gov/resources/advisories/advisory-withdrawal-issue-23a) - [Exporting from the UK to Panama | business.gov.uk](https://www.great.gov.uk/markets/panama/) - [FinCEN Alert Hizballah Alert](https://www.fincen.gov/system/files/shared/FinCEN-Alert-Hizballah-Alert-508C.pdf) - [FINANCIAL ACTION TASK FORCE ON MONEY LAUNDERING FATF | FinCEN.gov](https://www.fincen.gov/financial-action-task-force-money-laundering-fatf) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Panama.html) - [FATF/GAFILAT](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-panama-2018.html) - [GAFILAT](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/GAFILAT-1st-FUR-Panama.pdf.coredownload.inline.pdf) - [European Commission](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [FinCEN, US Department of the Treasury](https://www.fincen.gov/system/files/shared/FinCEN-Alert-Hizballah-Alert-508C.pdf) - [FinCEN, US Department of the Treasury](https://www.fincen.gov/resources/advisories/advisory-withdrawal-issue-23a) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-03-27/dark-fleet-panama-registry-set-to-remove-128-ships-as-us-tightens-sanctions) - [Bloomberg](https://www.bloomberg.com/news/articles/2024-12-02/ships-sanctioned-for-hauling-russian-oil-can-t-use-panama-s-flag) - [Bloomberg](https://www.bloomberg.com/news/articles/2025-01-23/russian-oil-ships-hunt-for-new-flags-to-hide-from-sanctions) - [OCCRP](https://www.occrp.org/en/investigation/european-ships-keep-russias-shadow-fleet-afloat) - [ICIJ](https://www.icij.org/investigations/panama-papers/panama-papers-trial-concludes-with-all-defendants-absolved-of-money-laundering-charge/) - [ICIJ](https://www.icij.org/inside-icij/2024/07/panamas-new-president-labels-panama-papers-a-hoax-as-experts-voice-concerns-about-money-laundering-acquittals/) - [Global Witness](https://www.globalwitness.org/en/campaigns/corruption-and-money-laundering/narco-a-lago-panama/) - [UNODC](https://www.unodc.org/ropan/en/Noticias/2026_30enero_panama_activos_virtuales.html) - [ICIJ](https://www.icij.org/investigations/panama-papers/swiss-lawyer-from-panama-papers-firm-to-face-court-on-tax-evasion-charges/) Coverage gaps fim-int-2026-07-07-G001: No direct retrieval of Panama's own… fim-int-2026-07-07-G001: No direct retrieval of Panama's own National Risk Assessment document; NRA status is inferred from FATF/GAFILAT secondary reporting rather than a primary Panamanian government publication. [resolved] fim-int-2026-07-07-G002: No independent verification via a p… fim-int-2026-07-07-G002: No independent verification via a primary Panamanian corporate or Superintendencia registry source of the specific nominee-shareholder BO opacity mechanics described by Global Witness and ICIJ. [resolved] fim-int-2026-07-07-G003: No confirmed legislative-tracking s… fim-int-2026-07-07-G003: No confirmed legislative-tracking status for a successor VASP/crypto bill beyond UNODC capacity-building reporting; Panama's own legislative record was not retrieved this cycle. [resolved] fim-int-2026-07-07-G004: Outcome of the Zollinger trial (sch… fim-int-2026-07-07-G004: Outcome of the Zollinger trial (scheduled March 2026) is not yet available to assess whether German cross-border prosecution succeeds where Panama's domestic prosecution failed. [resolved] fim-int-2026-07-07-G005: Colon Free Zone-specific enforcemen… fim-int-2026-07-07-G005: Colon Free Zone-specific enforcement statistics (SAR filings, customs seizures) for the current window were not retrieved beyond FATF/FinCEN typology-level description. [resolved] fim-int-2026-08-05-G001: Tier D jurisdiction checks (KH, LA,… fim-int-2026-08-05-G001: Tier D jurisdiction checks (KH, LA, MX, CO) were not actively searched within the PA-scoped pooled search budget this cycle. [resolved] fim-int-2026-08-05-G002: No PA-nexus conflict-finance/extrac… fim-int-2026-08-05-G002: No PA-nexus conflict-finance/extractive-industry material surfaced or was searched with dedicated queries this cycle. [resolved] fim-int-2026-08-05-G003: The Deibler Brothers felony-convict… fim-int-2026-08-05-G003: The Deibler Brothers felony-conviction claim lacks independent second-source corroboration beyond the PA OAG press release. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): No dedicated D3 (enabler jurisdictions) professional-facilitator finding beyond the BO-registry structural facts was located this cycle. [resolved] fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G002 ({'scheme': 'financial_integrity', 'value': 'D4'}): No independent D4 (conflict finance) PA-specific finding beyond the Hizballah-flagged-vessel cross-reference was located this cycle. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D5'}): Current legislative status/committee stage of Draft Law No. 314 was not independently confirmed against the Asamblea Nacional's own legislative tracker. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No Tier-1 primary legislative text of Draft Law 314 was retrieved this cycle; current support is Tier-3 legal-commentary only. [resolved] fim-int-2026-10-04-G002: D2 (beneficial ownership), D3 (enab… fim-int-2026-10-04-G002: D2 (beneficial ownership), D3 (enabler jurisdictions), D4 (conflict finance) and D6 (compliance technology) had no sourced coverage this cycle for Panama. [resolved] fim-int-2026-10-04-G003: Tier-D watch jurisdictions (Cambodi… fim-int-2026-10-04-G003: Tier-D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) were not researched on this Panama-bound dispatch; that coverage belongs to the monitor's broader cross-jurisdiction cadence. [resolved] fim-int-2026-10-11-G001: Tier D jurisdictions (KH, LA, MX, C… fim-int-2026-10-11-G001: Tier D jurisdictions (KH, LA, MX, CO) were not independently swept this cycle; pooled search budget concentrated on Panama. [resolved] fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): Asamblea Nacional floor record of Anteproyecto 314's committee status as of October 2026 was not located; current status relies on T3 commentary from April 2026. [resolved] fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-11-G003 ({'scheme': 'financial_integrity', 'value': 'D8'}): No qualifying D8 commercial-activity event was located; this reflects absence of findings in a pooled search budget rather than confirmed non-occurrence. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D7'}): No UAF primary technical post-mortem or restoration-date statement on the June 2026 cyberattack was located this cycle. [resolved] fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): Panama-specific sanctions-changes (D1) and conflict-finance findings (D4) were not located this cycle; D1 is recorded as no_source and D4 as not_applicable_in_regime. [resolved] fim-int-2026-10-18-G003: Tier-D jurisdiction-watch (KH/LA/MX… fim-int-2026-10-18-G003: Tier-D jurisdiction-watch (KH/LA/MX/CO) was not actively searched this cycle due to pooled-budget constraints shared across the five union consumers. [resolved] fim-int-2026-10-25-G001: No direct UAF primary-bulletin URL … fim-int-2026-10-25-G001: No direct UAF primary-bulletin URL was located to corroborate the sectoral STR trend figures attributed to the UAF. [resolved] fim-int-2026-10-25-G002: No official JCJ reglamento implemen… fim-int-2026-10-25-G002: No official JCJ reglamento implementing Law 527 secondary controls was located this cycle (shared with advennt's registration perimeter work, relevant to D5 crypto-adjacent oversight context). [resolved] fim-int-2026-10-25-G003: Codere América v. Panama ICSID arbi… fim-int-2026-10-25-G003: Codere América v. Panama ICSID arbitration over JCJ's tolerance of allegedly illegal slot halls had no new procedural step located this cycle. [resolved] fim-int-2026-10-25-G004: D1, D3, D4, D6 and D8 domains had n… fim-int-2026-10-25-G004: D1, D3, D4, D6 and D8 domains had no Panama-specific material located this cycle; Tier-D watch jurisdiction channels were not separately re-swept. [resolved] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D3'}): SBP's own publication of Acuerdo No. 1-2026's full text was not retrieved this pass; only secondary Panamanian press coverage available. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): No D2 (Beneficial Ownership), D4 (Conflict Finance), D5 (Crypto) or D6 (Compliance Technology) PA-specific material was found this cycle. [open] fim-int-2026-11-01-G003: T1 Russian Sanctions-Evasion Archit… fim-int-2026-11-01-G003: T1 Russian Sanctions-Evasion Architecture — PA-specific material not applicable this regime this cycle. [open] FIM-GAP-001 (D2): The 2024 acquittal of all 28 Panama Papers… FIM-GAP-001 (D2): The 2024 acquittal of all 28 Panama Papers defendants, including Mossack Fonseca's founders, on money-laundering charges — with the presiding court dismissing key electronic evidence on chain-of-custody grounds — demonstrates persistent weakness in Panama's capacity to secure domestic convictions against professional enablers of offshore shell-company networks. FIM-GAP-002 (D2): Panama's beneficial-ownership registry (La… FIM-GAP-002 (D2): Panama's beneficial-ownership registry (Law 129/2020) is held privately by supervisory authorities rather than made publicly accessible, restricting the ability of banks, foreign law enforcement, and investigative journalists to independently verify nominee-shareholder and private-foundation ownership structures. FIM-GAP-003 (D5): Panama has no comprehensive VASP/crypto AM… FIM-GAP-003 (D5): Panama has no comprehensive VASP/crypto AML statute in force after President Cortizo vetoed the 2022 crypto bill for lacking adequate anti-money-laundering controls; capacity-building continues via UNODC training but no replacement legislation has been enacted. FIM-GAP-004 (D1): Despite an active de-flagging campaign aga… FIM-GAP-004 (D1): Despite an active de-flagging campaign against already-sanctioned vessels, Panama's registry continues to receive newly-reflagged shadow-fleet tankers exiting other flags before they are individually designated, reflecting a structural lag between vessel-level sanctions designation and registry-level screening. FIM-GAP-005 (D3): Colon Free Zone administration and Panaman… FIM-GAP-005 (D3): Colon Free Zone administration and Panamanian Customs systems remain incompletely integrated for electronic transaction tracking, sustaining the trade-based money-laundering vulnerability long identified by FATF and FinCEN typology reporting on the zone. ## Evidence #### Confidence-tiered claims Acuerdo No. 1-2026 reinforces Banking Law Arts. 112-114 CDD/beneficial-owner identification and UN Security Council freeze-list procedures for banks and fiduciaries [[Source 1]](#sec-sources) Probable · 1 source Remains off the FATF grey list; not among the 22 jurisdictions on the 19 June 2026 plenary roster [[Source 1]](#sec-sources) Probable · 1 source Draft Law 314 would create dedicated VASP/PSP/EMI licensing under joint SBP oversight, closing the current AML-registration-only gap under Law 23/2015 [[Source 1]](#sec-sources) Probable · 1 source No enacted sector-specific VASP/PSP/EMI licensing regime; firms rely on general AML registration under Law 23/2015 [[Source 1]](#sec-sources) Probable · 1 source stable Probable Acuerdo No. 1-2026 (16 Jan 2026), repealing Acuerdo 10-2015, tightening KYC/UBO/remote-onboarding due diligence for banks and fiduciaries [[Source 1]](#sec-sources) Probable · 1 source Acuerdo No. 8-2026 (signed 22 Sep 2026) imposes new electronic-funds-transfer supervision/validation scheme; Acuerdo No. 9-2026 defers Acuerdo 6-2026's credit-adequation deadline to 31 March 2027 [[Source 1]](#sec-sources) Probable · 1 source Ley 526/2026 (28 May 2026), regulated by Decreto Ejecutivo 32/2026 (2 Sep 2026), requires multinational-group entities with foreign-source passive income to demonstrate local substance or face a flat 15% tax plus penalties [[Source 1]](#sec-sources) Probable · 1 source remains in Asamblea Nacional committee review; no enactment or plenary-debate movement found dated in this cycle's window [[Source 1]](#sec-sources) Uncertain · 1 source Ley 23/2015 (as amended), Decreto Ejecutivo 35/2022; SBP supervisor, UAF FIU; off FATF grey list since Oct 2023, off EU high-risk list since 2025 [[Source 1]](#sec-sources) Probable · 1 source off FATF 'Jurisdictions under Increased Monitoring' list since October 2023 [[Source 1]](#sec-sources) Probable · 1 source UAF detected an information-security incident and temporarily suspended its technology platforms and services, disrupting suspicious-transaction-report intake from roughly 16,727 obligated subjects with no stated restoration date. [[Source 1]](#sec-sources) Probable · 1 source UAF H1 2026 statistics recorded 839 STRs; gambling-related reports led the non-financial-sector category with an increase of 58%, followed by lawyers, real estate and car sales. [[Source 1]](#sec-sources) Probable · 1 source SBP approved a new norm setting clearer criteria for sanctioning banks that fail to comply with AML/CFT/CPF rules, alongside continued growth in the International Banking Centre's deposit base ($121.866bn, +7.69% YoY). [[Source 1]](#sec-sources) Probable · 1 source Entities in multinational groups earning foreign-source passive income (dividends, interest, royalties, capital gains, real estate income) must demonstrate genuine economic substance in Panama or face a 15% flat tax on net taxable passive income from FY2027; SBP/securities/insurance-supervised financial entities and merchant marine are excluded. [[Source 1]](#sec-sources) Probable · 1 source FATF removed Panama from its grey list in October 2023 and the EU removed it from its AML/CFT high-risk list in July 2025, but the EU separately retains Panama on its non-cooperative tax-jurisdictions list for tax-transparency reasons — a distinct designation from the AML high-risk list. [[Source 1]](#sec-sources) Probable · 1 source Panama's dedicated VASP/PSP/EMI licensing bill, filed 13 January 2026, remains unenacted as of this cycle, leaving AML registration under Law 23/2015 as the only binding compliance layer for crypto firms. [[Source 1]](#sec-sources) Probable · 1 source Bank STRs up 11% YoY (1,117 to 1,237); real-estate STRs up 350% (2 to 9); national total down 9% (1,603 to 1,462), Jan-Sep 2026 [[Source 1]](#sec-sources) Probable · 1 source Panama's Fifth Round mutual evaluation scheduled for May 2028, under an effectiveness-weighted methodology; Panama holds 2026 Pro-Tempore Presidency [[Source 1]](#sec-sources) Probable · 1 source Confirmed provisional detention of 11 individuals and house arrest for 2 more under 'Operación Poseidón' organised-crime/money-laundering case [[Source 1]](#sec-sources) Probable · 1 source Fintech/VASP framework draft law and three virtual-asset bills remain without a first-debate date; SMV non-general opinions keep certain non-custodial token schemes outside licensing perimeter [[Source 1]](#sec-sources) Probable · 1 source Panama and Nicaragua scheduled after Costa Rica (Nov 2026), Honduras (May 2027), Guatemala (Nov 2027) [[Source 1]](#sec-sources) Probable · 1 source True [[Source 1]](#sec-sources) Probable · 1 source True [[Source 1]](#sec-sources) Probable · 1 source Acuerdo de Prevencion para Otros Sujetos Obligados Financieros No. 1-2026 (20 Oct 2026) requiring MICI-licensed empresas financieras to register with SBP as AML-obligated financial subjects under Law 23/2015 [[Source 1]](#sec-sources) Probable · 1 source Panama-City-resident individual and a Panama/Greece-based maritime manager for Iran petroleum shadow-fleet facilitation, effective 21 Oct 2026 [[Source 1]](#sec-sources) Probable · 1 source Seven Panama-flagged vessels caught up in October 2026 OFAC sanctions actions had registrations cancelled, reported into this window [[Source 1]](#sec-sources) Probable · 1 source Remains in committee-stage discussion; would introduce dedicated licensing categories for VASPs, PSPs and EMIs aligned to FATF/OECD standards [[Source 1]](#sec-sources) Probable · 1 source