PA · run world-payments-2026-07-04 v13.3.0
content: ai_generated 142 sources retrieved model claude-sonnet-5 ·

Panama

PA schema world-payments-v1 trajectory: not recorded

Last updated · 14 modules · 61 sourced findings · 142 sources in the cumulative register

14Modulesbaseline.modules[]
61Findingsmodules[].findings[]
39Tier-1 sourcesrun_metadata.t1_source_count
Confidence mix (sums to 14 rendered modules; click to filter)

Jurisdiction brief

Lead Signal

Panama enters this monitoring cycle with its first comprehensive baseline assessment, and the standout finding is a persistent structural gap: the country still has no dedicated licensing regime for non-bank payment institutions or e-money issuers. The Superintendencia de Bancos de Panamá (SBP) maintains a registry of Means of Payment/E-Money Issuers, but supervises those entities solely for anti-money-laundering, counter-terrorist-financing and weapons-proliferation-financing purposes under Law 23 of 2015 — not under any prudential or conduct-of-business licensing framework. A World Bank Financial Sector Assessment Program note flags that this creates public confusion between AML registration and genuine licensing, a distinction with direct commercial-relevance consequences for market entry and correspondent-bank due diligence. Panama's legislature moved to address the gap on 13 January 2026 with Anteproyecto de Ley No. 314, the Ley Marco Integral de Tecnologías Financieras, which would create Panama's first dedicated licensing categories for virtual-asset service providers, payment-service providers and e-money issuers, with SBP as primary supervisor and the Financial Analysis Unit (UAF) receiving suspicious-activity reports. The bill has not been enacted, and no forward committee or plenary date has been sourced this cycle.

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Density

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Panama has no dedicated EMI/PSP/PI licensing regime yet. The SBP currently supervises banks, trust companies and money-remittance operators; EMI, PI and PSP activity is neither expressly prohibited nor fully regulated. Draft Law No. 314, introduced 13 January 2026, would create the first dedicated licensing framework for VASPs, PSPs and EMIs under SBP supervision with UAF handling SAR intake, but remains unenacted as of this cycle. SBP Rule 1-2026 (Jan 2026) has separately tightened AML/CFT documentary requirements affecting fintech bank-access pathways.

Movement — NEWAnteproyecto de Ley 314 filed; SBP Rule 1-2026 in forceNew draft licensing law and new bank-access tightening rule identified for Panama this cycle.
Open gap — wpm-int-7No parallel/competing fintech legislative proposals (e.g. other draft bills reported to be under National Assembly review alongside Draft Law 314) were surfaced by this cycle's research beyond the single Draft Law 314 thread.no under-indexing note recorded
Standing sub-brief274 words · last cycle wpm-2026-09-05

Licensing, Authorisation & Market Access

Panama's Superintendencia de Bancos de Panamá (SBP) publishes a registry of Means of Payment and E-Money Issuers, but this registry is an anti-money-laundering, counter-terrorist-financing and weapons-proliferation-financing registration under Law 23 of 2015 rather than a prudential or conduct-of-business licence. A World Bank Financial Sector Assessment Program technical note corroborates that this arrangement creates public confusion between AML registration and genuine licensing, with only four fintechs formally registered as Financial Obligated Parties according to secondary commentary. For non-bank payment institutions and e-money issuers, the practical effect is legal uncertainty that complicates market entry and correspondent-bank due diligence, since counterparties cannot rely on the registry as evidence of prudential supervision.

Periodic update · new data 2026-09-05 · run wpm-2026-09-05

Licensing, Authorisation & Market Access

Panama's payments-market-access environment is undergoing simultaneous change on two distinct tracks. Anteproyecto de Ley 314, presented to the Asamblea Nacional plenary on 13 January 2026 by Deputy Ernesto Cedeno Alvarado, proposes distinct licence types for payment service providers, virtual-asset service providers, and PSP-like intermediaries, with capital and governance requirements calibrated proportionally to risk, under joint supervision by the Superintendencia de Bancos de Panama (SBP) for prudential matters and the Unidad de Analisis Financiero (UAF) for AML/CFT matters. This is assessed with probable confidence from a Tier-3 legal-commentary source and remains at an early legislative stage: the bill requires committee review and two further plenary debates plus presidential assent before taking effect, corroborated by an independent Tier-3 source describing the same filing and legislative posture.

Separately, and already in force, SBP Rule 1-2026 requires banks to collect enhanced evidence of economic activity, beneficial ownership, and source of funds before account opening. This is a confirmed, Tier-1 primary-source finding directly sourced from the regulator itself, and it has immediate practical effect on how non-bank payment institutions and e-money issuers access Panamanian banking rails, independent of and preceding any dedicated licensing framework Bill 314 might eventually establish. The bank-or-nonbank distinction is significant here: Rule 1-2026 formally applies to banks' own account-opening practices, but its effect flows through directly to the nonbank PSPs and EMIs seeking to bank with them, tightening market access for that segment ahead of any dedicated licence category existing for them.

This combination reflects and updates the standing characterisation of Panama's fintech regulatory environment as a 'legal nothingness', a patchwork of general banking and AML statutes without a dedicated PSP, EMI, or VASP framework. That characterisation, assessed with probable confidence, remains accurate as of this cycle in the sense that no dedicated licence category yet exists, but the picture is now one of a regulatory gap actively being addressed on two fronts simultaneously: immediate, already-effective tightening of the terms under which nonbank entities can access bank accounts, and a proposed, not-yet-enacted structural fix in the form of Bill 314's tiered licensing regime.

The proposed licensing structure's risk-proportionate design merits note for its market-access implications specifically. By differentiating capital and governance requirements across PSP, VASP, and PSP-like intermediary categories rather than applying a single uniform bar, the bill's design would potentially lower the market-access threshold for smaller or lower-risk payment intermediaries relative to a one-size-fits-all licensing standard, while still imposing a supervisory perimeter that does not currently exist. This is a design observation drawn directly from the bill's proposed structure rather than an independent judgment about its likely effect.

Outlook

The committee-stage progression of Anteproyecto de Ley 314 is the primary item to watch for Panama's licensing and market-access landscape, with an expected impact window in the fourth quarter of 2026 carrying a half-year uncertainty band given the bill's early stage and the multiple further legislative steps required. In the interim, the practical market-access reality for nonbank payment institutions is shaped more immediately by SBP Rule 1-2026's already-effective account-opening documentary tightening than by the still-pending licensing bill. A primary-source gap remains: the Asamblea Nacional's own hosting of Bill 314's text was not independently fetched this cycle, meaning the bill's precise legislative language has not been directly verified against a Tier-1 source.

2 earlier distinct update(s)
Periodic update · new data 2026-08-25 · run wpm-2026-08-21

Licensing, Authorisation & Market Access

Panama's payments-licensing landscape is currently defined by absence: there is no enacted licensing regime specific to payment service providers, electronic-money institutions, or virtual-asset service providers. Non-bank payment activity — illustrated by an estimated eighteen registered remittance companies — operates under the general money-services-business framework rather than under a dedicated PSP/EMI licensing statute. This gap is the backdrop against which Draft Law No. 314, introduced in the National Assembly on 13 January 2026, should be read: the draft would create Panama's first dedicated licensing regime for PSPs, EMIs and VASPs, placing them under Superintendencia de Bancos de Panamá supervision with Unidad de Análisis Financiero suspicious-activity-report intake. Commentary on the draft indicates it would additionally impose capitalisation and governance standards on newly licensed entities. As a draft moving through the legislative process, its provisions are not yet binding, and its practical timeline is assessed as multi-year and uncertain.

On the bank side of the licensing ledger, a distinct but related development occurred: SBP Rule 1-2026 tightened AML/CFT documentary requirements for account opening and ongoing monitoring. This is a bank/PSP-side supervisory tightening, formally distinct from the non-bank PSP/EMI/VASP licensing gap that Draft Law No. 314 targets, but material to market access in practice, because non-bank payment and crypto firms in Panama depend on correspondent and business-banking relationships with SBP-supervised banks to operate.

The bank-versus-non-bank distinction is therefore the organising fact for this module this cycle. Banks and their PSP relationships are governed by an increasingly formalised, actively tightening AML/CFT documentary regime under direct SBP supervision. Non-bank PSPs, EMIs and VASPs, by contrast, remain outside any dedicated licensing perimeter, governed only by the general MSB framework and by whatever conditions their banking relationships impose. Draft Law No. 314 would collapse this asymmetry by bringing non-bank entities into a comparable direct-supervision structure, but until enactment the asymmetry is the operative market-access reality for any prospective non-bank payments entrant into Panama.

Outlook

The single most consequential development to track next cycle is legislative progress on Draft Law No. 314: whether it advances through further Assembly debate, is amended, or stalls. Its current proposed-stage, multi-year uncertainty band means market entrants planning around a licensed PSP/EMI/VASP pathway in Panama should not assume near-term availability of that pathway. In the interim, entrants relying on the existing MSB framework, or on banking relationships with SBP-supervised institutions, should expect those banking relationships to be subject to the tightening documentary standard introduced by SBP Rule 1-2026.

Periodic update · new data 2026-08-11 · run wpm-2026-08-05

Licensing, Authorisation & Market Access

Act 7 of 2025 (SB 202) is the structural licensing development for Pennsylvania this cycle: it extends Money Transmitter Act licensure to virtual-currency transmission conducted for a fee, effective August 26, 2025. This closes a licensing gap that had previously allowed fee-based virtual-currency transmission to operate outside the state's money-transmission licensing perimeter, and it is a high-confidence, Tier 1 finding corroborated by both the Pennsylvania Department of Banking and Securities' own announcement and the Pennsylvania Bulletin's statutory text. As a market-access matter, the change is squarely nonbank-PI/EMI-facing: bank-chartered payment service providers in Pennsylvania already operate under a distinct prudential supervisory track, so Act 7's extension of licensure to virtual-currency transmission principally affects nonbank payment institutions and electronic-money issuers offering virtual-currency transmission services, bringing them onto the same licensing, examination, and ongoing-compliance footing as fiat money transmitters rather than an unlicensed or ambiguously licensed model.

The underlying statute was renamed to the Money Transmission and Virtual Currency Transmission Business Licensing Law, with expanded definitions and exemptions, including a self-hosted-wallet carve-out and a business-entity transaction exemption; neither exemption type maps cleanly onto a standard licensing-exemption enum, which itself signals how bespoke Pennsylvania's carve-outs are relative to more standardized state virtual-currency licensing regimes elsewhere. This is a high-confidence, Tier 1 finding corroborated by law-firm secondary commentary. In parallel, Pennsylvania rescinded 10 Pa. Code Section 19.1a, its prior non-binding Virtual Currency Statement of Policy, in its entirety, effective the same date, on the basis that the guidance had become redundant once Act 7's statutory coverage took effect; this is a lifecycle transition from interpretive guidance to a licensing statute carrying enforcement consequences, and it is itself a high-confidence, Tier 1 finding. This is a standing-brief content-tier item rather than a dated dashboard entry, reflecting that Act 7 is a durable statutory change to the state's licensing perimeter rather than an episodic dashboard-level event, and market-access questions for virtual-currency transmission in Pennsylvania now rest on that statutory text rather than on the withdrawn policy statement.

Outlook

The practical significance of Act 7 for market access will be measured over coming cycles less by the statutory text itself, which is now settled and in effect, than by how the Department of Banking and Securities applies the new licensing perimeter in practice: whether virtual-currency transmitters previously operating in the state without a money-transmitter licence come forward to obtain one, and whether the self-hosted-wallet and business-entity exemptions are interpreted narrowly or broadly in early licensing determinations. No enforcement or licensing-decision data specific to the new virtual-currency transmission category has yet been reported this cycle; that is the next materiality threshold to watch for Pennsylvania's nonbank payment-institution and electronic-money-institution market-access conditions.

Sources and findings (5)
  1. T1https://www.superbancos.gob.pa/en/authorizations/means-paymentretrieved
  2. T2https://www.lexology.com/library/detail.aspx?g=3f2a65c9-efa5-4b1d-ad1b-dd721ca9be10retrieved
  3. T3https://globallawexperts.com/panama-fintech-law-2026-draft-law-no-314-sbp-rule-1-2026-licensing-aml-and-bank-access/retrieved
  4. T3https://en.wikipedia.org/wiki/Banking_in_Panamaretrieved
  5. T1https://documents1.worldbank.org/curated/en/099040424151021308/pdf/P179962143f93d0531a2901588726639e71.pdfretrieved

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Panama has no dedicated conduct-of-business or safeguarding regime for non-bank payment/e-money providers; consumer and conduct protection for banking relationships defaults to the SBP and ACODECO under general banking and consumer-protection law, with AML documentary/onboarding obligations tightened via SBP Rule 1-2026.

Standing sub-brief186 words · last cycle wpm-2026-07-04

Conduct, Safeguarding & Promotions

SBP Rule 1-2026, issued 16 January 2026, updates customer-due-diligence, enhanced-due-diligence, transaction-monitoring and internal-control obligations for all SBP-supervised entities, revoking prior rules 10-2015, 1-2013, 8-2000 and 10-2000. Secondary commentary anticipates a period of narrower fintech-client onboarding while institutions absorb the new compliance requirements, a conduct-adjacent effect that sits alongside the module's core safeguarding question.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T1https://www.superbancos.gob.pa/en/node/1652retrieved
  2. T3https://globallawexperts.com/panama-fintech-law-2026-draft-law-no-314-sbp-rule-1-2026-licensing-aml-and-bank-access/retrieved
  3. T1https://www.superbancos.gob.pa/en/sac/preguntas-frecuentesretrieved
  4. T3https://www.infobae.com/panama/2026/06/24/panama-pone-orden-a-la-forma-de-evaluar-los-incumplimientos-bancarios/retrieved

#

Panama has no comprehensive crypto/stablecoin law in force. A 2021-22 crypto bill (Bill 697) was partially vetoed by President Cortizo in June 2022 over AML concerns and was struck down as unconstitutional by the Supreme Court in July 2023, leaving digital assets in a legal grey area; a renewed Bill No. 247 (2025) is pending before the National Assembly.

Standing sub-brief212 words · last cycle wpm-2026-07-04

Stablecoins & Digital Money

Panama's most consequential crypto-regulatory event remains the 2022-23 nullification of Bill No. 697: partially vetoed by President Cortizo in June 2022 on anti-money-laundering grounds while Panama sat on the FATF grey list, then declared entirely unconstitutional by the Supreme Court in July 2023, resetting the country's legislative effort at comprehensive crypto regulation to zero. The Supreme Court's ruling sided fully with the President's veto objections, leaving no comprehensive crypto framework in force and establishing a legal precedent that now weighs on any future legislative attempt, including the pending Bill No. 247.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T3https://www.coindesk.com/policy/2022/06/17/panamanian-president-partially-vetoes-crypto-regulation-legislationretrieved
  2. T3https://sb-sb.com/services/crypto/crypto-license/latam/panama/retrieved
  3. T3https://www.forbes.com/sites/digital-assets/2025/07/31/panama-crypto-law-aims-to-make-the-country-a-bitcoin-hub/retrieved
  4. T3https://www.lightspark.com/knowledge/is-crypto-legal-in-panamaretrieved

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Panama's operational-resilience framework for regulated financial entities rests on a set of pre-DORA SBP agreements covering outsourcing, electronic banking, and IT risk management, with cloud-service use outside Panama requiring prior SBP/SMV approval or notification; there is no consolidated cyber-resilience statute equivalent to DORA.

Standing sub-brief176 words · last cycle wpm-2026-07-04

Operational Resilience & Critical Infrastructure

Panama's operational-resilience framework rests on pre-DORA agreements issued by SBP and the Superintendencia del Mercado de Valores: Acuerdos 009-2005, 006-2011, 003-2012 and 005-2018 cover outsourcing, electronic-banking risk and IT-risk management respectively. Cloud services located outside Panama require prior SBP approval or SMV notification, and no consolidated cyber-resilience statute equivalent to the EU's Digital Operational Resilience Act exists; comparators such as DORA are cited by market commentary for contrast only, not as a benchmark Panama has adopted.

No periodic updates recorded against this sub-brief.

Sources and findings (5)
  1. T2https://aws.amazon.com/financial-services/security-compliance/compliance-center/pa/retrieved
  2. T2https://aws.amazon.com/financial-services/security-compliance/compliance-center/pa/retrieved
  3. T3https://emailmarketingpanama.com/en/email-banking-financial-services.htmlretrieved
  4. T3https://gladiium.com/cybersecurity-panama/retrieved
  5. T1https://documents1.worldbank.org/curated/en/099613104102429031/pdf/SECBOS1af572a90621b72716e27781ecaec.pdfretrieved

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Card-scheme rails in Panama run through the domestic Telered/Clave debit network alongside Visa and Mastercard acceptance via bank-operated gateways; PCI DSS compliance is expected of payment gateways and processors but there is no bespoke Panamanian interchange-regulation or surcharging statute identified.

Open gap — wpm-int-5No source was found confirming or denying the existence of a Panamanian interchange-regulation or card-surcharging statute (W4); absence recorded as no_source, not confirmed non-existence.no under-indexing note recorded
Standing sub-brief137 words · last cycle wpm-2026-07-04

Scheme & Network Compliance

All Panamanian banks operate through Telered's Clave debit-card system and the traditional ACH, alongside newer bank-specific instant-transfer platforms such as Yappy. Visa and Mastercard are accepted via bank-operated gateways, and no bespoke interchange-regulation or card-surcharging statute was identified in this cycle's research; the gap is recorded as no-source rather than confirmed non-existence.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T3https://www.martesfinanciero.com/relieve/yappy-evoluciona-para-ser-una-plataforma-de-pagos-independiente/retrieved
  2. T3https://jootser.com/pasarelas-de-pago-para-e-commerce-en-panama/retrieved
  3. T3https://jootser.com/pasarelas-de-pago-para-e-commerce-en-panama/retrieved
  4. T1https://www.superbancos.gob.pa/retrieved

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Panama is a fully dollarized economy with no foreign-exchange controls, functioning as a regional trade-finance and correspondent hub; the dominant retail corridor is US-Panama remittances, while digital/mobile remittance fees remain persistently higher across Central America/Panama/Dominican Republic (CAPDR) than the global average despite a declining trend.

Standing sub-brief146 words · last cycle wpm-2026-07-04

Payment Corridor Dynamics

Panama remains fully dollarized with no foreign-exchange controls, functioning as a regional trade-finance and correspondent-banking hub. International Banking Center external deposits grew 14.72% to US$48,097 million, with Colombia, Brazil, Guatemala, Costa Rica and the Dominican Republic together accounting for over 58% of these funds, corroborating commentary on dollarization's attractiveness for cross-border platforms.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T3https://globallawexperts.com/how-to-open-a-fintech-company/retrieved
  2. T1https://www.elibrary.imf.org/view/journals/001/2022/238/article-A001-en.xmlretrieved
  3. T1https://www.superbancos.gob.pa/en/node/1687retrieved
  4. T3https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/retrieved

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Panama's payments industry is dominated by an oversized International Banking Center of roughly 50-80 licensed banks, with domestic digital-wallet competition concentrated among a handful of bank-sponsored platforms (Yappy/Banco General, Nequi/Banistmo, Kuara/Global Bank-Banesco-MMG, Zinli/Banco Mercantil), rather than independent non-bank fintech challengers.

Standing sub-brief127 words · last cycle wpm-2026-07-04

Industry Structure & Commercial Dynamics

Panama hosts 50 to 80-plus licensed banks, and domestic digital-wallet competition is concentrated among bank-sponsored platforms — Yappy (Banco General), Nequi (Banistmo), Kuara (Global Bank-Banesco-MMG) and Zinli (Banco Mercantil) — rather than independent non-bank fintech challengers.

Illustrating the structural difficulty non-bank challengers face against bank distribution advantages, telco entrant Tigo Money (Millicom) soft-launched in August 2023 but was shut down by March 2024 — a single-source but illustrative market-structure signal about the durability of incumbent-bank wallet dominance.

No periodic updates recorded against this sub-brief.

Sources and findings (5)
  1. T3https://www.centralamerica.com/investing/banking-in-panama/retrieved
  2. T3https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/retrieved
  3. T3https://newsroompanama.com/2024/04/27/banco-general-yappy-makes-an-important-update/retrieved
  4. T3https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/retrieved
  5. T2https://www.trade.gov/country-commercial-guides/panama-trade-financingretrieved

The most consequential recent payments-adjacent litigation is the Supreme Court's 2023 nullification of the vetoed crypto law; on the supervisory-enforcement side, the SBP operates a public sanctions register for banking/trust/AML breaches and has just codified (Acuerdo 3-2026) a graduated sanctions methodology to replace prior ad hoc practice.

Standing sub-brief134 words · last cycle wpm-2026-07-04

Legal & Litigation

The most consequential payments-adjacent litigation event remains the Supreme Court's July 2023 ruling declaring the entirety of crypto bill No. 697 unconstitutional, siding with President Cortizo's 2022 veto objections and nullifying Panama's first comprehensive attempt at crypto regulation.

More recently, SBP Acuerdo No. 3-2026 (29 May 2026) established uniform criteria classifying AML/CFT infractions as minor, serious or very serious, weighing duration, recidivism, harm and institution size, replacing what had been ad hoc sanctioning practice; this instrument is sourced only via T3 secondary reporting, with no primary SBP gazette text retrieved this cycle.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T3https://sb-sb.com/services/crypto/crypto-license/latam/panama/retrieved
  2. T1https://www.superbancos.gob.pa/en/sanciones?field_year_sancion_value=Allretrieved
  3. T3https://www.infobae.com/panama/2026/06/24/panama-pone-orden-a-la-forma-de-evaluar-los-incumplimientos-bancarios/retrieved
  4. T1https://documents1.worldbank.org/curated/en/099040424151021308/pdf/P179962143f93d0531a2901588726639e71.pdfretrieved

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Merchant acquiring in Panama is delivered through bank-affiliated gateways (Banco General/Yappy Comercial, Banistmo, BAC Credomatic, Credicorp) plus independent processors (Wompi, Pagadito, Paguelofacil), with standard percentage-plus-tax merchant discount pricing and hybrid local-acquirer/global-PSP models used for multi-currency and tourism-sector acceptance.

Standing sub-brief126 words · last cycle wpm-2026-07-04

Merchant Acquiring & Risk

Yappy Comercial, Banco General's merchant-facing product, charges a commission of 1% plus ITBMS (minimum US$0.02) per transaction received, collected daily against that day's total received amount — a primary merchant-pricing disclosure drawn directly from the bank's own site.

Foreign PSPs can operate in Panama but typically must partner with a licensed local entity or establish local presence; tourism-sector merchants commonly combine local acquiring banks such as Banco General with global PSPs such as Worldline and Adyen to achieve multi-currency acceptance.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T2https://www.bgeneral.com/yappy/retrieved
  2. T3https://jootser.com/pasarelas-de-pago-para-e-commerce-en-panama/retrieved
  3. T3https://payatlas.com/countries/panama-paretrieved
  4. T3https://payatlas.com/countries/panama-paretrieved

#

Panama's payments innovation is led by bank-sponsored real-time mobile wallets built on the Telered/ACH Xpress rails, with Yappy the dominant platform and growing interoperability across banks; roughly 93% of the population is reported to use mobile banking, and Caja de Ahorros runs an agency-banking program for financial inclusion in remote areas.

Standing sub-brief134 words · last cycle wpm-2026-07-04

Product Innovation & Market Development

Telered's ACH Xpress instant-payment integration had 16 banks integrated by end-2023, executing 1.4 million transactions worth $18 million, with a stated goal of adding ten more banks under the renamed 'Xpress' platform — a clear signal of expanding bank-to-bank interoperability.

State savings bank Caja de Ahorros runs an agency-banking programme for financial inclusion, though agent locations remain absent from the most remote communities such as Darién province, and national postal operator COTEL's financial-service potential remains underutilised for lack of investment, per a World Bank/IMF payments technical note.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T3https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/retrieved
  2. T4https://americaretail-malls.com/paises/centroamerica/panama-digital-el-93-de-la-poblacion-ya-usa-banca-movil/retrieved
  3. T1https://www.superbancos.gob.pa/documentos/evaluaciones_fmi/NT-SPN-Pagos-Panama-Payments-TN.pdfretrieved
  4. T3https://www.prensa.com/economia/yappy-nequi-zinli-y-ahora-kuara-compiten-en-el-mercado-de-los-pagos-digitales-en-panama/retrieved

#

Consumer protection for payments splits between ACODECO (general commercial/advertising complaints under Law 45 of 2007, competence up to US$5,000, US$30,000 for vehicles) and the SBP (banking-specific consumer complaints); there is no dedicated APP-fraud mandatory-reimbursement regime, and refund mechanics for misdirected instant-payment transfers rely on voluntary bank features rather than statutory liability rules.

Standing sub-brief140 words · last cycle wpm-2026-07-04

Consumer Protection & APP Fraud

Under Law 45 of 2007, ACODECO can decide directly only on consumer complaints up to US$5,000 (US$30,000 for vehicles under Law 14 of 2018); beyond those thresholds consumers must pursue ordinary courts, and no dedicated APP-fraud mandatory-reimbursement regime exists in Panama's regulatory architecture.

Because Panamanian banking regulation prevents banks from unilaterally debiting a client's account for a misdirected transfer without authorization or a court order, Banco General added a voluntary immediate-refund function to Yappy after user complaints — illustrating reliance on industry practice rather than a statutory misdirected-payment liability regime.

No periodic updates recorded against this sub-brief.

Sources and findings (4)
  1. T3https://lawgratis.com/blog-detail/consumer-law-panamaretrieved
  2. T1https://www.superbancos.gob.pa/en/sac/preguntas-frecuentesretrieved
  3. T3https://fmm.com.pa/panama-and-consumer-protection-in-the-digital-era/retrieved
  4. T3https://newsroompanama.com/2024/04/27/banco-general-yappy-makes-an-important-update/retrieved

#

sentinel.baseline: Panama's core AML/CFT instrument is Law 23 of 2015 (as amended), supervised by the SBP for financial obligated subjects and enforced via the newly codified Acuerdo 3-2026 sanctions methodology; Panama was FATF grey-listed June 2019 and formally delisted 27 October 2023, with the EU following in removing Panama from its high-risk list in 2024/2025.

Standing sub-brief184 words · last cycle wpm-2026-07-04

AML/CFT & Financial Crime (Sentinel.gi-fed)

Per Sentinel.gi's feed, FATF excluded Panama from its grey list on 27 October 2023 (having listed the country since June 2019) after determining that strengthened AML/CFT controls were in place; the European Commission followed by removing Panama from its high-risk list on 14 March 2024, corroborated by two independent T1 anchors — the FATF country page and the EC removal document.

No periodic updates recorded against this sub-brief.

Sources and findings (6)
  1. T3https://www.laestrella.com.pa/amp/economia/panama-endurece-las-reglas-de-prevencion-de-delitos-financieros-en-los-bancos-HH23530869
  2. T?FIM (sentinel.gi) per-JID baseline profile — Panama — Panama exited the FATF grey list in October 2023 and the EU high-risk third-country list in June 2025. 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.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure
  4. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: capacity-deficit
  5. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: legal-gap
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: enforcement-absence

#

Panama has no central bank and relies on Banco Nacional de Panamá as settlement bank for domestic clearing; correspondent-banking access has historically been sensitive to FATF/EU listing status, with post-2023 delisting improving relationships even as SBP Rule 1-2026 signals renewed compliance tightening to correspondent partners in the US and Europe.

Standing sub-brief186 words · last cycle wpm-2026-08-21

Correspondent Banking, Settlement & Access

Absent a central bank, Banco Nacional de Panamá operates the BNP clearinghouse, Panama's most important settlement system, with final settlement of net retail-payment positions effected in commercial-bank money on BNP's books; the World Bank's Financial Sector Assessment finds this settlement-risk management lacks sophistication, and participants can run largely uncollateralized net debit positions — the module's analytical spine is precisely this bank-versus-non-bank access asymmetry.

Periodic update · new data 2026-08-25 · run wpm-2026-08-21

Correspondent Banking, Settlement & Access

The analytical spine of Panama's correspondent-banking picture this cycle is the tension between structural trade volume and continued illicit-trade characterisation. The Colón Free Zone, a free-trade zone handling an estimated USD 25 billion in annual trade, is characterised in a 2026 anti-illicit-trade report as a smuggling and money-laundering transshipment hub. Panamanian officials rebutted this characterisation while acknowledging customs seizures exceeding USD 1 billion, including cocaine interceptions, over the same period.

For correspondent banks and payment intermediaries with exposure to Colón-linked trade-finance flows, this kind of allegation functions as a de-risking input independent of its ultimate factual resolution: correspondent-banking risk assessments weigh reputational and illicit-trade-exposure factors that a report of this kind directly speaks to, regardless of whether Panama's own authorities contest the framing. The scale of the acknowledged customs seizures is itself evidence that illicit flows through the zone are non-trivial in volume, even if their characterisation as evidence of systemic laundering remains contested between the report's authors and Panamanian officials.

This module's Panama-specific correspondent-banking picture should be read as one instance of a broader access-asymmetry pattern that recurs globally: bank-supervised entities apply risk-based de-risking judgments that non-bank actors further down the payment chain cannot directly influence, and a report alleging free-trade-zone transshipment risk is precisely the kind of input that feeds those judgments without requiring any formal enforcement action to have occurred.

Outlook

The item to watch next cycle is whether any Tier-1 source corroborates or rebuts the Colón Free Zone transshipment characterisation. Absent that, correspondent banks are likely to continue treating the allegation as a live de-risking input. A second item is whether Panama's improving AML supervisory architecture begins to visibly offset correspondent-banking caution specific to the Colón Free Zone, though no evidence of that offset was available this cycle.

Sources and findings (5)
  1. T1https://documents1.worldbank.org/curated/en/099613104102429031/pdf/SECBOS1af572a90621b72716e27781ecaec.pdfretrieved
  2. T2https://www.prnewswire.com/news-releases/panama-officially-removed-from-fatf-grey-list-301970490.htmlretrieved
  3. T3https://globallawexperts.com/panama-fintech-law-2026-draft-law-no-314-sbp-rule-1-2026-licensing-aml-and-bank-access/retrieved
  4. T1https://www.superbancos.gob.pa/en/node/1687retrieved
  5. T4https://ape.socialcatalystlab.org/papers/apep_1234/v1/paper.pdfretrieved

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Panama's fintech investment activity remains modest in absolute terms relative to its role as a financial hub: trailing-12-month equity funding has been in the low tens of millions of dollars across a handful of rounds, with limited M&A exits in the fintech vertical, alongside the January 2026 legislative event of Draft Law 314's introduction.

Open gap — wpm-int-6Individual fintech funding-round and acquisition deal values in Panama are not disclosed in available sources (Tracxn aggregates only); deal-level commercial_event objects could not be populated this cycle.Private-company signal depth is structurally limited for Panama by aggregator-only coverage — a recognised WPM bias-correction area.
Standing sub-brief179 words · last cycle wpm-2026-07-04

Commercial Intelligence (M&A, Investment & Product)

Aggregate 2025 equity funding in Panama's fintech sector fell to $14.4 million across four rounds (through December), down from $18.4 million across nine rounds the prior year; individual deal values are not publicly disclosed. As of January 2026, only 67 of Panama's 707 fintech companies had received funding, and the sector recorded just one acquisition in the year through July 2025 against three historically — again with individual deal values not publicly disclosed.

No periodic updates recorded against this sub-brief.

Sources and findings (3)
  1. T4https://tracxn.com/d/geographies/panama/__M43a-AgsfK3LvgIGrffDKvH7UYcE9F8msaKUAD17KZgretrieved
  2. T4https://tracxn.com/d/explore/fintech-startups-in-panama/__yCpaKPFTlkZqAiiUSM-AyoXXfjbmrU1FCPMPyAFfEFsretrieved
  3. T3https://globallawexperts.com/panama-fintech-law-2026-draft-law-no-314-sbp-rule-1-2026-licensing-aml-and-bank-access/retrieved
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trust.content_sourceai_generated

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