--- title: "Panama Payments Regulation Monitor | World Payments Monitor" canonical: https://payments.gi/jurisdictions/panama/ source_html: /jurisdictions/panama/index.html description: "Panama payments and e-money regulation: 14 modules, 61 sourced findings, updated 2026-10-26. Licensing, safeguarding, stablecoins, AML/CFT." generated_at: 2026-10-26T19:20:26Z content_sha256: 3241080c5bf9b8767185537ad4a676abd93195fd8e1da7d43b4c7ed15d11bcb0 generator: "fe-fleet/md-twin@1.0" --- # Panama PA schema world-payments-v1 trajectory: not yet assessed Last updated 2026-10-26 · 14 modules · 61 sourced findings · 187 sources in the cumulative register Download report (PDF) Expand all 14 Modules 0 Moved this cycle 1 Key judgments 3 Open gaps 61 Findings 98 Tier-1 sources Confidence mix 13 unpopulated 1 confirmed (sums to 14 rendered modules; click to filter) No modules moved this cycle. ## Jurisdiction brief Jurisdiction lead brief 1,554 Full executive summary 516 Jurisdiction sub-brief 2 204 ###### Latest update · 25 October 2026 #### Lead Signal Panama's payments market is defined by commercial wallet consolidation racing ahead of the regulatory framework meant to govern it. Banistmo, one of Panama's larger banks, integrated the Yappy, Kuara and Xpress digital-wallet rails directly into its own mobile application, extending phone-number-based send-and-receive functionality across participating banks to more than 600,000 customers as of early October 2026. This is a bank-led aggregation move that bridges previously separate wallet ecosystems within a single institution's app, and it illustrates how quickly commercial interoperability among Panama's digital-payment rails is advancing even as the country's underlying licensing architecture for payment and fintech activity remains in draft form. The second thread reinforcing this picture is Banco Nacional de Panama's continued pursuit of a 24/7 continuous-operation instant-payments rail, with interoperability being extended beyond banks to fintechs and cooperatives. Taken together with the Banistmo wallet integration, this signals that Panama's payments infrastructure is moving toward broader, round-the-clock interoperability from multiple directions at once, commercial and quasi-public, while the statutory licensing regime that would formally supervise non-bank participants in that interoperable system has not yet been enacted. #### Other Developments Banistmo's wallet integration functions as the defining commercial-intelligence event. The partnership brought together Yappy, Kuara and Xpress under Banistmo's own app, announced 9 October 2026, with the specific financial terms of the arrangement not publicly disclosed. The scale claim, more than 600,000 customers gaining expanded digital-payment options, positions this as a market-moving product development rather than a minor feature update, extending phone-number-based payments across participating banks within a single consolidated interface. Banco Nacional de Panama's instant-payments push continues without a new confirmed date. The bank's pursuit of a 24/7 continuous-operation rail with interoperability extended to fintechs and cooperatives, not just banks, was restated this cycle as a standing development rather than a newly dated milestone, indicating the initiative remains active but has not reached a fresh procedural marker since it was last reported. #### Cross-Monitor Connections The same gap between commercial payments innovation and the state of Panama's licensing statute that shows up here connects directly to financial-crime-focused monitoring of Panama's pending fintech and virtual-asset legislation: the Anteproyecto de Ley N.314 and related draft bills that would eventually create a dedicated licensing perimeter for payment and e-money firms are the same instruments relevant to anti-money-laundering registration and supervisory coverage questions tracked elsewhere. An International Monetary Fund Article IV mission's review of virtual-asset risk-assessment approaches with Panama's banking supervisor, reported in mid-October, situates squarely at this intersection between payments-market development and financial-integrity oversight. #### Outlook Panama's instant-payments and wallet-interoperability landscape is advancing commercially faster than its licensing statute, a gap likely to persist through at least the near term given that the Anteproyecto de Ley N.314 has no confirmed date for a first legislative debate. As scheduled, Banco Nacional's 24/7 interoperable rail remains a standing initiative without a fresh completion marker, and further bank-led wallet aggregation of the kind Banistmo has pursued is plausible given the commercial incentives already visible in the development, even as the supervisory perimeter for non-bank participants in that ecosystem remains unresolved. 8 earlier updates not shown here. ###### Standing brief · as of 4 July 2026 Written before the update above. Where they differ, the update is the more recent position. #### 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. Running in parallel, Panama's AML/CFT architecture has been actively consolidating since the country's delisting from the FATF grey list on 27 October 2023 (after listing since June 2019) and the European Commission's removal of Panama from its high-risk list on 14 March 2024. SBP Rule 1-2026 (16 January 2026) updated customer-due-diligence, enhanced-due-diligence and transaction-monitoring obligations, revoking four prior rules dating to 2000-2015, and Acuerdo No. 3-2026 (29 May 2026) codified a graduated sanctions methodology classifying infractions as minor, serious or very serious. Together these instruments replace a more ad hoc enforcement practice with a more legible compliance architecture — read by market participants as improving legal certainty even as the near-term effect on fintech-client onboarding by Panamanian correspondent banks appears to be tightening rather than loosening. #### Other Developments Panama's crypto and stablecoin framework remains in a legislative vacuum entrenched by litigation. Bill No. 697, the 2021-22 crypto framework, was partially vetoed by President Cortizo in June 2022 on AML grounds while Panama sat on the FATF grey list, then declared entirely unconstitutional by the Supreme Court in July 2023 — nullifying the country's first comprehensive attempt at crypto regulation and resetting the legislative clock. A successor, Bill No. 247, introduced in 2025, proposes VASP licensing tied to UAF registration, FATF-aligned KYC/AML compliance and a National Council for Digital Assets, but remains pending before the National Assembly with no confirmed forward timeline. On market structure, Panama's digital-wallet competition remains concentrated among bank-sponsored platforms — Yappy (Banco General), Nequi (Banistmo), Kuara (Global Bank-Banesco-MMG) and Zinli (Banco Mercantil) — reflecting the gravitational pull of a banking sector hosting 50 to 80-plus licensed institutions. Illustrating the difficulty non-bank challengers face, telco entrant Tigo Money soft-launched in August 2023 and had shut down by March 2024. Meanwhile instant-payments infrastructure continues to expand: Telered's ACH Xpress platform had 16 banks integrated by end-2023, executing 1.4 million transactions worth $18 million, with plans to add ten more participants. Dollarization without FX controls continues to reinforce Panama's role 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 those funds. An IMF working paper finds CAPDR digital remittance costs, though declining, remain above the global average. Operational resilience continues to run on a pre-DORA architecture: SBP and Superintendencia del Mercado de Valores agreements on outsourcing, electronic-banking risk and IT-risk management govern the sector, with cloud services located outside Panama requiring prior SBP approval or SMV notification, and no consolidated cyber-resilience statute equivalent to the EU's DORA yet exists. On payment rails, all Panamanian banks operate through Telered's Clave debit-card system and the traditional ACH alongside bank-specific instant-transfer platforms, with Visa and Mastercard accepted through bank-operated gateways; no bespoke interchange-regulation or card-surcharging statute was identified. PCI-DSS certification, tokenization and 3-D Secure authentication are treated as market expectations for scheme-connected processors rather than statutory mandates. Absent a central bank, Banco Nacional de Panamá's clearinghouse operates as the country's most important settlement system, with the World Bank's Financial Sector Assessment finding that settlement-risk management lacks sophistication and participants can run largely uncollateralized net debit positions — a structural vulnerability that also frames correspondent-banking access considerations. Consumer-protection architecture remains split and incomplete: ACODECO handles only limited banking-consumer matters under Law 45 of 2007 (misleading advertising, credit records, warranty, capped at direct decisions up to US$5,000), while other banking complaints go to SBP directly, and no dedicated APP-fraud mandatory-reimbursement regime or non-bank e-money safeguarding regime exists. Banco General's voluntary addition of an immediate-refund function to Yappy after user complaints illustrates reliance on industry practice rather than statutory rule. Commercial/fintech investment activity, meanwhile, looks modest against Panama's regional-hub role: aggregate 2025 equity funding fell to $14.4 million across four rounds, down from $18.4 million across nine rounds the prior year, with individual deal values undisclosed in available sources. #### Cross-Monitor Connections Panama's AML/CFT trajectory — the FATF/EU delisting and its consolidation through SBP Rule 1-2026 and Acuerdo 3-2026 — carries illicit-finance significance beyond WPM's payments-market-structure remit; that underlying analysis is flagged to FIM, which is better placed to assess the AML/CFT substance, while WPM here carries only the Sentinel-fed provenance summary relevant to payments supervision. Similarly, the 2022 veto of Bill 697 was explicitly grounded in AML/FATF grey-list concerns, and any illicit-finance-use analysis of Panama's pending VASP framework (Bill 247) properly belongs to FIM rather than WPM. #### Outlook Two forward markers dominate the Panama picture. First, Draft Law 314 is the mechanism most likely to close the licensing gap identified in W1a/W1b, but its passage and timeline are unconfirmed this cycle — a re-verification point for next cycle. Second, SBP Rule 1-2026's compliance tightening is likely to produce a near-term period of narrower fintech-client onboarding by correspondent banks even as the broader post-delisting trend favours improved international access; how these two forces net out for non-bank payment entrants over the coming cycles is the central open question for Panama's payments market structure. Read full brief · 1554 words ###### Latest update · 4 October 2026 #### Regulatory Status Panama's payments-regulatory status this cycle combines two confirmed-in-force bank-conduct tightenings with a persistent structural gap in payments-specific licensing. SBP's Acuerdo No. 01-2026 (16/27 January 2026), retrieved directly from SBP's own publication, tightens AML/CFT documentary requirements for account opening and ongoing monitoring, with direct relevance to fintech firms' bank-access onboarding. SBP's Acuerdo 7-2026 (approved 25 August 2026), known this cycle only through Tier-3 press reporting, bans fees on in-branch cash withdrawals and deposits from savings and checking accounts. Underlying both is the structural finding, confirmed at Tier-1 by a 2024 World Bank Financial Sector Assessment Program technical note, that Panama has not enacted a payment systems law, leaving no regulator charged with payment-system oversight or PSP licensing in its absence. Draft Law No. 314, filed 13 January 2026, proposes to close that gap with dedicated PSP and EMI licence categories, but remains unenacted and is supported only by Tier-3 legal commentary this cycle. #### Outlook Panama's payments-regulatory trajectory is tightening on the bank-conduct and AML-onboarding fronts while the core payments-licensing gap remains open. Draft Law 314's enactment timeline is uncertain, carrying only an indicative 2027 Q1 estimate on a year-wide uncertainty band; as scheduled, no Tier-1 confirmation of its content or stage has yet been obtained. 2 earlier updates not shown here. ###### Standing brief · as of 4 July 2026 Written before the update above. Where they differ, the update is the more recent position. #### Regulatory Status Panama's payments-regulatory status, established in this baseline cycle, is anchored by a persistent gap: no dedicated licensing regime exists for non-bank payment institutions or e-money issuers, with SBP's Law 23/2015 registry serving only an AML/CFT function rather than prudential or conduct supervision. Anteproyecto de Ley No. 314, introduced 13 January 2026, would close that gap by creating VASP/PSP/EMI licensing categories, but remains unenacted with no confirmed timeline. In parallel, Panama's AML/CFT posture has strengthened structurally since the FATF (October 2023) and EU (March 2024) delistings, consolidated by SBP Rule 1-2026 and Acuerdo 3-2026's graduated sanctions methodology; the crypto/stablecoin file remains stalled, with Bill 247 pending after the 2023 Supreme Court nullification of Bill 697. Market structure remains bank-dominated across every module: Yappy, Nequi, Kuara and Zinli lead digital-wallet competition and Tigo Money's 2023-24 exit illustrates the barrier non-bank entrants face; correspondent-banking access runs through Banco Nacional de Panamá absent a central bank, with post-delisting relief now offset by Rule 1-2026's compliance tightening; consumer protection splits between ACODECO and SBP with no APP-fraud reimbursement regime; and commercial/fintech investment activity is modest, with 2025 aggregate equity funding down year-on-year and the Draft Law 314 introduction standing as the year's principal market-development milestone. #### Outlook Panama's jurisdiction-level trajectory is one of tightening: the risk-tracker classification is moderate with a regulatory direction of tightening, concentrated in licensing (W1a/W1b), digital-asset law (W2) and AML/CFT supervision (W11/W12). The pivotal forward markers are Draft Law 314's legislative progress and Bill 247's movement, both unconfirmed this cycle; SBP Rule 1-2026's near-term onboarding effects on non-bank entrants and correspondent banks should be re-tested next cycle alongside any primary-source confirmation of Acuerdo 3-2026's text. Read full brief · 516 words Standing brief, as of 11 August 2026. #### Regulatory Status Pennsylvania's money-transmission licensing perimeter tightened this cycle with the entry into effect of Act 7 of 2025 (SB 202), which extends Money Transmitter Act licensure to virtual-currency transmission conducted for a fee, effective August 26, 2025. The underlying statute was renamed to the Money Transmission and Virtual Currency Transmission Business Licensing Law and had its definitions and exemptions expanded, including a self-hosted-wallet carve-out and a business-entity transaction exemption. The state's prior Virtual Currency Statement of Policy at 10 Pa. Code Section 19.1a was rescinded in its entirety as redundant once Act 7's statutory coverage took effect. All three findings are high-confidence and Tier 1, corroborated across the Pennsylvania Department of Banking and Securities, the Pennsylvania Bulletin, and secondary law-firm commentary. This is a nonbank-PI/EMI-facing development principally; bank-chartered payment service providers in the state remain under a distinct prudential supervisory track. #### Outlook The next materiality threshold for Pennsylvania's payments market-access conditions is enforcement or licensing-decision activity under the new virtual-currency transmission perimeter: whether previously unlicensed transmitters come forward, and how narrowly or broadly the Department of Banking and Securities interprets the self-hosted-wallet and business-entity exemptions in practice. No such activity has been reported yet this cycle. Read full brief · 204 words × 14 of 14 modules Signal Moved Judgment Gap Density Comfortable Compact Expand all sources Reset all Selections OR within a group, AND across groups. Press / to search. ### W1aLicensing, Authorisation & Market AccessProbableconfirmed 2026-07-04▾# Panama has no dedicated EMI/PSP licensing regime; payment and e-money activity is carried out under general banking-licence or non-bank financial-service-provider status supervised by the SBP, which now additionally requires tightened AML/CFT documentation per Acuerdo 1-2026 for account opening and ongoing monitoring. Draft Law 314 (filed 13 Jan 2026) would introduce activity-based PSP/EMI/VASP licensing but remains unenacted. Horizon · 2026-Q4 (± six months) Anteproyecto de Ley 314 fintech framework law progression Proposed · Tier 3 source Horizon · 2026-Q4 (± six months) Anteproyecto de Ley 314 fintech framework law progression Proposed · Tier 3 source Horizon · 2027-Q1 (± a year) Draft Law 314 fintech/VASP licensing framework Consultation · Tier 3 source Horizon · 2027 (± more than a year) Draft Law No. 314 fintech licensing framework pending enactment Proposed · Tier 3 source Horizon · 2027-Q1 (± a year) Draft Law 314 PSP/EMI licensing regime Proposed · Tier 3 source Horizon · 2027-Q1 (± more than a year) Anteproyecto de Ley 314 committee progress Proposed · Tier 3 source Horizon · 2026-H2 (± six months) Draft Law No. 314 expected legislative movement Proposed · Tier 3 source Standing sub-brief · as of 4 July 2026 274 words · last cycle 2026-10-18 #### 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. That gap is the direct backdrop to Anteproyecto de Ley No. 314, the Ley Marco Integral de Tecnologías Financieras, introduced to the National Assembly on 13 January 2026. The bill proposes Panama's first dedicated licensing categories for virtual-asset service providers, payment-service providers and e-money issuers, designating SBP as primary prudential supervisor while routing suspicious-activity reports to the Financial Analysis Unit (UAF). If enacted, it would be the first dedicated market-access gateway for non-bank PSPs and EMIs in Panama; however, no forward committee or plenary date has been sourced this cycle, and no parallel or competing fintech legislative proposals were identified in this cycle's research. #### Outlook Draft Law 314's progression is the single most consequential forward marker for Panama's licensing architecture: enactment would resolve the AML-registration-versus-licensing confusion that currently burdens non-bank market entrants, while continued stasis would leave SBP's Law 23/2015 registry as the only touchpoint for non-bank payment supervision. This module should be re-verified next cycle for committee or plenary movement. Read full sub-brief · 274 words Periodic update · new data 2026-10-18 #### Licensing, Authorisation & Market Access Panama's bank-access and licensing landscape tightened at the documentary level this cycle through SBP Rule 1-2026 (Acuerdo No. 01-2026), published 27 January 2026. The rule requires banks to apply enhanced AML/CFT risk-mitigation documentary checks when onboarding or maintaining relationships with fintechs, payment service providers and virtual-asset service providers, specifying corporate formation documents, proof of economic activity, AML/CFT programme documentation, and ultimate-beneficial-owner declarations at the 25 percent ownership threshold. This is probable, resting on Tier-3 law-firm commentary summarising the Acuerdo rather than the primary SBP text itself. For non-bank payment and e-money firms, this rule effectively codifies the documentary bar banks must clear before extending bank-access relationships, which has historically been one of the principal practical constraints on non-bank payment-sector growth in Panama. Separately, the SBP's Board approved Acuerdo No. 7-2026, amending Articles 4 and 5 of Acuerdo No. 4-2011 to eliminate or cap several retail-banking fees, including cash withdrawal and deposit fees below monthly thresholds, SWIFT-confirmation fees, bank-reference-letter fees, and beneficiary-designation fees. This is probable, also pending primary-source confirmation. While this measure is primarily consumer-facing, bank-reference-letter and SWIFT-confirmation fee changes are directly relevant to payment firms and correspondent relationships that rely on bank-issued documentation for onboarding or cross-border verification. Against this backdrop, Panama's dedicated VASP/PSP/EMI licensing framework, Draft Law No. 314, filed 13 January 2026, remains under legislative review with no confirmed movement this cycle, notwithstanding industry expectations of progress in the second half of 2026. This is probable. Until the bill advances, Rule 1-2026's enhanced documentary regime is the most concrete near-term lever shaping how non-bank payment and virtual-asset firms access the Panamanian banking system, in the continued absence of a dedicated licensing category for those firm types. #### Outlook The practical test of Rule 1-2026 will be whether SBP-supervised banks apply the enhanced documentary checks in a manner that facilitates rather than further restricts bank access for fintech, PSP and VASP clients; this is not yet observable from the available sourcing and would require primary SBP guidance or bank-level implementation evidence to resolve. Draft Law No. 314's legislative trajectory remains the single most consequential open question for Panama's licensing architecture; as scheduled for potential second-half-2026 movement, no confirmation has yet emerged, and the next legislative session is the marker to watch. 6 earlier distinct update(s) Periodic update · new data 2026-10-11 #### Licensing, Authorisation & Market Access Panama's licensing and market-access architecture for payments tightened at the bank-sector level this cycle without any corresponding advance at the non-bank level. SBP Acuerdo No. 1-2026, dated 16 January 2026, repeals the prior Acuerdo 10-2015 and updates due diligence obligations attaching to remote and digital-channel client onboarding, applying to banks, fiduciary companies and payment or e-money issuers alike. For firms using digital or remote channels to open accounts or contract financial services, this raises the bar for the onboarding controls a licence-holder must demonstrate, a market-access-adjacent development insofar as it changes what a firm must show to serve customers through those channels rather than changing who may be licensed in the first place. The larger market-access question for Panama's payments sector remains unresolved: Anteproyecto de Ley 314 would introduce the jurisdiction's first dedicated licensing regime for payment service providers, electronic-money institutions and virtual-asset service providers, under joint prudential supervision by SBP and anti-money-laundering oversight by the Unidad de Analisis Financiero, together with a regulatory sandbox mechanism. As of the most recent dateable reporting, from around April 2026, the bill remained in Asamblea Nacional committee review, having completed only its introduction phase; committee review, two plenary debates and presidential assent would all still need to occur before enactment. No confirmed progression was found dated within the current reporting window, and that absence of confirmed movement should be read as an information gap rather than as evidence the bill has stalled or advanced. Until Anteproyecto 314 is enacted, non-bank payment and e-money firms seeking to operate in Panama continue to do so without a purpose-built licensing framework distinct from the bank-centric regime the 2026 Acuerdos now update. #### Outlook The marker to track for Panama's licensing and market-access environment is whether Anteproyecto de Ley 314 moves out of committee review toward plenary debate; its current stalled status, last confirmed dated around April 2026, means the timeline to enactment remains genuinely open rather than merely delayed. In the interim, the practical effect of Acuerdo No. 1-2026 on digital-onboarding market access for banks, fiduciaries and payment and e-money issuers will depend on how SBP supervises implementation of the updated due-diligence standard, a question current reporting cannot yet answer given the instrument's recency. Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access Panama's licensing landscape for payments and digital-asset businesses is at a genuine inflection point. Draft Law No. 314, filed with the National Assembly on 13 January 2026, proposes Panama's first dedicated licensing framework covering payment service providers, e-money issuers, and virtual-asset service providers, placing all three categories under joint supervision by the Superintendencia de Bancos de Panamá (SBP) and the Unidad de Análisis Financiero (UAF). Prior to this proposal, Panama had no unified regime of this kind; non-bank payment institutions and e-money issuers operating in Panama have generally done so under general corporate and AML obligated-entity registration rather than under a purpose-built licensing category, and virtual-asset businesses have operated in a similar regulatory gap. While Draft Law No. 314 remains at the proposed stage before the legislature, the practical licensing and onboarding environment has already been reshaped by SBP Rule (Acuerdo) No. 1-2026, in force from 27 January 2026. This rule expressly revokes four prior regulations, Rules 10-2015, 1-2013 and 8-2000 among them, and tightens AML/CFT documentary and customer-due-diligence obligations across the full population of SBP-supervised entities. Because this rule applies to bank and non-bank PSP/EMI entities alike wherever they fall under SBP supervision, it functions as a de facto tightening of the market-access bar even in the absence of the dedicated PSP/EMI/VASP licensing category that Draft Law No. 314 would create. The distinction between bank and non-bank supervised entities matters here: a bank entering this documentary regime does so as an already-licensed and long-supervised entity, while a non-bank PI or EMI applicant faces the same tightened documentary bar as a threshold matter for any future licensing application, without yet having a dedicated licence category to apply for. #### Outlook The central market-access question is the pace and outcome of Draft Law No. 314's legislative progress; current expectations point to a 2027 timeframe at the earliest, with no confirmed committee stage this cycle. Until enactment, market access for non-bank payment and virtual-asset businesses in Panama will continue to run through the combination of general AML registration and SBP Rule 1-2026's tightened documentary standard, rather than through a dedicated licence. Periodic update · new data 2026-09-14 #### Licensing, Authorisation & Market Access Panama's payments licensing landscape saw two material developments this cycle, both pointing toward a formalisation of a previously undefined regulatory space. Draft Law 314, the Ley Marco Integral de Tecnologías Financieras, introduced 13 January 2026, would establish Panama's first dedicated licensing categories for payment-service providers, electronic-money issuers, and virtual-asset service providers. This is a market-access-defining development: today, none of these categories has a dedicated licensing pathway, meaning non-bank payment providers operate in a space defined more by what is not prohibited than by what is affirmatively authorised. Separately, and already in effect, the Superintendencia de Bancos de Panamá published Rule 1-2026 on 27 January 2026, tightening AML/CFT documentary requirements for bank account opening and ongoing monitoring. This is a bank-side instrument in form, but its market-access consequence for non-bank payment institutions and EMIs is direct: since Panama has no dedicated non-bank licensing regime today, PSPs and EMIs seeking to operate depend on banking relationships, and any tightening of the documentary bar for account opening raises the practical bar for market entry via the bank-access channel that currently substitutes for a dedicated licence. The bank-PSP versus non-bank-PI/EMI distinction is therefore central to this module this cycle: banks face a documentary-tightening obligation directly, while non-bank PSPs and EMIs face the same tightening indirectly, as a precondition of the banking access they currently rely on in the absence of their own licensing track. #### Outlook Draft Law 314 remains at the consultation stage with an estimated 2027-Q1 impact window carrying year-level uncertainty. The key question for market access is whether the eventual licensing framework will create a standalone non-bank licensing pathway that reduces dependence on the bank-access channel, or whether banking-relationship dependency persists even after formal licensing categories exist. Periodic update · new data 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. Periodic update · new data 2026-08-25 #### 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 #### 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. Evidence 5 Sources and findings (5) - T1[https://www.superbancos.gob.pa/en/authorizations/means-payment](https://www.superbancos.gob.pa/en/authorizations/means-payment)retrieved 2026-07-04 - T2[https://www.lexology.com/library/detail.aspx?g=3f2a65c9-efa5-4b1d-ad1b-dd721ca9be10](https://www.lexology.com/library/detail.aspx?g=3f2a65c9-efa5-4b1d-ad1b-dd721ca9be10)retrieved 2026-07-04 - T3[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/)retrieved 2026-07-04 - T3[https://en.wikipedia.org/wiki/Banking_in_Panama](https://en.wikipedia.org/wiki/Banking_in_Panama)retrieved 2026-07-04 - T1[https://documents1.worldbank.org/curated/en/099040424151021308/pdf/P179962143f93d0531a2901588726639e71.pdf](https://documents1.worldbank.org/curated/en/099040424151021308/pdf/P179962143f93d0531a2901588726639e71.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-07-04 ### W1bConduct, Safeguarding & PromotionsProbableconfirmed 2026-07-04▾# 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. Horizon · 2027-03-31 (± a quarter) Acuerdo 6-2026 credit-adequation deadline now 31 March 2027 Adopted, not yet in force · Tier 2 source Standing sub-brief · as of 4 July 2026 186 words · last cycle 2026-10-11 #### 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 dedicated conduct-of-business or safeguarding regime exists for non-bank e-money customers. ACODECO handles only limited banking-consumer matters under Law 45 of 2007 — misleading advertising, credit records and warranty claims — while other banking complaints go directly to SBP; consumer-facing safeguarding of e-money balances is not addressed by either regulator, an absence that reflects the lack of a dedicated regime rather than a confirmed permissive rule. #### Outlook The bank-PSP/non-bank-PI-EMI distinction is acute here: banks absorb Rule 1-2026's CDD/EDD tightening within existing conduct frameworks, while non-bank e-money issuers have no conduct-of-business or safeguarding regime to absorb it into at all. Enactment of Draft Law 314 would be the natural vehicle to close this conduct/safeguarding gap for non-bank entities; absent that, the gap persists as a standing feature of Panama's regime. Read full sub-brief · 186 words Periodic update · new data 2026-10-11 #### Conduct, Safeguarding & Financial Promotions Panama's conduct-side regulatory activity this cycle centred on three SBP Acuerdos issued across 2026, each addressing a distinct conduct or operational dimension. Acuerdo No. 7-2026, dated 25 August 2026, modifies Articles 4 and 5 of the existing Acuerdo 4-2011 to strengthen transparency requirements around bank commissions and charges, a direct consumer-facing fee-disclosure development applicable to licensed banks. Separately, 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, a development reported through Panamanian press coverage of the primary regulatory act rather than independently retrieved from SBP's own published text this cycle. The same date produced Acuerdo No. 9-2026, which defers the formal entry into force of Acuerdo 6-2026's credit-adequation standard to 31 March 2027, a sequencing decision affecting the timeline on which an existing conduct standard takes effect rather than a substantive change to that standard itself. These three instruments should be read as incremental conduct tightening layered onto the existing bank-centric regulatory structure, with fee transparency and electronic-funds-transfer supervision both strengthening in 2026 while a separate credit-adequation standard is given additional implementation time. No safeguarding-specific instrument distinct from these three was identified in this cycle's research for Panama. #### Outlook The near-term marker for Panama's conduct and safeguarding environment is the 31 March 2027 credit-adequation deadline now set by Acuerdo No. 9-2026; whether that standard takes effect as rescheduled, or faces a further deferral, will be a relevant indicator of SBP's sequencing approach to conduct-standard implementation generally. Acuerdos 7-2026 and 8-2026 have not yet been independently verified against SBP's own full published text in every particular, since the record relies in part on secondary press reporting of the primary acts; confirmation against the primary instruments would strengthen the evidentiary basis for assessing their practical effect in future cycles. 1 earlier distinct update(s) Periodic update · new data 2026-10-04 #### Conduct, Safeguarding & Financial Promotions Bank conduct requirements in Panama tightened on two fronts this cycle, both issued by the Superintendencia de Bancos de Panama. Acuerdo No. 01-2026, dated 16/27 January 2026 and retrieved directly from SBP's own publication, sharpens AML/CFT documentary requirements for account opening and ongoing monitoring across both bank and non-bank account relationships. This is primarily a due-diligence and monitoring instrument, but its effect on conduct toward customers opening accounts is direct: documentary expectations at onboarding are now higher than they were before 27 January 2026. Separately, Acuerdo 7-2026, approved on 25 August 2026, amends the existing Acuerdo 4-2011 to ban fees on in-branch cash withdrawals and deposits from savings and checking accounts, effective from its approval date. This is a consumer-facing fee-conduct change with no AML or licensing dimension: it restricts what banks may charge customers for basic cash transactions at branch counters. The only sourcing located for this instrument this cycle is Tier-3 press reporting; SBP's own text of Acuerdo 7-2026 has not been independently retrieved, so this finding carries Probable rather than Confirmed confidence, and any firm relying on the fee-ban's precise scope or effective-date mechanics should treat the press account as provisional pending the primary text. Both instruments point in the same direction: Panamanian banking-sector conduct regulation is tightening, whether on the documentary side of account opening or on the fee side of routine account servicing. Safeguarding-specific developments with a Panama nexus were not identified this cycle; the conduct movement observed is concentrated in AML-onboarding documentation and cash-transaction fee structure rather than in client-asset safeguarding or financial-promotions rules specifically. #### Outlook As scheduled, both Acuerdo 1-2026 and Acuerdo 7-2026 are already in effect as of their respective dates, so the relevant near-term question for market participants is implementation and compliance with the tightened onboarding-documentation and fee-restriction standards rather than anticipation of further rule change. Confirmation of Acuerdo 7-2026's precise terms against SBP's own primary text remains an open item; until that is retrieved, the fee-ban's scope should be treated as reported rather than confirmed. Evidence 4 Sources and findings (4) - T1[https://www.superbancos.gob.pa/en/node/1652](https://www.superbancos.gob.pa/en/node/1652)retrieved 2026-07-04 - T3[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/)retrieved 2026-07-04 - T1[https://www.superbancos.gob.pa/en/sac/preguntas-frecuentes](https://www.superbancos.gob.pa/en/sac/preguntas-frecuentes)retrieved 2026-07-04 - T3[https://www.infobae.com/panama/2026/06/24/panama-pone-orden-a-la-forma-de-evaluar-los-incumplimientos-bancarios/](https://www.infobae.com/panama/2026/06/24/panama-pone-orden-a-la-forma-de-evaluar-los-incumplimientos-bancarios/)retrieved 2026-07-04 ### W2Stablecoins & Digital Money1 gapProbableconfirmed 2026-07-04▾# 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. Open gap — wpm-int-2 No stablecoin-specific regime or development found for Panama this cycle. Emerging-market/corridor-level coverage for Panama is structurally thin. Standing sub-brief · as of 4 July 2026 212 words · last cycle 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. A successor bill, No. 247, introduced in 2025, proposes licensing of virtual-asset service providers registered with the Financial Analysis Unit (UAF), mandates FATF-aligned KYC/AML compliance, and creates a National Council for Digital Assets. Its status remains pending before the National Assembly, with no confirmed forward enactment date sourced this cycle; the bill's fate should be re-verified next cycle. #### Outlook Litigation precedent now functions as an implicit filter on Panama's crypto/stablecoin ambitions: any future VASP or stablecoin framework must clear the constitutional bar the Supreme Court set in 2023. Bill 247's progression — or continued stasis — is the key marker to track next cycle; illicit-finance-use dimensions of any eventual VASP regime fall to FIM rather than WPM. Read full sub-brief · 212 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T3[https://www.coindesk.com/policy/2022/06/17/panamanian-president-partially-vetoes-crypto-regulation-legislation](https://www.coindesk.com/policy/2022/06/17/panamanian-president-partially-vetoes-crypto-regulation-legislation)retrieved 2026-07-04 - T3[https://sb-sb.com/services/crypto/crypto-license/latam/panama/](https://sb-sb.com/services/crypto/crypto-license/latam/panama/)retrieved 2026-07-04 - T3[https://www.forbes.com/sites/digital-assets/2025/07/31/panama-crypto-law-aims-to-make-the-country-a-bitcoin-hub/](https://www.forbes.com/sites/digital-assets/2025/07/31/panama-crypto-law-aims-to-make-the-country-a-bitcoin-hub/)retrieved 2026-07-04 - T3[https://www.lightspark.com/knowledge/is-crypto-legal-in-panama](https://www.lightspark.com/knowledge/is-crypto-legal-in-panama)retrieved 2026-07-04 ### W3Operational Resilience & Critical InfrastructureProbableconfirmed 2026-07-04▾# 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. Kept on Dataprotection.gi, not restated here: data and cloud switching obligations on service providers, including notice periods and charges. [Open this jurisdiction's page on Dataprotection.gi →](https://dataprotection.gi/jurisdictions/panama/) Standing sub-brief · as of 4 July 2026 176 words · last cycle 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. Absent a central bank, Banco Nacional de Panamá's clearinghouse functions as the country's most important settlement system for retail payments. The World Bank's Financial Sector Assessment finds that settlement-risk management here lacks sophistication, with participants able to run largely uncollateralized net debit positions — a structural feature carried through directly into this monitor's W12 correspondent-banking and settlement analysis. #### Outlook Absent a DORA-equivalent statute, Panama's operational-resilience posture will likely continue to develop incrementally through SBP/SMV rule updates rather than a single consolidating law; monitor for any successor instrument that might formally supersede the 2005-2018 Acuerdo series. Read full sub-brief · 176 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T2[https://aws.amazon.com/financial-services/security-compliance/compliance-center/pa/](https://aws.amazon.com/financial-services/security-compliance/compliance-center/pa/)retrieved 2026-07-04 - T2[https://aws.amazon.com/financial-services/security-compliance/compliance-center/pa/](https://aws.amazon.com/financial-services/security-compliance/compliance-center/pa/)retrieved 2026-07-04 - T3[https://emailmarketingpanama.com/en/email-banking-financial-services.html](https://emailmarketingpanama.com/en/email-banking-financial-services.html)retrieved 2026-07-04 - T3[https://gladiium.com/cybersecurity-panama/](https://gladiium.com/cybersecurity-panama/)retrieved 2026-07-04 - T1[https://documents1.worldbank.org/curated/en/099613104102429031/pdf/SECBOS1af572a90621b72716e27781ecaec.pdf](https://documents1.worldbank.org/curated/en/099613104102429031/pdf/SECBOS1af572a90621b72716e27781ecaec.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-07-04 ### W4Scheme & Network Compliance1 gapProbableconfirmed 2026-07-04▾# 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-3 No scheme/network compliance (Visa/Mastercard/PCI-DSS) development found for Panama this cycle. no under-indexing note recorded Standing sub-brief · as of 4 July 2026 137 words · last cycle 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. PCI-DSS certification, tokenization and 3-D Secure authentication are flagged by market commentary as expected functionalities for scheme-connected payment gateways, though no bespoke statutory mandate for these controls was identified; this finding rests on a single indicative source rather than confirmed regulatory text. #### Outlook The absence of a confirmed interchange-regulation statute remains an open research question rather than a settled finding of deregulation; this module should be re-tested against any Draft Law 314 secondary provisions on scheme access if the bill advances. Read full sub-brief · 137 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T3[https://www.martesfinanciero.com/relieve/yappy-evoluciona-para-ser-una-plataforma-de-pagos-independiente/](https://www.martesfinanciero.com/relieve/yappy-evoluciona-para-ser-una-plataforma-de-pagos-independiente/)retrieved 2026-07-04 - T3[https://jootser.com/pasarelas-de-pago-para-e-commerce-en-panama/](https://jootser.com/pasarelas-de-pago-para-e-commerce-en-panama/)retrieved 2026-07-04 - T3[https://jootser.com/pasarelas-de-pago-para-e-commerce-en-panama/](https://jootser.com/pasarelas-de-pago-para-e-commerce-en-panama/)retrieved 2026-07-04 - T1[https://www.superbancos.gob.pa/](https://www.superbancos.gob.pa/)retrieved 2026-07-04 ### W5Payment Corridor DynamicsProbableconfirmed 2026-07-04▾# 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-brief · as of 4 July 2026 146 words · last cycle 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. An IMF Working Paper covering the CAPDR region finds a clear trend of declining remittance fees at any level of digitalization, though costs remain higher for CAPDR countries relative to other global regions — meaning Panama's dominant US-Panama retail corridor still carries an above-average cost burden even as digital channels expand. #### Outlook Panama's hub role looks structurally durable given dollarization and continued IBC deposit growth, but the CAPDR remittance-cost gap versus global benchmarks is unlikely to close quickly; corridor-level fee dynamics warrant continued tracking alongside the correspondent-access questions raised in W12. Read full sub-brief · 146 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T3[https://globallawexperts.com/how-to-open-a-fintech-company/](https://globallawexperts.com/how-to-open-a-fintech-company/)retrieved 2026-07-04 - T1[https://www.elibrary.imf.org/view/journals/001/2022/238/article-A001-en.xml](https://www.elibrary.imf.org/view/journals/001/2022/238/article-A001-en.xml) Applies beyond this jurisdiction (IMF)retrieved 2026-07-04 - T1[https://www.superbancos.gob.pa/en/node/1687](https://www.superbancos.gob.pa/en/node/1687)retrieved 2026-07-04 - T3[https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/](https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/)retrieved 2026-07-04 ### W6Industry Structure & CommercialProbableconfirmed 2026-07-04▾# 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-brief · as of 4 July 2026 127 words · last cycle 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. #### Outlook Bank-sponsored wallets are likely to retain their structural advantage absent a dedicated non-bank licensing pathway; Draft Law 314's fate is therefore also a market-structure variable, not only a compliance one, since a workable non-bank licence could lower the distribution barrier that defeated Tigo Money. Read full sub-brief · 127 words no periodic updates on record for this sub-brief Evidence 5 Sources and findings (5) - T3[https://www.centralamerica.com/investing/banking-in-panama/](https://www.centralamerica.com/investing/banking-in-panama/)retrieved 2026-07-04 - T3[https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/](https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/)retrieved 2026-07-04 - T3[https://newsroompanama.com/2024/04/27/banco-general-yappy-makes-an-important-update/](https://newsroompanama.com/2024/04/27/banco-general-yappy-makes-an-important-update/)retrieved 2026-07-04 - T3[https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/](https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/)retrieved 2026-07-04 - T2[https://www.trade.gov/country-commercial-guides/panama-trade-financing](https://www.trade.gov/country-commercial-guides/panama-trade-financing)retrieved 2026-07-04 ### W7Legal & LitigationProbableconfirmed 2026-07-04▾# 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-brief · as of 4 July 2026 134 words · last cycle 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. #### Outlook Both instruments together signal a more codified, legible enforcement posture from SBP, which should reduce litigation unpredictability going forward; a primary-text citation for Acuerdo 3-2026 should be sought next cycle to upgrade its sourcing above T3 secondary reporting. Read full sub-brief · 134 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T3[https://sb-sb.com/services/crypto/crypto-license/latam/panama/](https://sb-sb.com/services/crypto/crypto-license/latam/panama/)retrieved 2026-07-04 - T1[https://www.superbancos.gob.pa/en/sanciones?field_year_sancion_value=All](https://www.superbancos.gob.pa/en/sanciones?field_year_sancion_value=All)retrieved 2026-07-04 - T3[https://www.infobae.com/panama/2026/06/24/panama-pone-orden-a-la-forma-de-evaluar-los-incumplimientos-bancarios/](https://www.infobae.com/panama/2026/06/24/panama-pone-orden-a-la-forma-de-evaluar-los-incumplimientos-bancarios/)retrieved 2026-07-04 - T1[https://documents1.worldbank.org/curated/en/099040424151021308/pdf/P179962143f93d0531a2901588726639e71.pdf](https://documents1.worldbank.org/curated/en/099040424151021308/pdf/P179962143f93d0531a2901588726639e71.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-07-04 ### W8Merchant Acquiring & RiskProbableconfirmed 2026-07-04▾# 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-brief · as of 4 July 2026 126 words · last cycle 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. #### Outlook Merchant acquiring in Panama looks set to continue running on bank-affiliated rails blended with global PSP partnerships for cross-border acceptance, a structure that suits the tourism-heavy merchant base but leaves foreign PSPs dependent on local bank partnership as a market-access condition. Read full sub-brief · 126 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T2[https://www.bgeneral.com/yappy/](https://www.bgeneral.com/yappy/)retrieved 2026-07-04 - T3[https://jootser.com/pasarelas-de-pago-para-e-commerce-en-panama/](https://jootser.com/pasarelas-de-pago-para-e-commerce-en-panama/)retrieved 2026-07-04 - T3[https://payatlas.com/countries/panama-pa](https://payatlas.com/countries/panama-pa)retrieved 2026-07-04 - T3[https://payatlas.com/countries/panama-pa](https://payatlas.com/countries/panama-pa)retrieved 2026-07-04 ### W9Product Innovation & Market Development1 judgmentlimited signalProbableconfirmed 2026-07-04▾# 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. Key judgment — Probable · impact Panama's instant-payments market is advancing commercially (bank-led wallet aggregation) faster than its underlying licensing statute, which remains in draft form. claims: none recorded Standing sub-brief · as of 4 July 2026 134 words · last cycle 2026-10-25 #### 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. #### Outlook Instant-payments interoperability is on a clear expansionary trajectory, but the inclusion gaps in the most remote provinces suggest the benefits of Telered's Xpress rollout are concentrated in already-banked urban populations; closing the agency-banking and postal-channel gap remains an unresolved financial-inclusion question. Read full sub-brief · 134 words Periodic update · new data 2026-10-25 #### Product Innovation & Market Development Banistmo's integration of the Yappy, Kuara and Xpress digital-wallet rails into its own mobile banking application is the principal product-innovation development for Panama. Announced 9 October 2026, the integration extends phone-number-based send-and-receive payment functionality across participating banks to more than 600,000 customers, consolidating what had previously been separate wallet ecosystems into a single bank-hosted interface. This is a notable step in market-level interoperability: rather than customers needing separate applications for each wallet brand, a single bank app now bridges several rails, reducing friction for peer-to-peer and possibly merchant-directed payments within Panama's digital-payments ecosystem. The commercial terms of the arrangement among Banistmo, Yappy, Kuara and Xpress were not publicly disclosed, so the scale of investment or revenue-sharing behind the integration cannot be assessed from available reporting, but the customer-reach figure alone signals a product move large enough to shift usage patterns across Panama's retail digital-payments market. Alongside this bank-led consolidation, Banco Nacional de Panama continues to pursue a separate but complementary infrastructure development: a instant-payments rail designed for 24 hours a day, seven days a week continuous operation, with interoperability extended beyond banks to fintechs and cooperatives. This initiative was restated without a new procedural date attached, indicating it remains an active, standing development rather than a newly completed milestone. Read together, the Banistmo wallet integration and Banco Nacional's infrastructure push represent two distinct vectors, commercial aggregation at the bank level and public-infrastructure interoperability at the rail level, both moving toward the same broader outcome: a more interconnected, round-the-clock Panamanian payments ecosystem spanning banks, wallets, fintechs and cooperatives. The significance of these developments is sharpened by the fact that they are proceeding ahead of, rather than alongside, a settled licensing framework for non-bank payment and e-money participants. Panama's dedicated fintech and payments licensing statute, the Anteproyecto de Ley N.314, remains in draft form without a confirmed legislative debate date. This means wallet operators such as Yappy, Kuara and Xpress, along with cooperatives and fintechs that might eventually connect to Banco Nacional's interoperable rail, are participating in an increasingly interconnected commercial payments market while the formal supervisory perimeter that would eventually govern their activity as payment-service providers has not yet been enacted. The market is, in effect, building ahead of its own regulatory architecture. #### Outlook Further bank-led wallet aggregation of the kind Banistmo has pursued appears commercially plausible given the customer-reach and interoperability gains already demonstrated, and Banco Nacional's 24/7 interoperable rail remains, as scheduled, a standing initiative without a confirmed new completion date. The central open question for Panama's product-innovation trajectory is how long this commercial advance can continue to outpace the licensing statute: if the Anteproyecto de Ley N.314 remains stalled, non-bank participants such as fintechs and cooperatives may continue to be drawn into an increasingly interoperable payments ecosystem without a correspondingly clear supervisory framework attaching to their role in it. 2 earlier distinct update(s) Periodic update · new data 2026-09-28 #### Product Innovation & Market Development The SBP has expanded its Fintech Hub into a structured pre-filing channel, through which fintech applicants present payment-flow diagrams and AML control matrices to the regulator ahead of making formal applications to establish banking relationships. This development is reported at Uncertain confidence, and is characterised in reporting as functioning as a de facto prerequisite for fintech applicants seeking to open or sustain banking relationships in Panama during 2026, rather than as a formally codified legal requirement under any specific rule or statute. The Fintech Hub mechanism is procedural in nature: it does not itself create a new payment rail, product category, or instant-payments scheme, but instead functions as a market-development gate that shapes how fintech and payments innovators access the banking relationships their business models depend on. No dedicated instant-payments scheme or other novel payments-product development was identified in Panama this cycle. The Fintech Hub's significance for product innovation lies specifically in its function as an access-shaping mechanism: a fintech product or service that depends on a banking relationship for settlement, custody, or account provision must now, as a practical matter reported this cycle, pass through this pre-filing review before that relationship can be formalised, adding a procedural step to product-to-market timelines for payments and fintech innovators in Panama. #### Outlook Watch for whether the SBP formalises the Fintech Hub pre-filing channel into codified rule rather than informal practice, and for whether its expansion correlates with faster or slower fintech product launches in Panama relative to prior periods. The relationship between this pre-filing gate and the eventual Draft Law No. 314 licensing framework, if enacted, is also worth monitoring, since a formal licence category could either supersede or formalise the Hub's current gatekeeping role. Periodic update · new data 2026-09-14 #### Product Innovation & Market Development Panama's EMI, payment-institution, and PSP product categories remain in a state of regulatory limbo this cycle: neither expressly prohibited nor formally regulated under any dedicated instrument. This classification uncertainty is the structural backdrop against which Draft Law 314 was introduced, and one legal-commentary source, held at only uncertain confidence given its single-source status, characterises the pre-2026 environment for dedicated PSP and VASP regulation in stark terms, describing it as effectively a regulatory void for these product categories specifically. This characterisation should be read as commentary rather than confirmed regulatory fact, but it is consistent with the broader pattern visible across this cycle's Panama findings: a jurisdiction where non-bank payment product innovation has proceeded in the absence of a dedicated statutory framework, relying instead on general banking-sector rules applied indirectly wherever a fintech product touches the banking system. Draft Law 314's introduction is itself evidence that this gap has been recognised as a policy problem requiring a dedicated legislative response, even though that response remains at the consultation stage. #### Outlook The product-development question to watch is whether Draft Law 314, once and if it advances, resolves the EMI/PI/PSP classification uncertainty definitively, or whether it leaves residual grey areas for newer product categories not explicitly contemplated in the current draft. Until the framework is enacted, product innovation in Panama's non-bank payments space continues under the same classification ambiguity that has characterised the market to date. Evidence 4 Sources and findings (4) - T3[https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/](https://elcapitalfinanciero.com/nequi-y-yappy-se-disputan-clientes-bancarios-en-panama/)retrieved 2026-07-04 - T4[https://americaretail-malls.com/paises/centroamerica/panama-digital-el-93-de-la-poblacion-ya-usa-banca-movil/](https://americaretail-malls.com/paises/centroamerica/panama-digital-el-93-de-la-poblacion-ya-usa-banca-movil/)retrieved 2026-07-04 - T1[https://www.superbancos.gob.pa/documentos/evaluaciones_fmi/NT-SPN-Pagos-Panama-Payments-TN.pdf](https://www.superbancos.gob.pa/documentos/evaluaciones_fmi/NT-SPN-Pagos-Panama-Payments-TN.pdf)retrieved 2026-07-04 - T3[https://www.prensa.com/economia/yappy-nequi-zinli-y-ahora-kuara-compiten-en-el-mercado-de-los-pagos-digitales-en-panama/](https://www.prensa.com/economia/yappy-nequi-zinli-y-ahora-kuara-compiten-en-el-mercado-de-los-pagos-digitales-en-panama/)retrieved 2026-07-04 ### W10Consumer Protection & APP FraudProbableconfirmed 2026-07-04▾# 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-brief · as of 4 July 2026 140 words · last cycle 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. #### Outlook Without a statutory misdirected-payment or APP-fraud reimbursement rule, consumer protection for e-money customers will likely continue to depend on voluntary industry practice such as Yappy's refund feature rather than an enforceable regulatory entitlement, a gap Draft Law 314 does not appear to address directly. Read full sub-brief · 140 words no periodic updates on record for this sub-brief Evidence 4 Sources and findings (4) - T3[https://lawgratis.com/blog-detail/consumer-law-panama](https://lawgratis.com/blog-detail/consumer-law-panama)retrieved 2026-07-04 - T1[https://www.superbancos.gob.pa/en/sac/preguntas-frecuentes](https://www.superbancos.gob.pa/en/sac/preguntas-frecuentes)retrieved 2026-07-04 - T3[https://fmm.com.pa/panama-and-consumer-protection-in-the-digital-era/](https://fmm.com.pa/panama-and-consumer-protection-in-the-digital-era/)retrieved 2026-07-04 - T3[https://newsroompanama.com/2024/04/27/banco-general-yappy-makes-an-important-update/](https://newsroompanama.com/2024/04/27/banco-general-yappy-makes-an-important-update/)retrieved 2026-07-04 ### W11AML/CFT & Financial Crime (Sentinel.gi-fed)1 gapSourced from Sentinel.gi ↗limited signalConfirmedconfirmed 2026-07-04▾# 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. Open gap — wpm-int-1 No W11 AML/CFT source found this cycle; surface is Sentinel-fed/subscribed from financial-integrity. Merchant-acquiring ops, payment-corridor dynamics, and correspondent-banking access were structurally under-indexed this cycle. Standing sub-brief · as of 4 July 2026 184 words · last cycle 2026-10-18 #### 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. Sentinel.gi further reports that SBP Rule 1-2026 (16 January 2026) updates due-diligence, enhanced-due-diligence and transaction-monitoring obligations, and that Acuerdo 3-2026 (29 May 2026) codifies a graduated sanctions methodology — together consolidating Panama's post-delisting AML/CFT control architecture. WPM carries this only as provenance summary; original illicit-finance analysis is routed to FIM via cross-monitor flags rather than analysed here. #### Outlook Panama's AML/CFT architecture reads as consolidating rather than static: the delisting removed the external-pressure trigger, but SBP has since chosen to keep tightening domestic controls through Rule 1-2026 and Acuerdo 3-2026, an approach likely to continue improving Panama's standing with FATF-style peer review even as it narrows onboarding at the margin; full illicit-finance substance remains for FIM's review, not WPM's. Read full sub-brief · 184 words Periodic update · new data 2026-10-18 #### AML/CFT & Financial Crime This cycle's W11 signal is sentinel-fed: Panama's Unidad de Analisis Financiero (UAF), the country's financial intelligence unit, experienced a platform suspension affecting its capacity to process suspicious-transaction reporting. This is an uncertain-confidence signal drawn from the sentinel feed mechanism. Consistent with the sentinel-feed protocol for this module, the substantive analysis of the incident, including its scope, duration, and the volume of affected reporting subjects, is carried in the financial-integrity monitor's coverage rather than re-analysed here; this brief surfaces the signal as relevant to the payments sector's AML/CFT operating environment without duplicating that analysis. For payment-sector obligated entities operating in Panama, a disruption to the FIU's reporting-intake infrastructure is a relevant operational-environment fact: it indicates a period during which confirmation of suspicious-transaction-report receipt by the national authority may have been delayed or uncertain, independent of any change to the underlying statutory reporting obligation itself, which remains unaffected by the platform incident. #### Outlook Resolution of this item depends on confirmation from the financial-integrity monitor's primary coverage regarding restoration of UAF's reporting platforms; until such confirmation is available, payment-sector entities should treat the reporting-channel status as unresolved rather than assume normal processing has resumed. Evidence 6 Sources and findings (6) - T3[https://www.laestrella.com.pa/amp/economia/panama-endurece-las-reglas-de-prevencion-de-delitos-financieros-en-los-bancos-HH23530869](https://www.laestrella.com.pa/amp/economia/panama-endurece-las-reglas-de-prevencion-de-delitos-financieros-en-los-bancos-HH23530869)retrieved 2026-07-04 - 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. - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: regulatory-failure - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005) — Gap: capacity-deficit - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: legal-gap - T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: enforcement-absence ### W12Correspondent Banking, Settlement & AccessProbableconfirmed 2026-07-04▾# 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-brief · as of 4 July 2026 186 words · last cycle 2026-10-04 #### 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. Panama's FATF delisting was expected to improve correspondent relationships and credit-line access; SBP Rule 1-2026 now signals renewed compliance tightening toward US/European correspondents, likely producing narrower fintech-client onboarding even as academic research on the grey-listing episode finds de-risking was more selective than the sweeping-exit narrative suggests, a nuance corroborated by continued IBC deposit growth despite the tightening. #### Outlook The net direction for correspondent access is cautiously positive, but the two forces — post-delisting relief and Rule 1-2026 compliance tightening — will likely offset each other in the near term, with non-bank PSPs and EMIs most exposed to any narrowing since they lack the dedicated licensing standing that banks already hold; this asymmetry remains the module's central watch item. Read full sub-brief · 186 words Periodic update · new data 2026-09-28 #### Correspondent Banking, Settlement & Access The defining feature of correspondent and settlement access in Panama this cycle is the bank-versus-non-bank asymmetry that SBP Rule (Acuerdo) No. 1-2026 has sharpened. The rule, in force from 27 January 2026, tightens AML/CFT documentary requirements for account opening across all SBP-supervised entities, expressly revoking four prior regulations including Rules 10-2015, 1-2013 and 8-2000. Because the rule applies uniformly to SBP-supervised entities, it raises the documentary bar for any fintech, payment institution, or e-money issuer seeking to open or maintain a banking relationship in Panama, at the same time that Panama's banks themselves, as already-supervised entities, absorb the same tightened standard as an incremental compliance update rather than a market-access barrier. This dynamic is compounded by the SBP's expanded Fintech Hub pre-filing channel, through which fintech applicants must present payment-flow diagrams and AML control matrices before a formal banking-relationship application, reported as functioning as a de facto prerequisite for banking access in 2026. Together, Rule 1-2026 and the Fintech Hub pre-filing practice describe a correspondent-banking-access environment where non-bank payment institutions and e-money issuers face a materially higher documentary and procedural bar to establishing or sustaining the banking relationships their settlement operations depend on, compared to already-licensed banks navigating the same rule as an incremental update. #### Outlook The bank-versus-non-bank access asymmetry described here is likely to persist, and potentially deepen, for as long as Draft Law No. 314's dedicated PSP/EMI/VASP licensing framework remains unenacted; a functioning licence category could, if it materialises, change the terms on which non-bank entities approach banking relationships by giving them a recognised regulatory status distinct from general AML registration alone. 1 earlier distinct update(s) Periodic update · new data 2026-08-25 #### 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. Evidence 5 Sources and findings (5) - T1[https://documents1.worldbank.org/curated/en/099613104102429031/pdf/SECBOS1af572a90621b72716e27781ecaec.pdf](https://documents1.worldbank.org/curated/en/099613104102429031/pdf/SECBOS1af572a90621b72716e27781ecaec.pdf) Applies beyond this jurisdiction (World Bank)retrieved 2026-07-04 - T2[https://www.prnewswire.com/news-releases/panama-officially-removed-from-fatf-grey-list-301970490.html](https://www.prnewswire.com/news-releases/panama-officially-removed-from-fatf-grey-list-301970490.html)retrieved 2026-07-04 - T3[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/)retrieved 2026-07-04 - T1[https://www.superbancos.gob.pa/en/node/1687](https://www.superbancos.gob.pa/en/node/1687)retrieved 2026-07-04 - T4[https://ape.socialcatalystlab.org/papers/apep_1234/v1/paper.pdf](https://ape.socialcatalystlab.org/papers/apep_1234/v1/paper.pdf)retrieved 2026-07-04 ### W13Commercial Intelligence (M&A, Investment & Product)limited signalUncertainconfirmed 2026-07-04▾# 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. Standing sub-brief · as of 4 July 2026 179 words · last cycle 2026-10-25 #### 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. The standout 2026 market-development milestone is legislative rather than transactional: Panama's Anteproyecto de Ley No. 314 was introduced to the National Assembly on 13 January 2026, proposing dedicated licensing categories for VASPs, PSPs and EMIs for the first time — tracked here for commercial-intelligence context as a market-development event rather than a funding or M&A transaction. #### Outlook Commercial signal for Panama's fintech sector is modest and dashboard-tier this cycle, with the Draft Law 314 introduction the only material market-development event; individual funding and M&A deal-level detail remains structurally under-indexed given aggregator-only source coverage, a recognised bias-correction area for future cycles. Read full sub-brief · 179 words Periodic update · new data 2026-10-25 #### Commercial Intelligence & Fintech The sole discrete commercial event identified for Panama's payments sector is Banistmo's partnership integrating the Yappy, Kuara and Xpress wallet rails into its own mobile banking application, announced 9 October 2026. The parties to this arrangement are Banistmo as the host bank and Yappy, Kuara and Xpress as the integrated wallet platforms, all domiciled in Panama. The event is best characterised as a partnership rather than a merger or acquisition: no equity stake, acquisition structure or standalone funding round was disclosed, and the amount associated with the arrangement is not publicly disclosed. The commercial rationale, extending phone-number-based payment functionality to more than 600,000 customers across participating banks, positions the deal as a customer-reach and product-breadth play rather than a balance-sheet transaction, consistent with a wallet-sector consolidation move rather than a conventional financial-sector acquisition. This event sits within Panama's broader wallet sector, where separate digital-payment brands, Yappy, Kuara and Xpress, had previously operated with varying degrees of interoperability. By bringing three of these rails into a single bank-hosted application, Banistmo has effectively acted as an aggregator, a commercial pattern distinct from the structural, market-wide interoperability initiative Banco Nacional de Panama is separately pursuing through its 24/7 instant-payments rail project. Where Banco Nacional's initiative is infrastructural and aims at system-wide interoperability extending to fintechs and cooperatives, Banistmo's move is a specific, dated commercial integration decision by a single institution, the kind of discrete deal this commercial-intelligence module is designed to surface rather than analyse as a broader structural trend. No further commercial events, such as mergers, acquisitions, new funding rounds, or additional product launches beyond the Banistmo integration, were identified for Panama's payments sector. The absence of disclosed financial terms for the Banistmo-Yappy-Kuara-Xpress arrangement means the commercial scale of the deal, in terms of investment or revenue impact, cannot be quantified from available reporting; only the customer-reach figure of more than 600,000 provides a scale proxy. #### Outlook Given the commercial momentum already visible in Panama's wallet sector, additional bank-led integrations or partnerships bringing together currently separate digital-wallet brands appear plausible, though no specific further deal has been identified as pending. Should the financial terms of the Banistmo-Yappy-Kuara-Xpress partnership become disclosed in future reporting, that would allow a more complete commercial assessment of the arrangement's scale; until then, the event stands as a customer-reach-driven product partnership whose balance-sheet dimensions remain undisclosed. Evidence 3 Sources and findings (3) - T4[https://tracxn.com/d/geographies/panama/__M43a-AgsfK3LvgIGrffDKvH7UYcE9F8msaKUAD17KZg](https://tracxn.com/d/geographies/panama/__M43a-AgsfK3LvgIGrffDKvH7UYcE9F8msaKUAD17KZg)retrieved 2026-07-04 - T4[https://tracxn.com/d/explore/fintech-startups-in-panama/__yCpaKPFTlkZqAiiUSM-AyoXXfjbmrU1FCPMPyAFfEFs](https://tracxn.com/d/explore/fintech-startups-in-panama/__yCpaKPFTlkZqAiiUSM-AyoXXfjbmrU1FCPMPyAFfEFs)retrieved 2026-07-04 - T3[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/)retrieved 2026-07-04 No modules match. Filters combine as OR inside a group and AND across groups. 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