title: PA — AML/CFT & Financial Crime (W11) | World Payments Monitor canonical: https://payments.gi/jurisdictions/panama/w11/ ### W11 AML/CFT & Financial Crime (Sentinel.gi-fed) [Sourced from Sentinel.gi ↗](https://sentinel.gi/jurisdictions/panama/#sec-dom-D7) limited signal Probable re-verified 2026-10-18 · changed 2026-10-18 sentinel.baseline: Panama's core AML/CFT instrument is Law 23 of 2015 (as amended), supervised by the SBP for financial obligated subjects and enforced via the newly codified Acuerdo 3-2026 sanctions methodology; Panama was FATF grey-listed June 2019 and formally delisted 27 October 2023, with the EU following in removing Panama from its high-risk list in 2024/2025. Standing sub-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 Sentinel (sentinel.gi) 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 Sentinel (sentinel.gi)'s review, not WPM's. 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. 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. **Coverage Gaps (`not_examined` model · S-1)**4 deficiency record(s) separated from substantive evidence - not_examined Gap: regulatory-failure (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002)) - not_examined Gap: capacity-deficit (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-005)) - not_examined Gap: legal-gap (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003)) - not_examined Gap: enforcement-absence (Sentinel (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001)) ** Sources and findings (2 unique sources · R-3/R-4)** 1. [W11-E1] T3 Derived: Probable [in_force 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) re-verified 2026-07-04 sentinel.enforcement: Acuerdo No. 3-2026 (29 May 2026) establishes new criteria for imposing and grading administrative sanctions on banks for AML/CFT/proliferation-financing breaches, strengthening legal certainty, transparency and objectivity in the SBP's sanctioning process. 2. [W11-E2] T2 Derived: Probable [in_force Sentinel (sentinel.gi) per-JID baseline profile — Panama](https://globallawexperts.com/panama-fintech-law-2026-draft-law-no-314-sbp-rule-1-2026-licensing-aml-and-bank-access/) re-verified 2026-07-04 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.