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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.
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.
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.
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)
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.
The item to watch next cycle is whether any Tier-1 source corroborates or rebuts the Colón Free Zone transshipment characterisation. Absent that, correspondent banks are likely to continue treating the allegation as a live de-risking input. A second item is whether Panama's improving AML supervisory architecture begins to visibly offset correspondent-banking caution specific to the Colón Free Zone, though no evidence of that offset was available this cycle.
Sources and findings (5 unique sources · R-3/R-4)
- [W12-E1] T1 Derived: Confirmed in_forcehttps://documents1.worldbank.org/curated/en/099613104102429031/pdf/SECBOS1af572a90621b72716e27781ecaec.pdf re-verified
As Panama does not have a central bank, BNP plays the role of the main settlement bank and operator of the country's most important settlement system (the BNP clearinghouse), with final settlement of net retail-payment positions effected in commercial bank money on BNP's books.
- [W12-E2] T2 Derived: Confirmed in_forcehttps://www.prnewswire.com/news-releases/panama-officially-removed-from-fatf-grey-list-301970490.html re-verified
Panama's removal from the FATF grey list was expected to lead to a significant improvement in relations between Panama's local banks and their international correspondents, and to more accessible lines of credit.
- [W12-E3] T3 Derived: Probable in_forcehttps://globallawexperts.com/panama-fintech-law-2026-draft-law-no-314-sbp-rule-1-2026-licensing-aml-and-bank-access/ re-verified
SBP Rule 1-2026 signals to correspondent banks, particularly in the United States and Europe, that Panama is tightening controls, with the likely practical effect being a period of increased caution and narrower fintech-client onboarding by Panamanian banks.
The International Banking Center's deposits reached a total balance of USD 118,204 million as of February 2026, a year-on-year increase of USD 8,005.9 million (7.27%), reaffirming Panama's role as a regional platform for savings, investment and cross-border banking access.
- [W12-E5] T4 Derived: Uncertain in_forcehttps://ape.socialcatalystlab.org/papers/apep_1234/v1/paper.pdf re-verified
Empirical research on Panama's grey-listing episode finds correspondent-banking de-risking was more selective than the sweeping narrative suggests: large, established international banks with strong compliance infrastructure retained relationships, while marginal players exited.