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Panama has no dedicated conduct-of-business or safeguarding regime for non-bank payment/e-money providers; consumer and conduct protection for banking relationships defaults to the SBP and ACODECO under general banking and consumer-protection law, with AML documentary/onboarding obligations tightened via SBP Rule 1-2026.
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.
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.
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)
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.
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.
Sources and findings (4 unique sources · R-3/R-4)
The SBP Board of Directors issued Rule 1 of 2026, dated 16 January 2026, updating provisions on customer due diligence, enhanced due diligence, transaction monitoring, and internal-control obligations of supervised entities, expressly revoking prior rules 10-2015, 1-2013, 8-2000, and 10-2000.
- [W1b-E2] 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 tightens AML/CFT documentary requirements for account opening and ongoing monitoring, and signals to correspondent banks that Panama is tightening controls, with banks likely to narrow the categories of fintech clients they onboard until compliance teams absorb the new standards.
- [W1b-E3] T1 Derived: Confirmed in_forcehttps://www.superbancos.gob.pa/en/sac/preguntas-frecuentes re-verified
Clients can file complaints against banks with the SBP directly or via a Complaint Form on its website, while ACODECO separately processes bank customer complaints on misleading advertising, credit records, and commercial matters such as warranties.
- [W1b-E4] T3 Derived: Probable in_forcehttps://www.infobae.com/panama/2026/06/24/panama-pone-orden-a-la-forma-de-evaluar-los-incumplimientos-bancarios/ re-verified
Acuerdo No. 3-2026 (29 May 2026) establishes uniform criteria for grading AML/CFT compliance breaches into minor, serious and very serious infractions, considering factors like duration, recidivism, harm caused, and institution size when graduating administrative sanctions.