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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.
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.
no periodic updates on record for this sub-brief
Sources and findings (4 unique sources · R-3/R-4)
- [W7-E1] T3 Derived: Probable draft_no_legal_forcehttps://sb-sb.com/services/crypto/crypto-license/latam/panama/ re-verified
In July 2023 Panama's Supreme Court declared the entire proposed crypto law (Bill 697) unconstitutional, siding with the President's veto objections and nullifying the country's first attempt at a comprehensive crypto framework.
- [W7-E2] T1 Derived: Confirmed in_forcehttps://www.superbancos.gob.pa/en/sanciones?field_year_sancion_value=All re-verified
The SBP publishes a register of concluded, administratively enforced pecuniary sanctions over B/.5,000 imposed under the Banking Law, Trust Law and AML/CFT/WMD Law, along with disqualifications barring individuals from managerial banking/trust positions.
- [W7-E3] 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) does not create new obligations but establishes clear, uniform criteria classifying AML/CFT infractions as minor, serious, or very serious, with aggravating factors including recidivism and lack of cooperation, and mitigating factors including voluntary correction.
- [W7-E4] T1 Derived: Confirmed in_forcehttps://documents1.worldbank.org/curated/en/099040424151021308/pdf/P179962143f93d0531a2901588726639e71.pdf re-verified
The competition agency's predecessor (CLICAC) took the Superintendency of Banks to court in 2004 after its request for banking-sector data was rejected, a case that went through multiple appeals and ended in the Supreme Court siding with the competition agency, illustrating longstanding ambiguity between banking and competition law.