Are you aware of the new due diligence rules applicable to corporate structures in Panama 2026?

The recently issued Agreement No. 1-2026 of the Superintendency of Banks of Panama (SBP) comprehensively updates the standards applicable to the prevention of money laundering, terrorist financing, and the financing of the proliferation of weapons of mass destruction (AML/CFT/CPF).

The reform strengthens the risk-based approach and requires financial institutions to conduct a more rigorous, dynamic, and documented assessment of their clients and corporate structures.

1. Periodic Updating of Client Files

The client's risk classification determines the minimum frequency for updating the relevant information:

High Risk: every 12 months
Medium Risk: every 24 months
Low Risk: every 48 months

2. Greater Scrutiny in the Identification of the Ultimate Beneficial Owner

The 10% ownership or voting rights threshold for identifying the ultimate beneficial owner remains in place. However, the regulation provides greater detail regarding ownership and control chains applicable to different legal structures, including trusts, private interest foundations, and companies undergoing liquidation.

Simplified due diligence is also excluded, among other circumstances, when:

• The ultimate beneficial owner cannot be identified through traditional share ownership.
• The company uses nominee directors or officers provided by a resident agent.
• The entity is a foreign legal entity.

3. Significant Sanctions 

Failure to comply with these regulatory standards may result in fines of up to B/.5,000,000.00, in addition to potential liability for directors and executive officers responsible for compliance-related functions within supervised institutions.

What does this mean for companies and asset-holding structures?

Companies, foundations, and other legal structures must maintain updated and properly supported information regarding their ownership, control, ultimate beneficial owners, business activities, and source of funds.

In today's regulatory environment, having a corporate structure is not enough: due diligence and transparency of the structure are essential elements for maintaining an appropriate banking and financial relationship.

MOLINA & CO.
Corporate legal services, compliance, asset structuring, and financial law.

For professional inquiries, please contact our legal team.