Panama

Licensing, Authorisation & Market Access

Panama's licensing and market-access architecture for payments tightened at the bank-sector level this cycle without any corresponding advance at the non-bank level. SBP Acuerdo No. 1-2026, dated 16 January 2026, repeals the prior Acuerdo 10-2015 and updates due diligence obligations attaching to remote and digital-channel client onboarding, applying to banks, fiduciary companies and payment or e-money issuers alike. For firms using digital or remote channels to open accounts or contract financial services, this raises the bar for the onboarding controls a licence-holder must demonstrate, a market-access-adjacent development insofar as it changes what a firm must show to serve customers through those channels rather than changing who may be licensed in the first place.

The larger market-access question for Panama's payments sector remains unresolved: Anteproyecto de Ley 314 would introduce the jurisdiction's first dedicated licensing regime for payment service providers, electronic-money institutions and virtual-asset service providers, under joint prudential supervision by SBP and anti-money-laundering oversight by the Unidad de Analisis Financiero, together with a regulatory sandbox mechanism. As of the most recent dateable reporting, from around April 2026, the bill remained in Asamblea Nacional committee review, having completed only its introduction phase; committee review, two plenary debates and presidential assent would all still need to occur before enactment. No confirmed progression was found dated within the current reporting window, and that absence of confirmed movement should be read as an information gap rather than as evidence the bill has stalled or advanced. Until Anteproyecto 314 is enacted, non-bank payment and e-money firms seeking to operate in Panama continue to do so without a purpose-built licensing framework distinct from the bank-centric regime the 2026 Acuerdos now update.

Outlook

The marker to track for Panama's licensing and market-access environment is whether Anteproyecto de Ley 314 moves out of committee review toward plenary debate; its current stalled status, last confirmed dated around April 2026, means the timeline to enactment remains genuinely open rather than merely delayed. In the interim, the practical effect of Acuerdo No. 1-2026 on digital-onboarding market access for banks, fiduciaries and payment and e-money issuers will depend on how SBP supervises implementation of the updated due-diligence standard, a question current reporting cannot yet answer given the instrument's recency.

Licensing, Authorisation & Market Access

Panama's licensing landscape for payments and digital-asset businesses is at a genuine inflection point. Draft Law No. 314, filed with the National Assembly on 13 January 2026, proposes Panama's first dedicated licensing framework covering payment service providers, e-money issuers, and virtual-asset service providers, placing all three categories under joint supervision by the Superintendencia de Bancos de Panamá (SBP) and the Unidad de Análisis Financiero (UAF). Prior to this proposal, Panama had no unified regime of this kind; non-bank payment institutions and e-money issuers operating in Panama have generally done so under general corporate and AML obligated-entity registration rather than under a purpose-built licensing category, and virtual-asset businesses have operated in a similar regulatory gap.

While Draft Law No. 314 remains at the proposed stage before the legislature, the practical licensing and onboarding environment has already been reshaped by SBP Rule (Acuerdo) No. 1-2026, in force from 27 January 2026. This rule expressly revokes four prior regulations, Rules 10-2015, 1-2013 and 8-2000 among them, and tightens AML/CFT documentary and customer-due-diligence obligations across the full population of SBP-supervised entities. Because this rule applies to bank and non-bank PSP/EMI entities alike wherever they fall under SBP supervision, it functions as a de facto tightening of the market-access bar even in the absence of the dedicated PSP/EMI/VASP licensing category that Draft Law No. 314 would create. The distinction between bank and non-bank supervised entities matters here: a bank entering this documentary regime does so as an already-licensed and long-supervised entity, while a non-bank PI or EMI applicant faces the same tightened documentary bar as a threshold matter for any future licensing application, without yet having a dedicated licence category to apply for.

Outlook

The central market-access question is the pace and outcome of Draft Law No. 314's legislative progress; current expectations point to a 2027 timeframe at the earliest, with no confirmed committee stage this cycle. Until enactment, market access for non-bank payment and virtual-asset businesses in Panama will continue to run through the combination of general AML registration and SBP Rule 1-2026's tightened documentary standard, rather than through a dedicated licence.

Licensing, Authorisation & Market Access

Panama's payments licensing landscape saw two material developments this cycle, both pointing toward a formalisation of a previously undefined regulatory space. Draft Law 314, the Ley Marco Integral de Tecnologías Financieras, introduced 13 January 2026, would establish Panama's first dedicated licensing categories for payment-service providers, electronic-money issuers, and virtual-asset service providers. This is a market-access-defining development: today, none of these categories has a dedicated licensing pathway, meaning non-bank payment providers operate in a space defined more by what is not prohibited than by what is affirmatively authorised.

Separately, and already in effect, the Superintendencia de Bancos de Panamá published Rule 1-2026 on 27 January 2026, tightening AML/CFT documentary requirements for bank account opening and ongoing monitoring. This is a bank-side instrument in form, but its market-access consequence for non-bank payment institutions and EMIs is direct: since Panama has no dedicated non-bank licensing regime today, PSPs and EMIs seeking to operate depend on banking relationships, and any tightening of the documentary bar for account opening raises the practical bar for market entry via the bank-access channel that currently substitutes for a dedicated licence. The bank-PSP versus non-bank-PI/EMI distinction is therefore central to this module this cycle: banks face a documentary-tightening obligation directly, while non-bank PSPs and EMIs face the same tightening indirectly, as a precondition of the banking access they currently rely on in the absence of their own licensing track.

Outlook

Draft Law 314 remains at the consultation stage with an estimated 2027-Q1 impact window carrying year-level uncertainty. The key question for market access is whether the eventual licensing framework will create a standalone non-bank licensing pathway that reduces dependence on the bank-access channel, or whether banking-relationship dependency persists even after formal licensing categories exist.

Licensing, Authorisation & Market Access

Panama's payments-market-access environment is undergoing simultaneous change on two distinct tracks. Anteproyecto de Ley 314, presented to the Asamblea Nacional plenary on 13 January 2026 by Deputy Ernesto Cedeno Alvarado, proposes distinct licence types for payment service providers, virtual-asset service providers, and PSP-like intermediaries, with capital and governance requirements calibrated proportionally to risk, under joint supervision by the Superintendencia de Bancos de Panama (SBP) for prudential matters and the Unidad de Analisis Financiero (UAF) for AML/CFT matters. This is assessed with probable confidence from a Tier-3 legal-commentary source and remains at an early legislative stage: the bill requires committee review and two further plenary debates plus presidential assent before taking effect, corroborated by an independent Tier-3 source describing the same filing and legislative posture.

Separately, and already in force, SBP Rule 1-2026 requires banks to collect enhanced evidence of economic activity, beneficial ownership, and source of funds before account opening. This is a confirmed, Tier-1 primary-source finding directly sourced from the regulator itself, and it has immediate practical effect on how non-bank payment institutions and e-money issuers access Panamanian banking rails, independent of and preceding any dedicated licensing framework Bill 314 might eventually establish. The bank-or-nonbank distinction is significant here: Rule 1-2026 formally applies to banks' own account-opening practices, but its effect flows through directly to the nonbank PSPs and EMIs seeking to bank with them, tightening market access for that segment ahead of any dedicated licence category existing for them.

This combination reflects and updates the standing characterisation of Panama's fintech regulatory environment as a 'legal nothingness', a patchwork of general banking and AML statutes without a dedicated PSP, EMI, or VASP framework. That characterisation, assessed with probable confidence, remains accurate as of this cycle in the sense that no dedicated licence category yet exists, but the picture is now one of a regulatory gap actively being addressed on two fronts simultaneously: immediate, already-effective tightening of the terms under which nonbank entities can access bank accounts, and a proposed, not-yet-enacted structural fix in the form of Bill 314's tiered licensing regime.

The proposed licensing structure's risk-proportionate design merits note for its market-access implications specifically. By differentiating capital and governance requirements across PSP, VASP, and PSP-like intermediary categories rather than applying a single uniform bar, the bill's design would potentially lower the market-access threshold for smaller or lower-risk payment intermediaries relative to a one-size-fits-all licensing standard, while still imposing a supervisory perimeter that does not currently exist. This is a design observation drawn directly from the bill's proposed structure rather than an independent judgment about its likely effect.

Outlook

The committee-stage progression of Anteproyecto de Ley 314 is the primary item to watch for Panama's licensing and market-access landscape, with an expected impact window in the fourth quarter of 2026 carrying a half-year uncertainty band given the bill's early stage and the multiple further legislative steps required. In the interim, the practical market-access reality for nonbank payment institutions is shaped more immediately by SBP Rule 1-2026's already-effective account-opening documentary tightening than by the still-pending licensing bill. A primary-source gap remains: the Asamblea Nacional's own hosting of Bill 314's text was not independently fetched this cycle, meaning the bill's precise legislative language has not been directly verified against a Tier-1 source.

Licensing, Authorisation & Market Access

Panama's payments-licensing landscape is currently defined by absence: there is no enacted licensing regime specific to payment service providers, electronic-money institutions, or virtual-asset service providers. Non-bank payment activity — illustrated by an estimated eighteen registered remittance companies — operates under the general money-services-business framework rather than under a dedicated PSP/EMI licensing statute. This gap is the backdrop against which Draft Law No. 314, introduced in the National Assembly on 13 January 2026, should be read: the draft would create Panama's first dedicated licensing regime for PSPs, EMIs and VASPs, placing them under Superintendencia de Bancos de Panamá supervision with Unidad de Análisis Financiero suspicious-activity-report intake. Commentary on the draft indicates it would additionally impose capitalisation and governance standards on newly licensed entities. As a draft moving through the legislative process, its provisions are not yet binding, and its practical timeline is assessed as multi-year and uncertain.

On the bank side of the licensing ledger, a distinct but related development occurred: SBP Rule 1-2026 tightened AML/CFT documentary requirements for account opening and ongoing monitoring. This is a bank/PSP-side supervisory tightening, formally distinct from the non-bank PSP/EMI/VASP licensing gap that Draft Law No. 314 targets, but material to market access in practice, because non-bank payment and crypto firms in Panama depend on correspondent and business-banking relationships with SBP-supervised banks to operate.

The bank-versus-non-bank distinction is therefore the organising fact for this module this cycle. Banks and their PSP relationships are governed by an increasingly formalised, actively tightening AML/CFT documentary regime under direct SBP supervision. Non-bank PSPs, EMIs and VASPs, by contrast, remain outside any dedicated licensing perimeter, governed only by the general MSB framework and by whatever conditions their banking relationships impose. Draft Law No. 314 would collapse this asymmetry by bringing non-bank entities into a comparable direct-supervision structure, but until enactment the asymmetry is the operative market-access reality for any prospective non-bank payments entrant into Panama.

Outlook

The single most consequential development to track next cycle is legislative progress on Draft Law No. 314: whether it advances through further Assembly debate, is amended, or stalls. Its current proposed-stage, multi-year uncertainty band means market entrants planning around a licensed PSP/EMI/VASP pathway in Panama should not assume near-term availability of that pathway. In the interim, entrants relying on the existing MSB framework, or on banking relationships with SBP-supervised institutions, should expect those banking relationships to be subject to the tightening documentary standard introduced by SBP Rule 1-2026.

Licensing, Authorisation & Market Access

Act 7 of 2025 (SB 202) is the structural licensing development for Pennsylvania this cycle: it extends Money Transmitter Act licensure to virtual-currency transmission conducted for a fee, effective August 26, 2025. This closes a licensing gap that had previously allowed fee-based virtual-currency transmission to operate outside the state's money-transmission licensing perimeter, and it is a high-confidence, Tier 1 finding corroborated by both the Pennsylvania Department of Banking and Securities' own announcement and the Pennsylvania Bulletin's statutory text. As a market-access matter, the change is squarely nonbank-PI/EMI-facing: bank-chartered payment service providers in Pennsylvania already operate under a distinct prudential supervisory track, so Act 7's extension of licensure to virtual-currency transmission principally affects nonbank payment institutions and electronic-money issuers offering virtual-currency transmission services, bringing them onto the same licensing, examination, and ongoing-compliance footing as fiat money transmitters rather than an unlicensed or ambiguously licensed model.

The underlying statute was renamed to the Money Transmission and Virtual Currency Transmission Business Licensing Law, with expanded definitions and exemptions, including a self-hosted-wallet carve-out and a business-entity transaction exemption; neither exemption type maps cleanly onto a standard licensing-exemption enum, which itself signals how bespoke Pennsylvania's carve-outs are relative to more standardized state virtual-currency licensing regimes elsewhere. This is a high-confidence, Tier 1 finding corroborated by law-firm secondary commentary. In parallel, Pennsylvania rescinded 10 Pa. Code Section 19.1a, its prior non-binding Virtual Currency Statement of Policy, in its entirety, effective the same date, on the basis that the guidance had become redundant once Act 7's statutory coverage took effect; this is a lifecycle transition from interpretive guidance to a licensing statute carrying enforcement consequences, and it is itself a high-confidence, Tier 1 finding. This is a standing-brief content-tier item rather than a dated dashboard entry, reflecting that Act 7 is a durable statutory change to the state's licensing perimeter rather than an episodic dashboard-level event, and market-access questions for virtual-currency transmission in Pennsylvania now rest on that statutory text rather than on the withdrawn policy statement.

Outlook

The practical significance of Act 7 for market access will be measured over coming cycles less by the statutory text itself, which is now settled and in effect, than by how the Department of Banking and Securities applies the new licensing perimeter in practice: whether virtual-currency transmitters previously operating in the state without a money-transmitter licence come forward to obtain one, and whether the self-hosted-wallet and business-entity exemptions are interpreted narrowly or broadly in early licensing determinations. No enforcement or licensing-decision data specific to the new virtual-currency transmission category has yet been reported this cycle; that is the next materiality threshold to watch for Pennsylvania's nonbank payment-institution and electronic-money-institution market-access conditions.

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.

Outlook

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.

Product Innovation & Market Development

Panama's EMI, payment-institution, and PSP product categories remain in a state of regulatory limbo this cycle: neither expressly prohibited nor formally regulated under any dedicated instrument. This classification uncertainty is the structural backdrop against which Draft Law 314 was introduced, and one legal-commentary source, held at only uncertain confidence given its single-source status, characterises the pre-2026 environment for dedicated PSP and VASP regulation in stark terms, describing it as effectively a regulatory void for these product categories specifically.

This characterisation should be read as commentary rather than confirmed regulatory fact, but it is consistent with the broader pattern visible across this cycle's Panama findings: a jurisdiction where non-bank payment product innovation has proceeded in the absence of a dedicated statutory framework, relying instead on general banking-sector rules applied indirectly wherever a fintech product touches the banking system. Draft Law 314's introduction is itself evidence that this gap has been recognised as a policy problem requiring a dedicated legislative response, even though that response remains at the consultation stage.

Outlook

The product-development question to watch is whether Draft Law 314, once and if it advances, resolves the EMI/PI/PSP classification uncertainty definitively, or whether it leaves residual grey areas for newer product categories not explicitly contemplated in the current draft. Until the framework is enacted, product innovation in Panama's non-bank payments space continues under the same classification ambiguity that has characterised the market to date.

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.

Outlook

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.