Panama’s compliance framework is not a formality. Non-compliance is a business risk.
Panama’s AML/CFT regulatory framework — built through two decades of legislative reform and multiple rounds of FATF evaluation — imposes real obligations on a broad range of regulated entities: financial institutions, real estate companies, law firms, accountants, company service providers, precious metals dealers, and gaming operators, among others. The framework under Law 23 of 2015 and Law 129 of 2020 carries real consequences. SSNF sanctions, operational restrictions, and reputational damage are the practical outcomes of non-compliance. At Chanis, AML/CFT compliance is an area of deep institutional knowledge — built from years of advising regulated entities, designing compliance programs, and managing regulatory engagement with the SBN, the SMV, the SSNF, and the UAF.
- Compliance Program Design
- KYC/CDD Frameworks
- Transaction Monitoring
- AML Training & Officer Support
AML/CFT compliance counsel for regulated entities operating under Panama’s Law 23/2015 framework.
COMPLIANCE PROGRAM DESIGN & IMPLEMENTATION
An effective AML/CFT compliance program is not a template — it is a documented system calibrated to the specific risks of the business. Panama’s regulatory framework requires that compliance programs be comprehensive, risk-based, and maintained current. We design, implement, and update compliance programs for entities across the regulated sectors.
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- Compliance program design — financial and non-financial regulated entities
- Risk-based approach (RBA) framework implementation
- Program update following regulatory changes (Law 23, Law 129, decrees)
- Board and senior management AML governance frameworks
- AML/CFT policies and procedures manuals
- Compliance officer role structuring and designation
- Annual compliance program review and gap analysis
- Compliance program documentation for SSNF examination
KYC/CDD FRAMEWORKS
Know Your Customer (KYC) and Customer Due Diligence (CDD) are the operational backbone of AML compliance. The depth of diligence required — simplified, standard, or enhanced — depends on the risk profile of the customer, the jurisdiction, and the transaction. We design KYC/CDD frameworks that are proportionate, defensible, and practical for the regulated entity’s business model.
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- Customer identification and verification (CIV) procedures
- Politically Exposed Persons (PEP) screening processes
- Simplified due diligence criteria and documentation
- KYC refresh and periodic review procedures
- Beneficial ownership identification frameworks
- Enhanced Due Diligence (EDD) for high-risk customers and transactions
- Customer risk rating methodologies
- Digital onboarding and remote verification compliance
AML RISK ASSESSMENTS
Regulatory and business-level risk assessments are required by law and provide the foundation for a defensible compliance program. We conduct institutional risk assessments that identify, analyze, and document the money laundering and terrorism financing risks faced by the specific entity — and calibrate the compliance response accordingly.
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- Institutional ML/TF risk assessment (required under Law 23/2015)
- Product and service risk profiling
- Customer base risk segmentation
- National Risk Assessment alignment and gap analysis
- Sector-specific risk analysis — real estate, corporate services, financial services
- Geographic risk analysis for international operations
- Risk assessment documentation for regulatory presentation and examination
- Periodic risk assessment review and update
REGULATORY REPRESENTATION & FILINGS
Regulated entities in Panama are subject to ongoing obligations with the SSNF, the SBN, the SMV, and the UAF. We manage regulatory filings, respond to examinations, and represent regulated entities in administrative proceedings — from routine registry renewal through to formal sanctions defense.
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- Annual registry renewal with the Superintendencia de Sujetos No Financieros (SSNF)
- SSNF examination response and management
- Voluntary disclosure, regularization, and corrective action plans
- Sanctions defense and penalty mitigation strategy
- UAF reporting obligations — Suspicious Transaction Reports (STRs)
- Administrative proceedings before the SSNF
- Representation before the SBN and SMV on AML matters
- Coordination with UAF on reporting obligations and guidance requests
TRANSACTION MONITORING & RED FLAG ANALYSIS
Effective transaction monitoring requires documented systems, trained personnel, and clear review procedures. When red flags arise — structuring patterns, PEP involvement, unusual transaction activity — the response must be documented, proportionate, and timely. We advise on monitoring frameworks and support compliance officers in managing specific situations.
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- Transaction monitoring framework design and implementation
- Suspicious transaction analysis and STR filing support
- Correspondent banking and cross-border payment monitoring
- Technology-assisted monitoring implementation guidance
- Red flag identification and documentation procedures
- Cash transaction reporting compliance
- Coordination with internal audit and compliance committee
- Post-incident review and program remediation
AML TRAINING & OFFICER SUPPORT
Compliance programs are only as effective as the people implementing them. The designated Compliance Officer carries direct regulatory exposure and requires legal support that is responsive and technically precise. We provide training programs for compliance officers and operational teams, and ongoing advisory support on specific situations as they arise.
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- AML/CFT training for compliance officers and senior management
- Compliance officer regulatory exposure — advisory and protection
- Internal audit support for AML compliance reviews
- Annual refresher training — updated for current regulatory requirements
- Operational staff training by risk category and business function
- Ongoing advisory support on specific compliance situations
- New employee AML onboarding programs
- Training documentation for SSNF examination purposes
Panama’s AML/CFT framework is not static. Neither is our advice on it.
Since Law 23 of 2015 was enacted, the framework has been amended, expanded, and interpreted through executive regulations, FATF guidance, and successive rounds of international review. We have practiced in this framework continuously — advising regulated entities through each wave of change. Our AML/CFT practice is not a standalone compliance department: it is part of the same integrated legal team advising on corporate structure, transactions, and regulatory strategy. When an AML issue intersects with a deal, a restructuring, or a regulatory investigation, the same team handles it.
INSTITUTIONAL DEPTH
Twenty years in Panama’s AML framework
We have advised regulated entities through every major amendment to Panama’s AML/CFT framework — from the original Law 42 through Law 23 of 2015, Law 129 of 2020, and successive regulatory decrees.
INTEGRATED PRACTICE
AML/CFT embedded in corporate and transactional work
When a transaction involves a regulated entity, when a real estate client has SSNF obligations, or when an M&A target requires AML due diligence, the compliance analysis is part of the same engagement.
REGULATORY RELATIONSHIPS
Direct engagement with Panama’s AML supervisors
We have represented regulated entities before the SSNF, the SBN, the SMV, and the UAF. We know how the regulators work and how to engage constructively in administrative proceedings.
Let’s talk about your matter.
Schedule a consultation with our team – a direct conversation about your business and what you need.
