Published and draft legislation - Panama

Anti-Money Laundering and Terrorism Financing obligations

Circular SBP 169/2015 and SBP 182/2015

By virtue of Law 23/2015, 27th April, analysed in Progresso 3, and the subsequent approval of Agreement 005/2015, 26th May, mentioned in Progreso 4, concerning measures that financial institutions and other identified persons must comply with concerning Know-your-Customer and/or Final Beneficiary Policy to prevent Money Laundering and Financing Terrorism, and other related crimes, the Panamanian Banking Supervisor (SBP) issued the following circulars:

Circular SBP/DPC/FINAN/0169/2015

It asks financial companies to submit Manuals, Programmes, Policies, Procedures and any other information used to Prevent Money Laundering and the Financing of Terrorism and their respective up-dates.

Financial institutions have until 15th February 2016 to submit this information to the banking regulator in PDF format on a Compact Disc.

Circular SBP/DPC/FINAN/0182/2015

This requires companies to send their 2014 and 2015 Financial Statements and Income Statements to the SBP by 31st March 2016. Furthermore, from 2016, financial institutions must submit their internal Financial Statements quarterly and their audited Financial Statements annually.

It is important to highlight that it remains mandatory for financial institutions to submit their Financial Statements, audited by an authorised chartered accountant, to the regulator, the Ministry of Trade and Industry’s Department of Financial Institutions, within four (4) months of the close of the financial year.

 Greater supervision

These initiatives mark the first steps in migrating to more stringent banking supervision, a major challenge for financial institutions in Panama, which will have to adapt and/or up-date their internal controls and procedures.