Recent Regulatory Changes for Panamanian Private Companies (SA and SRL): 2023–2025

Overview

Panama has undergone significant regulatory changes affecting its sociedad de responsabilidad limitada (SRL) and sociedad anónima (SA) during 2023–2025, driven by its exit from the FATF grey list, removal from EU AML lists, and the continued rollout of beneficial ownership and accounting record requirements.

1. FATF Delisting (October 2023)

Panama was removed from the FATF grey list in October 2023 following the completion of its action plan addressing strategic AML/CFT deficiencies. The delisting reversed enhanced due diligence requirements that international financial institutions had applied to Panamanian entities.

2. EU AML Delisting (July 2025)

Panama was removed from the EU's list of high-risk third countries for AML/CFT purposes in July 2025, following a Commission assessment confirming alignment with EU standards. This removes the additional due diligence burden on EU-based financial institutions transacting with Panamanian companies.

3. Executive Decree 177/2024 — Accounting Records

Executive Decree 177 of 2024 reinforced the obligation for Panamanian legal entities to maintain accounting records and underlying documentation. Records must be kept for a minimum of 5 years, maintained in Panama or at the registered agent's office (or another specified jurisdiction), and must be sufficient to explain transactions and the financial position of the entity. The registered agent is responsible for ensuring compliance.

4. RUBF — Beneficial Ownership Register

Law 129 of 2020 established the Registro Único de Beneficiarios Finales (RUBF), maintained by the Superintendencia de Sujetos No Financieros (SSNF). Registration is mandatory for all Panamanian SAs and SRLs. The threshold is more than 25% of shares or voting rights, or actual control. The SSNF issued updated guidance circulars in 2024–2025 clarifying verification obligations and penalties for non-compliance.

Summary of Key Legislative Instruments