SSNF Compliance in Panama: Without the Headaches
COX helps non-financial obligated entities meet essential due diligence, risk assessment, and compliance documentation requirements under Panama's AML regulatory framework.
This information is provided for general informational purposes and does not constitute legal advice.
What is the SSNF?
Panama's Superintendencia de Sujetos No Financieros (SSNF), created as an autonomous body by Law 124 of 2020, supervises and regulates non-financial obligated entities to prevent:
This information is provided for general informational purposes and does not constitute legal advice.
Panama AML Regulator
for Non-Financial Entities
Legal Framework
Key laws and regulations governing SSNF compliance
Law 23 of April 27, 2015
Establishes the legal foundation for Panama's AML/CFT framework and defines the obligations of non-financial regulated entities supervised by the SSNF.
Law 254 of November 11, 2021
Strengthens corporate transparency requirements in Panama, including obligations related to accounting records and beneficial ownership information for legal entities.
Executive Decree 35 of September 6, 2022 Key Update
Operationalizes Law 23 by requiring non-financial obligated entities to implement risk-based AML/CFT controls, maintain documented compliance policies, and generate auditable records for SSNF supervision.
Verify current text of regulations at the official Panama government portal. Laws may have been amended since publication.
Who Are Non-Financial Obligated Entities?
Organizations and professionals regulated by the SSNF in Panama
- Colón Free Zone companies
- Panama Pacífico entities
- Free trade zone companies
- Casinos and gambling operators
- Real estate developers and brokers
- Construction companies
- Value transport companies
- Pawn shops
- Precious metals and gemstone traders
- National lottery entities
- Postal services
- Vehicle dealerships
- Professionals performing regulated activities (lawyers, CPAs, notaries)
Sector Rules and Recent Resolutions
The SSNF adds sector rules and resolutions to Law 23 of 2015 and Executive Decree 35 of 2022
Casinos and Gaming
Agreement JD-01-2025, in force since 23 February 2026Basic due diligence from B/.2,000 per transaction; enhanced due diligence for cash transactions of B/.10,000 or more and for every transaction of a PEP. A weekly Multiple Transactions Report (RTM) and the cash transaction report to the UAF within the first 10 business days of each month. It repealed Resolution JD-005-015.
Lawyers and Certified Public Accountants
Agreement JD-02-2022When they carry out supervised activities for a client: their own risk assessment, reviewed at least once a year; enhanced due diligence for cash over B/.10,000, nominee services, PEPs and high-risk jurisdictions; the beneficial owner from 25%; and, for nominee services, an annual sworn statement to the SSNF within the first 15 calendar days of July.
Car Dealers
Agreement JD-001-2026, in force from 9 December 2026New guidelines for companies that buy and sell new and used cars: due diligence, beneficial owner, PEPs, cash transaction reports, unusual operations, suspicious operation reports to the UAF, manual, training and a liaison. It repeals Resolution JD-004-015 from that date.
Prevention Manual, Every Sector
Resolution S-037-2026, in force from 10 November 2026Adopts the Practical Guide for the prevention manual as the mandatory minimum standard that every non-financial obligated entity must build into its manual. It repeals Resolution I-REG-001-017 of 2017.
UN Lists and Preventive Freezing, Every Sector
Resolution S-033-2026, in force since 30 June 2026Only the UN Security Council lists are binding: a match means freezing without delay, with no prior court order. The OFAC, European Union, United Kingdom and other lists are control or reference lists that feed the risk assessment. For a legal entity, the check covers its beneficial owners, partners holding 25% or more, directors, officers, attorneys and legal representatives.
Pawn shops, value transport, precious metals and the other sectors have their own SSNF rules. This page does not reproduce their thresholds: check the current text of the rule for your activity on the SSNF website.
Customer Due Diligence Requirements
Minimum compliance controls required for SSNF-regulated entities
Standard Due Diligence
- Customer identification and identity verification
- Beneficial owner identification for corporate clients: every individual holding 25% or more, per Executive Decree 35/2022
- Documentation of the purpose of the business relationship
- Transaction monitoring based on customer risk profile
- Maintenance of compliance documentation for regulatory review
Enhanced Due Diligence (EDD)
Required when a customer is identified as a higher-risk profile:
- Politically Exposed Persons (PEPs): current or former holders of prominent public functions
- Close relatives of PEPs: family members within prescribed degree of relationship
- Key associates of PEPs: persons with close business or personal relationships
How COX Supports SSNF Compliance
Practical tools to implement required AML controls efficiently
Digital Onboarding
Send customers a secure digital form to collect identification documents, contact data, and source of funds information: all without paper.
Compliance Workflow Automation
Configure onboarding workflows that match your sector's SSNF requirements. Approvals, document checklists, and escalation paths are managed systematically.
Risk Matrix Configuration
Define risk scoring rules based on customer profile, sector, geographic origin, and transaction patterns. Automatically classify customers as low, medium, or high risk.
Customer Compliance File
Each customer record consolidates identification documents, screening results, risk scores, and due diligence decisions in a single exportable compliance file.
Audit-Ready Documentation
Every action is logged with user identity and timestamp. Compliance logs are immutable and structured to support SSNF inspection and internal audit processes.
Watchlist and AML Screening
Screen customers against international sanctions databases, PEP lists, and configurable internal watchlists. Match scoring is adjustable to reduce false positives.
Exportable Compliance Reports
Generate PDF and CSV compliance reports by customer, date range, or risk category. Share with regulators, auditors, or senior management on demand.
API Integration Roadmap
Planned integration with AgileCheck AML for advanced automated screening, expanded watchlist coverage, and real-time alert feeds.
Start Building an Audit-Ready Compliance Process
COX provides the tools your organization needs to meet SSNF obligations with confidence, from customer onboarding to compliance reporting.
Frequently Asked Questions
Common questions from compliance teams and regulated entities
This page provides general information about regulatory obligations in Panama and does not constitute legal advice. Regulated entities should consult with qualified legal counsel to determine their specific compliance obligations under SSNF regulations.
COX also covers these countries:
Mexico: PLD software Mexico: LFPIORPI Colombia Ecuador Guatemala Dominican Republic Venezuela