Panama

That gap is the direct backdrop to Anteproyecto de Ley No. 314, the Ley Marco Integral de Tecnologías Financieras, introduced to the National Assembly on 13 January 2026. The bill proposes Panama's first dedicated licensing categories for virtual-asset service providers, payment-service providers and e-money issuers, designating SBP as primary prudential supervisor while routing suspicious-activity reports to the Financial Analysis Unit (UAF). If enacted, it would be the first dedicated market-access gateway for non-bank PSPs and EMIs in Panama; however, no forward committee or plenary date has been sourced this cycle, and no parallel or competing fintech legislative proposals were identified in this cycle's research.

Outlook

Draft Law 314's progression is the single most consequential forward marker for Panama's licensing architecture: enactment would resolve the AML-registration-versus-licensing confusion that currently burdens non-bank market entrants, while continued stasis would leave SBP's Law 23/2015 registry as the only touchpoint for non-bank payment supervision. This module should be re-verified next cycle for committee or plenary movement.

No dedicated conduct-of-business or safeguarding regime exists for non-bank e-money customers. ACODECO handles only limited banking-consumer matters under Law 45 of 2007 — misleading advertising, credit records and warranty claims — while other banking complaints go directly to SBP; consumer-facing safeguarding of e-money balances is not addressed by either regulator, an absence that reflects the lack of a dedicated regime rather than a confirmed permissive rule.

Outlook

The bank-PSP/non-bank-PI-EMI distinction is acute here: banks absorb Rule 1-2026's CDD/EDD tightening within existing conduct frameworks, while non-bank e-money issuers have no conduct-of-business or safeguarding regime to absorb it into at all. Enactment of Draft Law 314 would be the natural vehicle to close this conduct/safeguarding gap for non-bank entities; absent that, the gap persists as a standing feature of Panama's regime.

A successor bill, No. 247, introduced in 2025, proposes licensing of virtual-asset service providers registered with the Financial Analysis Unit (UAF), mandates FATF-aligned KYC/AML compliance, and creates a National Council for Digital Assets. Its status remains pending before the National Assembly, with no confirmed forward enactment date sourced this cycle; the bill's fate should be re-verified next cycle.

Outlook

Litigation precedent now functions as an implicit filter on Panama's crypto/stablecoin ambitions: any future VASP or stablecoin framework must clear the constitutional bar the Supreme Court set in 2023. Bill 247's progression — or continued stasis — is the key marker to track next cycle; illicit-finance-use dimensions of any eventual VASP regime fall to FIM rather than WPM.

Absent a central bank, Banco Nacional de Panamá's clearinghouse functions as the country's most important settlement system for retail payments. The World Bank's Financial Sector Assessment finds that settlement-risk management here lacks sophistication, with participants able to run largely uncollateralized net debit positions — a structural feature carried through directly into this monitor's W12 correspondent-banking and settlement analysis.

Outlook

Absent a DORA-equivalent statute, Panama's operational-resilience posture will likely continue to develop incrementally through SBP/SMV rule updates rather than a single consolidating law; monitor for any successor instrument that might formally supersede the 2005-2018 Acuerdo series.

PCI-DSS certification, tokenization and 3-D Secure authentication are flagged by market commentary as expected functionalities for scheme-connected payment gateways, though no bespoke statutory mandate for these controls was identified; this finding rests on a single indicative source rather than confirmed regulatory text.

Outlook

The absence of a confirmed interchange-regulation statute remains an open research question rather than a settled finding of deregulation; this module should be re-tested against any Draft Law 314 secondary provisions on scheme access if the bill advances.

An IMF Working Paper covering the CAPDR region finds a clear trend of declining remittance fees at any level of digitalization, though costs remain higher for CAPDR countries relative to other global regions — meaning Panama's dominant US-Panama retail corridor still carries an above-average cost burden even as digital channels expand.

Outlook

Panama's hub role looks structurally durable given dollarization and continued IBC deposit growth, but the CAPDR remittance-cost gap versus global benchmarks is unlikely to close quickly; corridor-level fee dynamics warrant continued tracking alongside the correspondent-access questions raised in W12.

Outlook

Bank-sponsored wallets are likely to retain their structural advantage absent a dedicated non-bank licensing pathway; Draft Law 314's fate is therefore also a market-structure variable, not only a compliance one, since a workable non-bank licence could lower the distribution barrier that defeated Tigo Money.

Outlook

Both instruments together signal a more codified, legible enforcement posture from SBP, which should reduce litigation unpredictability going forward; a primary-text citation for Acuerdo 3-2026 should be sought next cycle to upgrade its sourcing above T3 secondary reporting.

Outlook

Merchant acquiring in Panama looks set to continue running on bank-affiliated rails blended with global PSP partnerships for cross-border acceptance, a structure that suits the tourism-heavy merchant base but leaves foreign PSPs dependent on local bank partnership as a market-access condition.

Outlook

Instant-payments interoperability is on a clear expansionary trajectory, but the inclusion gaps in the most remote provinces suggest the benefits of Telered's Xpress rollout are concentrated in already-banked urban populations; closing the agency-banking and postal-channel gap remains an unresolved financial-inclusion question.

Outlook

Without a statutory misdirected-payment or APP-fraud reimbursement rule, consumer protection for e-money customers will likely continue to depend on voluntary industry practice such as Yappy's refund feature rather than an enforceable regulatory entitlement, a gap Draft Law 314 does not appear to address directly.

Sentinel.gi further reports that SBP Rule 1-2026 (16 January 2026) updates due-diligence, enhanced-due-diligence and transaction-monitoring obligations, and that Acuerdo 3-2026 (29 May 2026) codifies a graduated sanctions methodology — together consolidating Panama's post-delisting AML/CFT control architecture. WPM carries this only as provenance summary; original illicit-finance analysis is routed to FIM via cross-monitor flags rather than analysed here.

Outlook

Panama's AML/CFT architecture reads as consolidating rather than static: the delisting removed the external-pressure trigger, but SBP has since chosen to keep tightening domestic controls through Rule 1-2026 and Acuerdo 3-2026, an approach likely to continue improving Panama's standing with FATF-style peer review even as it narrows onboarding at the margin; full illicit-finance substance remains for FIM's review, not WPM's.

Panama's FATF delisting was expected to improve correspondent relationships and credit-line access; SBP Rule 1-2026 now signals renewed compliance tightening toward US/European correspondents, likely producing narrower fintech-client onboarding even as academic research on the grey-listing episode finds de-risking was more selective than the sweeping-exit narrative suggests, a nuance corroborated by continued IBC deposit growth despite the tightening.

Outlook

The net direction for correspondent access is cautiously positive, but the two forces — post-delisting relief and Rule 1-2026 compliance tightening — will likely offset each other in the near term, with non-bank PSPs and EMIs most exposed to any narrowing since they lack the dedicated licensing standing that banks already hold; this asymmetry remains the module's central watch item.

The standout 2026 market-development milestone is legislative rather than transactional: Panama's Anteproyecto de Ley No. 314 was introduced to the National Assembly on 13 January 2026, proposing dedicated licensing categories for VASPs, PSPs and EMIs for the first time — tracked here for commercial-intelligence context as a market-development event rather than a funding or M&A transaction.

Outlook

Commercial signal for Panama's fintech sector is modest and dashboard-tier this cycle, with the Draft Law 314 introduction the only material market-development event; individual funding and M&A deal-level detail remains structurally under-indexed given aggregator-only source coverage, a recognised bias-correction area for future cycles.