Countries › Panama › Guide › 14. Disputes › Enforcing arbitral awards in Panama: New York and Panama Conventions, the Fourth Chamber, closed refusal grounds and the most favourable treaty rule

Enforcing arbitral awards in Panama: New York and Panama Conventions, the Fourth Chamber, closed refusal grounds and the most favourable treaty rule

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Last verified: 2026-10-29 · Status: Stable

Panama acceded to the New York Convention on 10 October 1984, in force from 8 January 1985, with no reservations listed, and has approved the 1975 Inter American (Panama) Convention. Awards made abroad are recognised by the Supreme Court Fourth Chamber, which gives the other side 15 days and decides within 60 days, and may refuse only on the closed grounds that mirror the New York Convention. International awards made in Panama skip recognition, and domestic awards go straight to a circuit judge.

Panama's currency, the balboa (B/.), is at par with the US dollar, which circulates as legal tender; the Superintendencia de Bancos states that the balboa's value is on a par with the US dollar (checked 29 October 2026). USD figures therefore equal the balboa figures.

Key facts

Party to the New York Convention	Yes textAccession 10 October 1984, as of 2026-10-29 · in force
New York Convention in force for Panama	1985-01-08 dateUNCITRAL status table, as of 2026-10-29 · in force
Reservations listed for Panama	None listed textUNCITRAL status table, as of 2026-10-29 · in force
Law approving the Inter American Convention on International Commercial Arbitration	Ley 11 de 1975 textLey 11 de 1975, as of 2026-10-29 · in force
Court recognising foreign awards	Supreme Court, Fourth Chamber textLey 131 de 2013 arts. 70 and 73, as of 2026-10-29 · in force
Days for the other side to respond	15 daysLey 131 de 2013 art. 73, as of 2026-10-29 · in force
Days for the Chamber to decide	60 daysLey 131 de 2013 art. 73, as of 2026-10-29 · in force
Translation of a non Spanish award	May be required by the Chamber textLey 131 de 2013 art. 71, as of 2026-10-29 · in force
Exchange rate used for USD conversions	1 PAB per USDBalboa at par with the US dollar (Superintendencia de Bancos), as of 2026-10-29 · in force

The rule

1. Panama acceded to the New York Convention on 10 October 1984 and it entered into force on 8 January 1985; the UNCITRAL status table lists no declarations or reservations for Panama. Domestically the Convention was approved by Ley 5 de 1983.Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York, 1958); Ley 5 de 1983, Accession, 1985-01-08 official text · verified 2026-10-29

2. International awards are recognised and enforced under the New York Convention, the Inter American Convention on International Commercial Arbitration (Panama, 30 January 1975) or any other ratified treaty; unless the parties agree otherwise, the applicant gets the most favourable treaty. International awards made in arbitrations seated in Panama are enforced directly without recognition.Ley 131 de 31 de diciembre de 2013, art. 70, 2013-12-31 official text · verified 2026-10-29

3. The applicant files the original award or an authenticated copy with the Fourth Chamber of General Business of the Supreme Court; if the award is not in Spanish the Chamber may require a translation. The Chamber gives the other parties 15 days to respond and decides within 60 days.Ley 131 de 31 de diciembre de 2013, arts. 71 and 73, 2013-12-31 official text · verified 2026-10-29

4. Recognition may be refused only, at the request of the resisting party, for incapacity or invalid agreement, lack of proper notice or inability to present its case, excess of the agreement, irregular composition or procedure, or an award not yet binding or set aside or suspended at the seat; and, on the Chamber's own motion, for non arbitrable subject matter or breach of Panama's international public policy. The Chamber may adjourn if annulment is pending at the seat and order security.Ley 131 de 31 de diciembre de 2013, art. 72, 2013-12-31 official text · verified 2026-10-29

5. The Código de Derecho Internacional Privado repeats the treaty hierarchy and the direct enforcement of Panama seated international awards, and the Código Procesal Civil confirms that the Fourth Chamber examines foreign judgments and arbitral awards and that the exequatur of foreign awards follows the law on arbitration.Ley 61 de 7 de octubre de 2015 (Código de Derecho Internacional Privado); Ley 402 de 2023 (Código Procesal Civil), Ley 61 arts. 158 and 159; Código Procesal Civil arts. 48 and 678, 2023-10-11 official text · verified 2026-10-29

6. Once recognised, an award is an executive title enforced by the competent judge; defences in execution must rest on facts after the award.Ley 402 de 2023 (Código Procesal Civil), arts. 732 and 764, 2023-10-11 official text · verified 2026-10-29

Award	Route	Source
Domestic award seated in Panama	Enforced by a civil circuit judge; 15 day opposition limited to annulment	Ley 131 art. 69
International award seated in Panama	Enforced directly, no recognition	Ley 131 art. 70
Award seated abroad	Recognition by the Fourth Chamber, then enforcement	Ley 131 arts. 70 to 73

Which route an award takes in Panama.

Worked example

A Colombian buyer wins a US$1,500,000 award in a Bogotá seated arbitration against a Panamanian seller.
It files the authenticated award with a Spanish translation if requested at the Fourth Chamber; the seller has 15 days to respond and the Chamber decides within 60 days.
After recognition, a circuit judge enforces it against the seller's Panamanian bank accounts as B/.1,500,000 (balboa at par).

Step by step

Obtain the original award or an authenticated or apostilled copy.
Prepare a Spanish translation by a public interpreter, as the Chamber may require it.
File at the Fourth Chamber, naming the treaty you rely on (or the most favourable rule of art. 72).
Identify assets and request attachment in the enforcement phase.

Common traps

An award set aside or suspended at the seat may be refused.
Public policy review is against Panama's international public policy, not domestic rules.
Do not file international awards seated in Panama for recognition; they are enforced directly.

Sources

← Commercial arbitration seated in Panama under Ley 131 de 2013: the agreement, the tribunal, interim measures, the award and annulmentEnforcing foreign court judgments in Panama: exequatur at the Supreme Court Fourth Chamber, reciprocity and the four conditions →

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