Countries › Panama › Guide › 14. Disputes › Enforcing foreign court judgments in Panama: exequatur at the Supreme Court Fourth Chamber, reciprocity and the four conditions

Enforcing foreign court judgments in Panama: exequatur at the Supreme Court Fourth Chamber, reciprocity and the four conditions

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

Foreign money judgments are enforced in Panama only after the Supreme Court Fourth Chamber declares them enforceable, giving the debtor and the Attorney General 5 days each. Without a treaty, a judgment is enforceable unless the State of origin refuses to enforce Panamanian judgments, and it must not be a default judgment without personal service, must concern a lawful obligation and must be authentic. Purely declaratory foreign judgments only need authentication, and judgments under a foreign court of non convenient forum are rejected.

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

Court recognising foreign judgments	Supreme Court, Fourth Chamber textCódigo Procesal Civil arts. 48 and 680, as of 2026-10-29 · in force
Reciprocity required	Negative reciprocity: refused if the State of origin does not enforce Panamanian judgments textCódigo Procesal Civil art. 678, as of 2026-10-29 · in force
Days for the debtor and the Attorney General to respond	5 daysCódigo Procesal Civil art. 680, as of 2026-10-29 · in force
Review of the merits	No; only the listed conditions textCódigo Procesal Civil art. 679, as of 2026-10-29 · in force
Exclusive Panamanian jurisdiction over real estate in Panama	Yes textLey 61 de 2015 art. 156, as of 2026-10-29 · in force
Choice of a foreign court can be honoured	Yes, if written, accepted by that court and on disposable matters textLey 61 de 2015 art. 15, 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. Foreign judgments have the force given by the applicable treaty. Without a treaty, they may be enforced unless it is proved that the State of origin does not comply with Panamanian judgments, in which case they have no force.Ley 402 de 2023 (Código Procesal Civil), art. 678, 2023-10-11 official text · verified 2026-10-29

2. Unless a treaty provides otherwise, a foreign judgment is enforceable only if it was given on a personal action, was not given in default (the claim was personally served where personal service was ordered), concerns an obligation lawful in Panama and is an authentic copy.Ley 402 de 2023 (Código Procesal Civil), art. 679, 2023-10-11 official text · verified 2026-10-29

3. The Código de Derecho Internacional Privado adds that the foreign court must not have breached Panama's exclusive jurisdiction, including over real estate in Panama, that the judgment must not breach Panamanian public policy and must be final and not subject to appeal, and that a Spanish translation is needed where relevant.Ley 61 de 7 de octubre de 2015 (Código de Derecho Internacional Privado), arts. 155 and 156, 2015-10-07 official text · verified 2026-10-29

4. The application goes to the Fourth Chamber of General Business of the Supreme Court, which notifies the party that must comply and the Attorney General for 5 days each; if all agree it orders enforcement, otherwise it holds a hearing to take evidence. Once declared enforceable, execution is sought from the competent court.Ley 402 de 2023 (Código Procesal Civil), arts. 48 and 680, 2023-10-11 official text · verified 2026-10-29

5. The exequatur court may order protective measures at the request of a party or on its own motion while the application is pending.Ley 61 de 7 de octubre de 2015 (Código de Derecho Internacional Privado), art. 157, 2015-10-07 official text · verified 2026-10-29

6. Declaratory foreign judgments that are duly authenticated are treated as foreign documents and do not need exequatur, but judgments with res judicata effect or a liquid award against a Panamanian national or resident do.Ley 61 de 7 de octubre de 2015 (Código de Derecho Internacional Privado), art. 143, 2015-10-07 official text · verified 2026-10-29

7. Suits filed in Panama as a consequence of a foreign judgment applying forum non conveniens are rejected by the court on its own motion on constitutional grounds.Ley 402 de 2023 (Código Procesal Civil), art. 684, 2023-10-11 official text · verified 2026-10-29

8. Panamanian courts may decline jurisdiction in favour of a foreign court designated in a written choice of court clause if that court accepts it, the matter is disposable and no exclusive Panamanian jurisdiction is breached, and must decline where there is an arbitration clause.Ley 61 de 7 de octubre de 2015 (Código de Derecho Internacional Privado), art. 15, 2015-10-07 official text · verified 2026-10-29

Condition	Source
Personal action	Código Procesal Civil art. 679
Not a default judgment without personal service	Código Procesal Civil art. 679; Ley 61 art. 156
Lawful obligation and no breach of public policy	Código Procesal Civil art. 679; Ley 61 art. 156
Authentic copy, translated into Spanish	Código Procesal Civil art. 679; Ley 61 art. 156
No breach of exclusive Panamanian jurisdiction (e.g. local real estate)	Ley 61 art. 156
State of origin enforces Panamanian judgments	Código Procesal Civil art. 678

Exequatur conditions in Panama.

Worked example

A New York court awards a lender US$900,000 against a Panamanian borrower who was personally served and defended.
The lender files the apostilled judgment with a Spanish translation at the Fourth Chamber; the borrower and the Attorney General get 5 days each.
If granted, a circuit judge enforces B/.900,000 against the borrower's assets in Panama.

Step by step

Confirm the defendant was personally served abroad; default judgments without personal service fail.
Obtain an apostilled copy (Panama is in the Apostille Convention) and a translation by a public interpreter.
Check whether a treaty with the State of origin applies.
File at the Fourth Chamber and ask for protective measures if assets may move.

Common traps

Judgments on Panamanian real estate are not enforceable; that jurisdiction is exclusive.
Where the foreign court dismissed a case for forum non conveniens, refiling the same claim in Panama is rejected.
The debtor can defeat enforcement by proving the State of origin does not enforce Panamanian judgments.

Sources

← Enforcing arbitral awards in Panama: New York and Panama Conventions, the Fourth Chamber, closed refusal grounds and the most favourable treaty ruleCross border litigation with Panama: serving defendants abroad, letters rogatory, evidence, apostilles and proving foreign law →

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