Countries › Panama › Guide › 10. Capital markets and finance › Investment funds in Panama: registered, foreign and private funds, investment manager licences and SMV fees

Investment funds in Panama: registered, foreign and private funds, investment manager licences and SMV fees

Argentina. For full detail on Argentina, go to The Argentine Thread.

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

Funds (sociedades de inversión) offered to the public in Panama register with the Superintendencia del Mercado de Valores, may be open or closed ended, and must keep assets with an authorised custodian. Private funds that are not offered in Panama and either limit holders to 50 or sell only to qualified investors with at least B/.100,000 each are outside the registered fund regime but need a Panamanian representative. Anyone managing funds in or from Panama needs an investment manager licence.

Panama's currency, the balboa (B/.), is at par with the US dollar, which circulates freely; the Superintendencia de Bancos states that the balboa's value is on a par with the US dollar and that the dollar circulates without restrictions in commercial and financial transactions (checked 29 October 2026). USD figures therefore equal the balboa figures.

Key facts

SMV registration fee per investment fund	5000 PABTexto Único DL 1 de 1999 art. 25 numeral 5 (Ley 66 de 2016), as of 2026-10-29 · in force
Additional SMV fee per sub fund	1500 PABTexto Único DL 1 de 1999 art. 25 numeral 5 (Ley 66 de 2016), as of 2026-10-29 · in force
Private fund minimum initial investment (qualified investor route)	100000 PABTexto Único DL 1 de 1999 art. 180, as of 2026-10-29 · in force
Net worth for an individual qualified investor (private funds)	1000000 PABTexto Único DL 1 de 1999 art. 180, as of 2026-10-29 · in force
Private fund limit on beneficial owners (numerical route)	50 holdersTexto Único DL 1 de 1999 art. 180, as of 2026-10-29 · in force
Investment manager licence fee	15000 PABTexto Único DL 1 de 1999 art. 25 numeral 14 (Ley 66 de 2016), 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); Ley 84 de 1904 art. 1, as of 2026-10-29 · in force

The rule

1. Investment funds may be open ended (investors may periodically redeem at net asset value less disclosed charges, with a variable number of units) or closed ended (no redemption before liquidation except in extraordinary cases); a closed fund may convert to open if its constitutional documents allow.Texto Único del Decreto Ley 1 de 1999 (Ley del Mercado de Valores), art. 152, 1999-07-08 official text · verified 2026-10-29

2. A fund is managed in or from Panama if it appoints an investment manager in Panama, has or advertises its main domicile in Panama, or appoints a custodian in Panama.Texto Único del Decreto Ley 1 de 1999 (Ley del Mercado de Valores), art. 158, 1999-07-08 official text · verified 2026-10-29

3. The money and securities of a registered fund must be held by intermediaries or other custodians authorised by the Superintendencia, with the independence from the fund and its manager that the Superintendencia sets.Texto Único del Decreto Ley 1 de 1999 (Ley del Mercado de Valores), art. 169, 1999-07-08 official text · verified 2026-10-29

4. Foreign funds are those formed under foreign law or whose principal manager is domiciled and manages the assets outside Panama; the Superintendencia may exempt them from specific rules if their home rules give investors substantially equal or better protection, and they may report under their home GAAP.Texto Único del Decreto Ley 1 de 1999 (Ley del Mercado de Valores), art. 179, 1999-07-08 official text · verified 2026-10-29

5. A separate register exists for funds that offer their units only abroad to persons domiciled outside Panama.Texto Único del Decreto Ley 1 de 1999 art. 179-A, added by Ley 12 de 2012 art. 287, art. 179-A, 2012-04-03 official text · verified 2026-10-29

6. Private funds are funds managed in or from Panama whose units are not offered in Panama and whose documents either limit beneficial owners to 50 or require offers by private communication, or restrict sales to qualified investors with a minimum initial investment of B/.100,000. Qualified investors are professionals dealing in the relevant assets or persons who sign that they have, alone or with a spouse, net worth of at least B/.1,000,000 and agree to be treated as such. Private funds are not registered funds.
Example: A Panama managed private equity fund with 30 qualified investors each committing B/.250,000 stays outside the registered fund rules. / 30 investors at US$250,000 each, US$7.5 million fund.Texto Único del Decreto Ley 1 de 1999 (Ley del Mercado de Valores), art. 180, 1999-07-08 official text · verified 2026-10-29

7. Private funds must appoint a representative in Panama, which may be an investment manager, casa de valores, investment adviser, licensed bank, audit firm, lawyer or law firm or another person authorised by the Superintendencia.Texto Único del Decreto Ley 1 de 1999 (Ley del Mercado de Valores), art. 181, 1999-07-08 official text · verified 2026-10-29

8. Only holders of an SMV investment manager licence may act as investment manager in or from Panama, whether or not the funds are registered; managers of funds publicly offered in Panama also need the licence even if they do not operate from Panama.Texto Único del Decreto Ley 1 de 1999 (Ley del Mercado de Valores), art. 184, 1999-07-08 official text · verified 2026-10-29

9. Fund fees: registration of a fund B/.5,000 per fund plus B/.1,500 per sub fund; annual supervision 0.0020 percent of average net assets attributable to units registered and sold in Panama, minimum B/.1,000 and maximum B/.20,000 per fund or sub fund; investment manager licence B/.15,000 with annual supervision of B/.10,000; termination of a fund registration B/.1,000.
Cost to do it: B/.5,000 (US$5,000) to register a fund plus B/.1,500 per sub fund; B/.15,000 (US$15,000) for a manager licence and B/.10,000 a year.
Example: An umbrella fund with three sub funds: B/.5,000 plus 3 x B/.1,500 = B/.9,500 to register; with B/.100,000,000 of average assets sold in Panama, supervision of B/.2,000 a year per fund. / US$9,500 to register, about US$2,000 a year.Ley 66 de 2016 arts. 3 and 4, rewriting arts. 25 and 26 of the Texto Único del Decreto Ley 1 de 1999, art. 25 numerals 5, 14 and 22; art. 26 numerals 3 and 10, 2016-12-09 official text · verified 2026-10-29

Route	Who may invest	Registration	Key rule
Registered fund	Public in Panama	SMV registration, B/.5,000 plus B/.1,500 per sub fund	Authorised custodian (art. 169), reports to SMV
Registered fund offered only abroad	Persons domiciled outside Panama	Separate register (art. 179-A)	No offer in Panama
Private fund	Up to 50 holders or qualified investors with B/.100,000 minimum, no offer in Panama	Not a registered fund	Panamanian representative (art. 181)
Foreign fund	As registered or exempt	Possible exemptions for equivalent home rules (art. 179)	Home GAAP allowed

Fund routes under the Texto Único del Decreto Ley 1 de 1999.

Worked example

A Latin American asset manager sets up a Panama managed fund for 40 family offices outside Panama, each investing at least US$100,000 (B/.100,000). The fund is a private fund under art. 180, appoints a Panamanian law firm as representative and is not registered.
The manager runs the portfolio from Panama City, so it needs an SMV investment manager licence (B/.15,000, then B/.10,000 a year).
Argentine family offices investing through the fund remain subject to their own FX and tax rules, covered at a high level in the Argentine guide.

Step by step

Decide the route: public registered fund, offshore only registered fund, private fund or foreign fund.
Draft constitutional documents with the holder limit or qualified investor clause if using the private route.
Appoint a licensed investment manager and an authorised custodian (registered funds) or a Panamanian representative (private funds).
File with the SMV and pay the registration fees.
Diary the annual supervision fees and SMV reports.

Common traps

Any offer to people domiciled in Panama takes a fund out of the private route.
A fund is managed from Panama if it merely names a Panamanian manager or custodian or advertises a Panamanian domicile, which brings the manager licence requirement.
Qualified investor status for individuals rests on a signed net worth declaration of B/.1,000,000; keep the signed declarations on file.

Sources

← Tender offers for listed Panamanian companies: the 25 and 50 percent triggers, 30 day minimum and 75 percent squeeze out offerSecured lending in Panama: the movable property mortgage of Ley 129 de 2013, registration, priority and out of court enforcement →

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