Countries › Panama › Guide › 13. Regulation › Anti money laundering in Panama: Ley 23 de 2015, UAF reporting, B/.10,000 cash reports and fines up to B/.5,000,000

Anti money laundering in Panama: Ley 23 de 2015, UAF reporting, B/.10,000 cash reports and fines up to B/.5,000,000

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

Ley 23 de 2015 makes banks, securities, insurance and trust firms (financial reporting entities) and a long list of non financial businesses, from free zone companies and real estate brokers to car dealers and lawyers acting as resident agents, apply risk based due diligence, report cash transactions of B/.10,000 or more and send suspicious transaction reports to the UAF within 15 calendar days. Since Ley 254 de 2021 fines run from B/.5,000 to B/.5,000,000.

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

Cash transaction report threshold	10000 PABLey 23 de 2015 art. 53, as of 2026-10-29 · in force
Suspicious transaction report deadline	15 daysLey 23 de 2015 art. 54, as of 2026-10-29 · in force
Minimum generic AML fine	5000 PABLey 23 de 2015 art. 60 per Ley 254 de 2021, as of 2026-10-29 · in force
Maximum generic AML fine	5000000 PABLey 23 de 2015 art. 60 per Ley 254 de 2021, as of 2026-10-29 · in force
Financial intelligence unit	Unidad de Análisis Financiero (UAF) textLey 23 de 2015 arts. 9 and 54, as of 2026-10-29 · in force

The rule

1. Non financial reporting entities are supervised by the Superintendencia de Sujetos no Financieros and include: companies in the Colón Free Zone, Panamá Pacífico, Barú and other free zones; casinos and online gambling; real estate developers, agents and brokers in purchase and sale deals; construction contractors; cash in transit firms; pawnshops; precious metals and stones dealers including the diamond exchange; the national lottery; the post office; new and used car dealers; lawyers and certified accountants performing listed activities for clients (property deals, managing funds or accounts, forming or administering companies, foundations and trusts, nominee services, registered office and acting as resident agent); and notaries.Ley 124 de 7 de enero de 2020, applied through Ley 23 de 2015 art. 23 as restored by Ley 254 de 2021, Ley 124 art. 40; Ley 254 art. 6, 2021-11-11 official text · verified 2026-10-29

2. Non financial reporting entities must register with the Superintendencia de Sujetos no Financieros under the procedure it sets.Ley 124 de 2020, art. 44, 2020-01-07 official text · verified 2026-10-29

3. Reporting entities must identify, assess and understand their money laundering, terrorist financing and proliferation financing risks and apply measures in proportion, with enhanced measures for higher risk clients; non financial entities must obtain the client's financial and transactional profile according to risk.Ley 23 de 2015 as amended by Ley 254 de 2021, arts. 26 and 26-B, 2021-11-11 official text · verified 2026-10-29

4. Reporting entities must report cash or quasi cash deposits or withdrawals of B/.10,000 or more, including successive smaller transactions that total B/.10,000 or more in a day or a week; currency exchanges of that size; and cash payments or collections of B/.10,000 or more (or that sum in a week) by the same client.
Example: Three cash payments of B/.4,000 by one client in the same week total B/.12,000 and must be reported. / US$12,000 in cash over a week triggers the report.Ley 23 de 2015, art. 53, 2015-04-27 official text · verified 2026-10-29

5. Suspicious transactions, of any amount, and control failures must be reported directly to the Unidad de Análisis Financiero (UAF) within 15 calendar days of detection, with a possible 15 day extension for supporting documents in complex cases.Ley 23 de 2015, art. 54, 2015-04-27 official text · verified 2026-10-29

6. Breaches of the law or of supervisors' rules without a specific sanction are fined from B/.5,000 to B/.5,000,000, graded by gravity, recidivism, damage and the size of the reporting entity; this includes late or incorrect reports.
Example: Fine range B/.5,000 to B/.5,000,000. / US$5,000 to US$5,000,000.Ley 23 de 2015 as amended by Ley 254 de 2021, art. 60, 2021-11-11 official text · verified 2026-10-29 · changed: Ley 254 de 11 November 2021 raised the maximum generic fine from B/.1,000,000 to B/.5,000,000 and added the size of the reporting entity as a grading factor.

7. Supervisors may impose progressive fines while a breach continues; acts of directors, officers and staff are attributed to the reporting entity, and the individuals remain civilly and criminally liable.Ley 23 de 2015, arts. 62 and 63, 2015-04-27 official text · verified 2026-10-29

8. On receiving United Nations Security Council lists (distributed by the UAF), reporting entities must immediately suspend transactions with and preventively freeze the funds of any matching client, notify the UAF at once, and keep the assets frozen until notified by a court.Ley 23 de 2015, art. 49, 2015-04-27 official text · verified 2026-10-29

Reporting entity	Supervisor
Banks, securities, insurance, trust and other financial firms	Their financial regulator (Ley 23 de 2015 arts. 19 and 22)
Free zone firms, real estate, construction, casinos, car dealers, pawnshops, precious metals, lawyers and accountants for listed activities, notaries	Superintendencia de Sujetos no Financieros (Ley 124 de 2020 arts. 39 and 40)

Who supervises whom.

Worked example

A foreign developer selling condos in Panama City through its own sales office is a reporting entity: it must register, profile buyers, report cash payments of B/.10,000 (US$10,000) or more and file suspicious transaction reports within 15 calendar days.
A Colón Free Zone distributor is covered just by operating in the free zone, whatever its products.

Step by step

Check whether any group company falls under art. 22 of Ley 23 or art. 40 of Ley 124.
Register non financial entities with the Superintendencia and appoint a compliance contact.
Run a written risk assessment and client due diligence, including beneficial owners.
Build cash aggregation rules (daily and weekly) and a 15 day suspicious report workflow.
Screen clients against UN Security Council lists; on a match suspend transactions, freeze, and notify the UAF immediately.

Common traps

Splitting cash below B/.10,000 does not help: daily and weekly totals count.
The resident agent of every Panamanian company is a reporting entity, so expect detailed due diligence requests when forming or keeping an entity.
Fines apply for late or incorrect reports, not only for failing to report.

Sources

← Personal data protection in Panama: Ley 81 de 2019, ANTAI enforcement, 72 hour breach notice and cross border transfersAnti corruption in Panama: bribery offences, foreign bribery and sanctions on companies under the Penal Code →

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