Cryptoassets Regulatory Intelligence cryptoassets.gi
PA v13.3.0
content: ai_generated legal review: never_reviewed (informational) publication gate: 1 failing10 sources retrieved model claude-sonnet-5 · 2026-08-05

Panama

PA schema crypto-v2.0.0 trajectory: not yet assessedunregulated gapoverlaps: FIM, WPM

Last updated · 8 categories · 12 sourced findings · 21 sources in the cumulative register

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Jurisdiction lead brief

Lead Signal

Panama's crypto regulatory posture this cycle is defined by a widening gap between current practice and a pending legislative fix. Today, Panama crypto businesses are not subject to a dedicated virtual-asset-service-provider licence; instead, they are treated as obligated subjects under Law 23 of 2015, which requires AML/CFT compliance but was not designed as a crypto-specific licensing instrument. Anteproyecto de Ley N° 314, introduced 13 January 2026, would change this materially: it would require VASPs and CASPs to obtain a licence, implement a comprehensive AML/CTF programme, meet capitalisation and governance standards, and submit to supervision by the Superintendencia de Bancos de Panamá (SBP) and the Unidad de Análisis Financiero (UAF). The draft has not been enacted, and confirmation of its progress through the Assembly's required debates was not located this cycle.

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Panama has no dedicated crypto/VASP licensing statute in force. Bill 697 (2022) was struck down as unconstitutional in July 2023. Two successor efforts are pending: Bill 247 (introduced March 2025) and Draft Law 314 (introduced January 2026), which would create licensing for VASPs, PSPs and EMIs together.

Standing sub-brief212 words · last cycle 2026-09-14

Crypto Licensing

Panama currently has no dedicated virtual-asset-service-provider licensing regime. Crypto businesses operating in Panama are not subject to a specific licence but are treated as obligated subjects under Law 23 of 2015, which requires AML/CFT compliance from a broad range of financial and non-financial actors without establishing a crypto-specific supervisory perimeter. This is a standing baseline position with no change this cycle.

Periodic update · new data 2026-09-14

Crypto Licensing

Panama has no dedicated crypto or virtual-asset service provider licensing law in force. Bill 697, the jurisdiction's first comprehensive attempt at crypto legislation, was declared unconstitutional in its entirety by the Supreme Court in July 2023, a ruling confirmed via press corroboration though direct retrieval of the court's own text was not achieved this cycle. That ruling left Panama without any dedicated crypto legislation, a status that persists into this cycle at confirmed confidence.

Since the 2023 ruling, two separate legislative efforts have emerged to fill the gap, and their relationship to one another remains unresolved. Bill 247, introduced 20 March 2025, proposes VASP licensing alongside stablecoin recognition and a special tax regime for crypto; it was referred to a National Assembly subcommittee on 30 September 2025 and remained unenacted as of May 2026. Separately and more recently, Draft Law 314, the Ley Marco Integral de Tecnologías Financieras, was introduced 13 January 2026 and proposes a broader licensing framework covering virtual-asset service providers together with payment-service providers and electronic-money issuers, positioned as the country's first dedicated licensing framework for VASPs specifically. Neither bill has been enacted, and whether one is intended to supersede the other, whether they are complementary, or whether they are simply competing drafts has not been resolved this cycle; confirming this would require direct review of the Asamblea Nacional's own record.

The supervisory authority most closely associated with crypto-adjacent activity today is the Superintendencia de Bancos de Panamá, which oversees AML exposure for bank-touching crypto businesses, though this is a general banking-supervision function rather than a dedicated crypto mandate. In the absence of any licence requirement, crypto businesses operating in or from Panama today do so without a bespoke authorisation regime, while AML exposure remains real through the general banking-supervision channel.

Outlook

Draft Law 314 carries a regulatory-horizon expectation of 2027-Q1 at the consultation stage, while Bill 247's own progression is expected around the same broad window but remains at the earlier proposed stage. Until the relationship between the two competing tracks is clarified and one, both, or neither receives a confirmed enactment path, Panama's crypto-licensing status should be read as genuinely unsettled rather than trending toward regulation on a fixed timeline. The most consequential development to watch for is any Asamblea Nacional record clarifying whether Bill 247 and Draft Law 314 are being reconciled into a single track.

1 earlier distinct update(s)
Periodic update · new data 2026-09-06

Crypto Licensing

Panama has no comprehensive crypto-licensing statute in force. The Superintendencia de Bancos de Panama (SBP) has maintained, since 2018, that crypto exchange, investment, and commercialisation activities are not specifically regulated and fall outside its stated supervisory competence absent dedicated legislation. This is a confirmed structural finding, assessed with probable confidence from a Tier-3 legal-commentary source describing the regulator's own longstanding position, and it defines the baseline: Panama is, and has been, an unregulated-gap jurisdiction for crypto licensing.

Anteproyecto de Ley 314, filed 13 January 2026, is the current legislative vehicle attempting to close this gap. It would create Panama's first dedicated VASP/CASP licensing framework, with prudential supervision vested in the SBP and AML/CFT oversight vested in the UAF. This is assessed with confirmed confidence as to the bill's content and filing, sourced from a Tier-3 publication, though the bill has not been enacted, is not binding, and requires further Assembly debates and presidential assent before it could take effect.

The bill's context matters for assessing enactment probability. It is the third legislative attempt at this reform: Bill 697 was found partially unconstitutional, and Bill 247 of 2025 also failed to advance to enactment. Whether Bill 247 remains live in parallel with Anteproyecto de Ley 314 was not established this cycle, which is itself a gap worth flagging, since parallel or competing legislative vehicles could affect the timeline and shape of any eventual reform.

Separately, token classification in Panama continues to rest on a fact-specific, activity-based test applied by the Superintendencia del Mercado de Valores (SMV), assessing whether a token structure functions as a security, involves a public offering, intermediation, or custody, rather than applying a technology-based classification framework. This is a stable, in-force approach assessed with probable confidence, and it operates independently of whatever VASP/CASP licensing perimeter Bill 314 might eventually establish; a token could be caught by the SMV's securities-law test regardless of the separate VASP licensing question.

Outlook

The committee and plenary progression of Anteproyecto de Ley 314 is the determinative item to watch for Panama's crypto-licensing landscape, with an expected impact window in the fourth quarter of 2026 and a half-year uncertainty band reflecting the bill's early stage. Given the precedent of two prior failed attempts at this same reform, enactment should be treated as genuinely uncertain rather than a near-certainty, and the current committee or debate stage of the bill as of September 2026 remains unestablished pending further primary-source research.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (3)
  1. T1 · Órgano Judicial de PanamáÓrgano Judicial de Panamá — Panama's National Assembly-approved virtual-asset bill (Proyecto de Ley No. 697 de 2021), which would have created a licensing/registration regime for virtual asset service providers, was declared wholly unconstitutional ('inexequible') by the Pleno of the Supreme Court of Justice, per a ruling published 4 May 2023, and therefore never entered into force as an operative licensing framework.retrieved M5bindingin force
  2. T2 · Superintendencia del Mercado de Valores de PanamáSuperintendencia del Mercado de Valores de Panamá — A Panama-incorporated company operating a virtual/cryptocurrency exchange platform using bitcoin as the exchange medium, without offering registered securities, is not required to notify or register with the Superintendencia del Mercado de Valores (SMV), per SMV Administrative Opinion 07-2018, unless the crypto-asset structure itself qualifies as a 'valor' (security) under general Securities Law.retrieved M3bindingin force
  3. T2 · World Bank Group / Superintendencia de Bancos de PanamáWorld Bank Group / Superintendencia de Bancos de Panamá — As of August 2026, Panama has no dedicated statute establishing a crypto-asset/virtual-asset service provider licensing regime; other integrated payment-system bills prepared with Inter-American Development Bank assistance deliberately excluded the controversial crypto provisions and have not been presented to the National Assembly.retrieved M4non-binding

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Panama has no statutory taxonomy for crypto-assets (no per-se definitions of utility token, security token, e-money token, or stablecoin). The Superintendencia del Mercado de Valores (SMV) instead evaluates token structures case-by-case against the general statutory definition of 'valor' (security) under the Securities Law, as illustrated by its 2018 administrative opinion addressing both bitcoin and gold-backed tokens.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T2 · Superintendencia del Mercado de Valores de PanamáSuperintendencia del Mercado de Valores de Panamá — Panama has no statutory taxonomy classifying crypto-assets (e.g., utility token, security token, stablecoin); the Superintendencia del Mercado de Valores assesses token structures case-by-case against the general definition of 'valor' under the Securities Law.retrieved M4bindingin force
  2. T2 · Superintendencia del Mercado de Valores de PanamáSuperintendencia del Mercado de Valores de Panamá — In SMV Administrative Opinion 07-2018, the regulator was asked to assess whether tokens representing beneficial ownership of gold reserves, and whether bitcoin itself, constitute a 'valor' under Panamanian securities law, illustrating that Panama applies a case-by-case securities characterisation test to crypto-assets rather than a statutory per-se classification.retrieved M3non-binding

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No Panamanian statute, regulation, or published regulator guidance specifically addresses staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization. These activities fall outside any existing licensing perimeter absent an ad hoc securities or banking characterisation by SMV or SBP respectively.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T2 · World Bank Group / Superintendencia de Bancos de PanamáWorld Bank Group / Superintendencia de Bancos de Panamá — No Panamanian law or regulator guidance specifically addresses staking, mining, DeFi lending, DEX operation, node operation, validator activity, or tokenization; these on-chain activities fall outside any existing licensing perimeter absent a case-by-case securities or banking characterisation.retrieved M3non-bindinga fact about the regime

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Panama has no statute or regulatory framework authorising, licensing, or imposing reserve/redemption requirements on stablecoin issuers. Stablecoins such as USDC and USDT circulate informally, including acceptance by the Panama City municipal government for local tax and fee payments via a bank-conversion arrangement announced in April 2025, entirely outside any national stablecoin-specific prudential regime.

Standing sub-brief325 words · last cycle 2026-09-14

Stablecoin Regime

Panama has no stablecoin-specific regulatory framework in force. What exists instead is stablecoin-adjacent content embedded within two separate, unenacted legislative tracks, and this cycle's finding is that neither track alone constitutes a stablecoin regime.

Bill 247 proposes voluntary legal recognition of Bitcoin, Ethereum, and stablecoins as payment instruments, a provision that would give stablecoins a defined legal status as a means of payment without necessarily imposing a dedicated issuer-licensing or reserve-backing regime of the kind seen in more developed stablecoin frameworks elsewhere. This bill was introduced 20 March 2025 and remained unenacted as of the most recent reporting available this cycle.

no periodic updates on record for this sub-brief

Sources and findings (1)
  1. T4 · CoinDeskCoinDesk — Panama has no statute or regulatory framework authorising, licensing, or imposing reserve/redemption requirements on stablecoin issuers; USDC and USDT are used informally (e.g., accepted by the Panama City municipal government for tax and fee payments via a bank-conversion arrangement) without any national stablecoin-specific prudential regime.retrieved M4non-bindinga fact about the regime

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General consumer-protection matters (misleading advertising, commercial quality/warranty complaints) fall to the Autoridad de Protección al Consumidor y Defensa de la Competencia (ACODECO) under Law 45 of 2007, but ACODECO has no crypto-specific rulebook. Consumer-protection jurisdiction over banks is separately reserved 'exclusively' to the Superintendencia de Bancos under Article 198 of the Banking Law, and the World Bank FSAP assessment flagged this SBP/ACODECO split as difficult for consumers to navigate. Separately, the SMV has issued public investor warnings on cryptocurrencies and ICOs.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

Sources and findings (2)
  1. T2 · World Bank Group / Superintendencia de Bancos de PanamáWorld Bank Group / Superintendencia de Bancos de Panamá — General consumer-protection complaints regarding crypto-adjacent products/services would fall under ACODECO pursuant to Law 45 of 2007 (misleading advertising, commercial quality complaints), while consumer-protection jurisdiction over banks is separately reserved exclusively to the Superintendencia de Bancos under Article 198 of the Banking Law, creating a fragmented perimeter for crypto-adjacent products.retrieved M3bindingin force
  2. T2 · Superintendencia del Mercado de Valores de PanamáSuperintendencia del Mercado de Valores de Panamá — The Superintendencia del Mercado de Valores has issued public investor warnings regarding cryptocurrencies and Initial Coin Offerings (ICOs), cautioning investors and the general public about associated risks, without this constituting a binding disclosure regime for crypto issuers.retrieved M3non-binding

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Panama operates a territorial tax system under which tax rules apply only within Panamanian territory (Código Tributario, Artículo 15), so foreign-source income is generally outside the scope of Panamanian income tax. However, no crypto-specific statute currently codifies how this territorial principle applies to crypto-asset gains after the 2022-2023 virtual-asset bill (which would have expressly classified crypto as foreign-source income exempt from capital-gains tax) was declared wholly unconstitutional. Crypto tax treatment therefore rests on the general territorial principle applied case-by-case by the Dirección General de Ingresos (DGI), rather than a codified crypto rule.

Standing sub-brief173 words · last cycle 2026-08-21

Tax Treatment

Panama signed the OECD's Crypto-Asset Reporting Framework (CARF) agreement in December 2025, with cross-border data exchange beginning in 2027. This is a known, dated forthcoming reporting obligation that will apply against the backdrop of Panama's general territorial tax system, under which foreign-sourced crypto income is currently exempt and no capital-gains tax applies to crypto transactions. The CARF signature does not itself change Panama's substantive tax treatment of crypto; it establishes a future cross-border information-exchange obligation layered on top of the existing favourable regime.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (2)
  1. T1 · Gaceta Oficial de Panamá / Órgano JudicialGaceta Oficial de Panamá / Órgano Judicial — Panama operates a territorial tax system under which tax rules apply only within Panama's territory (Código Tributario, Artículo 15), so foreign-source income — a category into which many crypto-asset transactions conducted via offshore/foreign platforms may fall — is generally outside the scope of Panamanian income tax, although no crypto-specific statute has codified this treatment after the 2022-2023 virtual-asset bill was struck down.retrieved M4bindingin force
  2. T4 · CoinDeskCoinDesk — The struck-down 2022 virtual-asset bill (Proyecto de Ley 697 de 2021) would have expressly classified crypto-assets as foreign-source income exempt from capital-gains tax under Panama's territorial system, but because the bill was declared wholly unconstitutional, this specific statutory exemption for crypto never took legal effect.retrieved M3non-binding

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No crypto-specific cross-border transfer restrictions, outbound limits, or crypto-specific reporting thresholds have been identified in Panamanian law. Cross-border crypto transfers appear to be governed only by general foreign-exchange, banking, and AML/CFT rules applicable to regulated financial institutions, which were not researched in crypto-specific detail in this run (deferred in part to the FIM aml_ctf subscription).

Standing sub-brief295 words · last cycle 2026-09-05

Cross-Border Transfer

Panama's cross-border virtual-asset transfer environment is currently unrestricted, a function of the jurisdiction's dollarised, capital-control-free foreign exchange regime. There is no outbound restriction specific to virtual-asset transfers under the current regime, a status assessed with probable confidence from a Tier-3 source, and this position persists absent the enactment of Draft Law 314, which would introduce Panama's first dedicated VASP supervisory perimeter but has not yet been passed.

No new data since the standing brief. 1 periodic run re-emitted it unchanged.

Sources and findings (1)
  1. T2 · World Bank Group / Superintendencia de Bancos de PanamáWorld Bank Group / Superintendencia de Bancos de Panamá — No crypto-specific cross-border transfer restrictions, outbound limits, or crypto-specific reporting thresholds have been identified in Panamanian law; cross-border crypto transfers are governed only by general foreign-exchange, banking, and AML/CFT rules applicable to regulated financial institutions.retrieved M3non-bindingour coverage gap, expected to resolve on a re-run

#

Crypto subscribes to the FIM aml_ctf module at the consumer level; no aml_cft_regime claims are produced in this baseline to avoid duplication. For disambiguation context only: Panama's general AML/CFT framework is led by the Superintendencia de Bancos (e.g., Rule 1-2026 on prevention of misuse of banking and fiduciary services, and Rule 3-2026 on administrative sanction criteria), but these instruments are not crypto-specific and were not researched for crypto-specific applicability in this run.

Absence reason not determinableNo sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

no periodic updates on record for this sub-brief

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Editorial metadata

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Editorial metadata for Panama
FieldValue
trust.lawyer_review.statusnever_reviewed
trust.lawyer_review.reviewerno reviewer on record
trust.content_sourceai_generated

Provenance and declared absence

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Envelope: baseline resolved at jurisdiction_json.baseline; 8 module(s), 12 finding(s), 21 source(s) in the cumulative register.

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