Regulatory Update: The New Agreement 1-2026 of the Superintendency of Banks

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The recent Agreement No. 1-2026, a regulation issued by the Board of Directors of the Superintendency of Banks of Panama marks a milestone in strengthening the International Financial Center. This regulation repeals the previous Agreement No. 10-2015 and establishes more robust guidelines aligned with FATF standards and Executive Decree No. 35 of 2022.

Innovations in Digital Identification and Risk

One of the most relevant new developments is the regulation of the acquiring of new customers through digital or remote means (Art. 14). Entities must now compulsorily incorporate the inferential geolocation of the applicant to verify their actual location and mitigate risks associated with sanctioned jurisdictions.

By formalizing and expanding the use of digital identification and remote verification, the barrier of physical presence is eliminated, enabling global citizens and businesses to initiate their banking relationship from anywhere in the world more quickly. Furthermore, the clearer segmentation of Simplified Due Diligence for low-risk products and the use of technological information sources for verification reduce the bureaucratic burden and waiting times. For the business sector, this translates into faster operational readiness, provided the Beneficial Ownership structure is transparent, allowing the Panamanian banking system to be not only safer but also significantly more efficient and competitive.

The Risk-Based Approach (RBA)

The Agreement strengthens the obligation to apply a risk-based approach for all obliged entities, including general and international licensed banks, and trust companies. The standard classifies due diligence into three levels:

1. Simplified: For low-risk clients or specific products such as payroll or savings accounts with balances less than B/. 5,000.00.

2. Standard: Reasonable knowledge of the financial and transactional profile.

3. Expanded or Reinforced: Mandatory for high-risk clients, including Politically Exposed Persons (PEPs) and those who operate with high volumes of cash.

Governance and Compliance

The figure of Prevention Committee, who must report directly to the Board of Directors, is strenghten. Likewise, the Compliance Officer must maintain total independence from business areas, and its participation in account openings or commercial functions is expressly prohibited.

Impact on the Global Customer

For the international investor the Agreement requires full transparency regarding the Ultimate Beneficiary, broadening the due diligence to identify the individual who owns 10% or more of the shares or exercises effective control. It also introduces necessary flexibility that promises to significantly expedite account openings for both individuals and legal entities. This advancement aims to position Panama at the forefront of digital banking in the region, combining legal certainty with commercial agility.

At Lex Innova we believe that this regulation not only seeks legal compliance, but also reinforces the sustainability and reputation of Panama as a safe destination for global capital.