Panama has enacted Law 697 of 2021, which regulates commercial activities involving virtual assets, marking the first comprehensive legal framework for cryptocurrency in the country. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The law establishes a regulatory framework but does not create a specific licensing regime for virtual asset service providers as of 2025–2026, leaving the practical implementation incomplete. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

No dedicated securities regulator has been formally empowered to oversee digital asset securities, and no specific securities licensing regime for crypto exists under Panamanian law. asamblea.gob.pa/legispan-2

There is no evidence that any entity has been licensed to conduct digital asset securities activities in Panama as of the current date. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The practical reality is that while legislation exists on paper, the regulatory infrastructure and enforcement mechanisms for virtual asset securities in Panama remain largely undeveloped and unproven. asamblea.gob.pa/legispan-2

The primary legislative instrument is Law 697 of 2021, officially titled "Que regula las actividades comerciales y los servicios de activos virtuales" (Which regulates commercial activities and virtual asset services), published through the Asamblea Nacional de Panamá. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The law was introduced as Bill 696 during the 2020–2021 legislative period, reflecting Panama's initial attempt to establish statutory recognition of virtual assets in commercial transactions. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The Asamblea Nacional de Panamá (National Assembly) serves as the legislative body that proposed and debated this framework, with the full legislative tracking available through the LEGISPAN system. asamblea.gob.pa/legispan-2

No specific regulatory agency is identified in the available text as having been designated primary authority for virtual asset securities oversight under Law 697. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The official legislative portal for Panama can be accessed through the Asamblea Nacional website infrastructure, which houses legislative records and bill tracking. asamblea.gob.pa/legispan-2

The law's scope is limited to "commercial activities and virtual asset services," and does not specifically address securitization, tokenized securities, or digital asset securities as a distinct category under securities law. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

As of 2025–2026, Panama has not designated a named securities regulator with specific jurisdiction over digital asset securities, and no amendments to the securities laws specifically addressing virtual assets have been identified. asamblea.gob.pa/legispan-2

The Superintendencia del Mercado de Valores (Securities Market Superintendency) of Panama is mentioned in the context of the broader securities framework, but specific grant of authority over cryptocurrency securities under Law 697 is not documented in the available text. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

Panama is a member of the Financial Action Task Force (FATF) through the GAFILAT (Financial Action Task Force of Latin America) regional body, but no current mutual evaluation report on Panama's virtual asset regime is cited in the provided materials. asamblea.gob.pa/legispan-2

The legislation's regulatory status remains as enacted law, but implementing regulations that would operationalize the digital asset securities framework have not been produced according to the accessible legislative records. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

Law 697 of 2021 does not establish a specific licensing regime with defined license categories, capital thresholds, or application procedures for virtual asset service providers operating in the securities space. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

No capital requirements expressed in monetary figures (USD or otherwise) for virtual asset securities firms are specified in Law 697, and no minimum capital thresholds have been published in implementing regulations. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

ZERO entities have been licensed under any virtual asset securities licensing framework in Panama, as no licensing mechanism has been operationalized and no registry of licensed virtual asset service providers exists. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The application timeline for any future licensing regime is unspecified, as the law defers to secondary legislation that has not yet been promulgated. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

Structural requirements for licensed entities, including corporate governance, operational resilience, and risk management standards for virtual asset securities businesses, are not enumerated in the available law text. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The law does specify that activities such as exchanging, transferring, or safeguarding virtual assets on behalf of third parties would be subject to regulation, but the precise scope covering these activities under securities laws requires clarification by authorities. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

There is no publicly available application form, fee schedule, or processing procedure for any virtual asset license, confirming the absence of a functional licensing pathway. asamblea.gob.pa/legispan-2

The absence of implementing regulations means that even if an entity wished to seek authorization, there is no clearly defined regulatory counterpart or submission process to follow. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

Law 697 references that virtual asset service providers must comply with anti-money laundering (AML) and counter-financing of terrorism (CFT) obligations, aligning with FATF standards applicable to virtual assets. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

Customer due diligence (CDD) requirements under Panamanian law would be derived from existing AML statutes applicable to financial institutions, and Law 697 subjects virtual asset businesses to these same obligations. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

Suspicious transaction reporting (STR) obligations for virtual asset service providers would be channeled through Panama's Financial Analysis Unit (Unidad de Análisis Financiero), the designated financial intelligence unit, consistent with the law's AML framework. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

Record retention requirements for virtual asset transactions follow the general AML standards under Panamanian law, requiring documentation of customer identification and transaction details for statutory periods. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

Beneficial ownership transparency obligations apply, requiring virtual asset service providers to identify and verify the ultimate beneficial owners of legal entity customers per Panama's corporate transparency requirements. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The law expects the designated regulatory authority to issue AML-specific guidance for virtual asset service providers, but no such guidance is available as of 2025–2026. asamblea.gob.pa/legispan-2

PEP screening obligations for virtual asset firms align with Panama's national AML law, requiring risk-based identification of customers holding prominent public functions or their family members and close associates. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

No enforcement actions, penalties, fines, arrests, or regulatory sanctions against virtual asset service providers for securities violations have been identified in the available Panamanian regulatory sources. asamblea.gob.pa/legispan-2

The lack of an operational regulatory framework means that enforcement mechanisms for virtual asset securities infractions have not been publicly exercised by Panamanian authorities. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

No specific cases involving unauthorized virtual asset securities offerings, unlicensed exchange operations, or AML failures by crypto businesses in Panama have been documented in the legislative records reviewed. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

No tax guidance has been issued for virtual assets, including digital asset securities, under Panamanian law as of 2025–2026. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The law explicitly covers only commercial and business regulatory aspects of virtual assets, with tax treatment left to the general provisions of Panama's Código Fiscal (Tax Code) which has not been amended to address cryptocurrency. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

No rulings, circulars, or administrative interpretations from Panama's Dirección General de Ingresos (General Directorate of Revenue) regarding taxation of virtual asset securities have been published. asamblea.gob.pa/legispan-2

The absence of implementing regulations under Law 697 creates significant legal uncertainty for businesses attempting to operate virtual asset securities platforms in Panama. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

There is no designated supervisory authority with clear jurisdiction over virtual asset securities, meaning businesses cannot determine which regulator to approach for guidance or authorization. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The lack of licensing mechanism exposes legitimate businesses to regulatory risk while providing a permissive environment for unlicensed actors, creating an uneven playing field. asamblea.gob.pa/legispan-2

No clear legal distinction is drawn between virtual assets that constitute securities versus those that are payments, commodities, or other categories, creating classification uncertainty. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

International compliance expectations from FATF and foreign counterparties may not be met due to Panama's incomplete regulatory infrastructure for virtual asset service providers. asamblea.gob.pa/legispan-2

Businesses face reputational and legal risks from operating in a jurisdiction where the regulatory framework exists in statute but lacks operational meaning in practice. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

The gap between paper law and practical reality means that even compliant businesses cannot secure recognized authorization, while non-compliant operators face no imminent enforcement threat. asamblea.gob.pa/APPS/SEG_LEGIS/PDF_SEG/PDF_SEG_2020/PDF...

Future implementing regulations from the Asamblea Nacional could impose requirements retroactively or with short compliance deadlines, creating transition risk for existing market participants. asamblea.gob.pa/legispan-2