Self-custodial wallet / non-custodial software in Panama

No Crypto-Specific Licensing Regime: As of late 2023 / early 2024, there is no specific "virtual asset license" in Panama issued by a dedicated crypto regulator.

General Business Registration: Any company wishing to operate in Panama, including those involved in virtual assets, must still:

Be incorporated under Panamanian law (Public Registry).

Obtain a business license ("Aviso de Operación") from the Ministry of Commerce and Industries.

Primary Relevance: This is the most likely regulator to assert jurisdiction over virtual asset activities, mainly for AML/CFT compliance. Panama is a member of the Financial Action Task Force (FATF) and is committed to implementing its recommendations, which include regulating VASPs for AML/CFT purposes.

Requirement: While not a "license," these entities would need to register with the SSNF for AML/CFT oversight and comply with all associated requirements.

Regulatory Reference: Law 23 of 2015 (Ley 23 de 2015, que adopta medidas para prevenir el blanqueo de capitales, el financiamiento del terrorismo y el financiamiento de la proliferación de armas de destrucción masiva). This law designates certain entities as "obligated subjects" (sujetos obligados) for AML/CFT purposes. While it doesn't explicitly name "VASPs," its broad scope and subsequent interpretations can cover them.

Relevance: If the virtual asset is deemed a "security" under Panamanian law, then the SMV would have jurisdiction. This is a crucial distinction.

Applicability: Projects issuing tokens that represent ownership, a right to profit, or other characteristics of traditional securities would fall under the SMV's purview. Exchanges listing such tokens, or custody providers holding them, would then need to comply with securities regulations.

Law 23 of April 27, 2015 (Ley 23 de 27 de abril de 2015): This is the foundational AML/CFT law in Panama. It adopted measures to prevent money laundering, financing of terrorism, and financing of the proliferation of weapons of mass destruction. It established the Financial Analysis Unit (UAF) and defined "obligated subjects" (sujetos obligados), which, through subsequent interpretations and amendments, have come to include VASPs. This law sets general obligations for customer due diligence, suspicious transaction reporting, and record-keeping.

Law 1 of January 5, 2024 (Ley No. 1 de 5 de enero de 2024): This is the most crucial and recent piece of legislation specifically for virtual assets. It amends Law 23 of 2015 and other related laws to define virtual assets and virtual asset service providers (VASPs), establish a licensing and supervision regime, and explicitly subject VASPs to AML/CFT obligations under the supervision of the Superintendency of Banks of Panama (SBP). This law ensures Panama's compliance with FATF Recommendation 15 on new technologies and VASPs.

Superintendencia de Bancos de Panamá (SBP) - Superintendency of Banks of Panama:

Unidad de Análisis Financiero (UAF) - Financial Analysis Unit of Panama:

Bill 697 / Law 173 (Proyecto de Ley No. 697 / Ley 173): This bill aimed to regulate the commercialization, use, and issuance of digital assets and create a framework for their recognition, custody, and tokenization. It specifically included provisions for:

Status: Partially Vetoed: The bill passed the National Assembly in April 2022. However, President Laurentino Cortizo partially vetoed it in June 2022.

Evolving Regulatory Framework: Panama has been discussing comprehensive cryptocurrency regulation, most notably with Bill 697, which was partially vetoed in 2022. This lack of a clear, dedicated crypto legal framework means that enforcement would likely fall under existing general financial laws (e.g., anti-money laundering, fraud), making it harder to categorize specifically as "crypto enforcement."

Failed Cryptocurrency Law (Bill 697):