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Panama AML Compliance

PEP Screening in Panama:
Stay Compliant with AML Regulations

PEP screening in Panama identifies whether a client, a family member or a close associate is a politically exposed person and documents the enhanced due diligence that Law 23 of 2015 requires. COX runs the check against PEP registers and restrictive lists and keeps the evidence for the Superintendency of Non-Financial Subjects.

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Law 23 of 2015 Aligned Resolution S-008-2026 Ready Built for Panama & LATAM

PEP Risk Detection

Screening against PEP lists, sanctions lists and watchlists, with evidence of every search.

Regulatory Definition

What Is a PEP Under Panama AML Regulations?

Under Panama's Law 23 of 2015, a Politically Exposed Person (PEP) is an individual who holds or has held a prominent public function, national or foreign, or in an international organization. The Superintendence of Non-Financial Subjects (SSNF) lists the positions that qualify in Resolution S-008-2026.

PEP screening is a cornerstone of AML compliance in Panama. Regulated entities must not only identify the PEP themselves but also screen their family members, close associates, and anyone who may act as a beneficial owner on their behalf.

Important: A person is a PEP from the appointment until leaving office, and for a later period of no more than 2 years.

Key Regulation

Law 23 of 2015

AML/CFT Framework

Resolution S-008-2026

SSNF PEP Guide

PEP Classification

Who Qualifies as a PEP in Panama?

Resolution S-008-2026 of the SSNF lists which positions, relatives and associates count. Some typical examples:

Direct PEPs

Examples of prominent public functions:

  • Heads of State and Government
  • Ministers and Secretaries of State
  • Members of Congress / National Assembly
  • Supreme Court Justices
  • High-ranking Military / Police Officers
  • Executives of State-owned Enterprises
  • Ambassadors and Consuls
  • Electoral Authority Officials

Family Members

Relatives by blood, marriage or civil partnership, for example:

  • Spouse or domestic partner
  • Parents and in-laws
  • Children and their spouses
  • Siblings and their spouses
Family members are treated as PEPs while the PEP status lasts, with the measures their risk calls for.

Close Associates

People with close social or professional ties, for example:

  • Business partners or co-owners
  • Legal representatives or proxies
  • Beneficial owners of shared entities
  • Persons with significant joint transactions
Associates are often used to obscure PEP ownership of assets and accounts.
Mandatory Obligation

Why PEP Screening Is Mandatory for Compliance in Panama

PEP screening is not optional. Panama's anti-money laundering regulations require every regulated entity to implement risk-based customer due diligence that includes the identification and ongoing monitoring of politically exposed persons.

The Superintendence of Non-Financial Subjects (SSNF) and other regulatory bodies actively supervise compliance. Failure to screen for PEPs exposes your organization to severe consequences.

Legal Obligation

Required by Law 23 of 2015 for all regulated entities

Active Supervision

SSNF conducts regular inspections and audits

Continuous Monitoring

Ongoing PEP status checks, not just at onboarding

Audit Trail

Full documentation required for regulatory review

Regulatory Framework

Regulatory Requirements: Law 23 & Resolution S-008-2026

Two key regulatory instruments define PEP screening obligations in Panama. Both establish clear responsibilities for regulated entities.

Law 23 of 2015

AML/CFT Framework Law
  • 1 Establishes the obligation to identify PEPs during customer onboarding and ongoing relationships
  • 2 Requires enhanced due diligence (EDD) for foreign and domestic PEPs, as clients or beneficial owners
  • 3 Asks for senior management approval and the source of wealth and funds from financial obligated parties, and from non-financial ones where it applies
  • 4 Covers family members and close associates, with extended measures when the risk analysis calls for them
  • 5 Leaves middle-ranking and junior officials out of the PEP definition

Resolution S-008-2026

SSNF Comprehensive PEP Guide
  • 1 Issued by the SSNF on 24 February 2026
  • 2 Lists the positions that make someone a PEP
  • 3 Defines who counts as a close associate of a PEP
  • 4 Defines who counts as a close family member of a PEP
2
YEARS

Maximum Period After Leaving Office

Critical Compliance Requirement

The Two-Year Ceiling After Leaving Office

One of the most critical: and often overlooked: aspects of PEP compliance in Panama is the post-office classification period. Under Panama's AML regulations, a person does not stop being a PEP the day they leave public office.

Law 23 of 2015 keeps the PEP status for a later period of no more than two years after leaving office. The law sets the ceiling; within it, your risk analysis decides, and the file has to show why. In practice:

  • Record when the person took and left office
  • Keep enhanced due diligence while the PEP status lasts
  • Record the decision, and its reason, when the PEP treatment ends
  • Screen the client again at each review of the file
COX records the dates of office of every PEP, direct or linked, so the file shows when the period started. Deciding when the PEP treatment ends stays with your compliance officer: the platform does not end it on its own.
Risk Awareness

Risks of Not Identifying PEPs

Non-compliance with PEP screening obligations in Panama carries severe consequences that can impact your organization financially, legally, and reputationally.

Heavy Fines

Significant fines, sanctions, and restrictions may apply for AML non-compliance.

Inspection Findings

An SSNF inspection asks for the evidence of each check

Misuse of Your Business

Funds of public origin moving through your clients without anyone asking

Reputational Damage

Loss of trust from clients, partners, and correspondent banks

Key Risk Signals to Watch For

  • Unusual or unexplained high-value transactions
  • Use of shell companies or complex corporate layers
  • Unclear source of funds or source of wealth
  • Transactions inconsistent with customer profile
  • Multiple accounts across different jurisdictions
  • Use of third parties or nominees to obscure ownership
  • Rapid movement of funds with no commercial rationale
  • Resistance to provide identification documents
Extended Screening

Beneficial Owner & Associate Screening

PEP risk doesn't stop at the individual. Panama's regulations require comprehensive screening of everyone connected to a PEP: especially through corporate structures.

The same applies in every country COX serves: alongside the politically exposed person, screen whoever controls or represents the entity: beneficial owners, directors, legal representatives and signatories. The ownership percentage that makes someone a beneficial owner is set by each country's regime, and COX reads it from your company's configuration instead of assuming one figure for everybody.

Corporate Structures

PEPs often use layered corporate structures, trusts, and foundations to hide beneficial ownership. Panama regulations require you to identify the ultimate beneficial owner (UBO) behind every legal entity.

COX records the ownership chain and weighs PEP exposure among beneficial owners in the risk matrix.

Close Associates

Business partners, legal representatives, and co-owners of PEPs must be identified and monitored. Associate screening prevents PEPs from using intermediaries to bypass compliance controls.

COX records associates as linked persons, each with its own PEP status and screening.

Family Networks

Relatives of a PEP are treated as PEPs while the PEP status lasts. Operations conducted through family members deserve the same attention as those of the PEP themselves.

COX links family members to PEP records for unified risk assessment.

The Solution

How COX Solves PEP Screening in Panama

Purpose-built for regulated entities in Panama and Latin America. COX automates every step of the PEP screening process.

Automated PEP Detection

Screen individuals and entities against PEP lists, sanctions lists and watchlists during onboarding.

Intelligent Risk Scoring

Configurable risk matrices evaluate PEP exposure across multiple indices: sector, geography, products, and more.

Alerts on New Matches

Continuous monitoring checks your files against each new edition of the lists and opens an alert for review.

Audit-Ready Reports

Generate compliance documentation instantly: risk assessments, screening results, and due diligence reports.

Enhanced Due Diligence

The risk matrix flags when a file requires EDD, and the file cannot be approved until it is documented.

Relationship Mapping

Record family members, associates and beneficial owners, and weigh indirect PEP exposure through corporate structures.

Continuous Monitoring

Files are checked again against every new edition of the lists, not only at onboarding.

LATAM-Ready Platform

Panama, Mexico, Colombia, Guatemala, the Dominican Republic and Venezuela, in Spanish and English.

Built for Regulated Entities
AML Regulation Aligned
Panama & LATAM Ready
Enterprise-Grade Security

Start Screening PEPs Today

Don't wait for a regulatory inspection to discover gaps in your PEP screening process. COX automates compliance so you can focus on growing your business.

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FAQ

Frequently Asked Questions

Everything you need to know about PEP screening requirements in Panama.

Under Panama's Law 23 of 2015, a Politically Exposed Person (PEP) is an individual who holds or has held a prominent public function, national or foreign, or in an international organization. The treatment extends to their family members and close associates, and the SSNF lists the positions that qualify in Resolution S-008-2026.

Law 23 of 2015 treats a person as a PEP from the appointment until leaving office, and for a later period of no more than 2 years. Within that ceiling, how long the enhanced measures last is a risk-based decision that the file has to document.

Yes. PEP screening is mandatory for all regulated entities in Panama under Law 23 of 2015 and Resolution S-008-2026. This includes financial institutions, non-financial subjects (lawyers, accountants, real estate agents, dealers in precious metals and stones), and any entity supervised by the SSNF or other regulatory bodies. Failure to comply exposes the obligated party to the sanctions the law provides.

No. Panama regulations require screening not only direct clients but also their family members, close associates, and beneficial owners of corporate structures. This extended screening is essential to detect indirect PEP exposure and prevent the use of intermediaries or shell companies to circumvent controls.

The sanctions are the ones Panamanian law provides for AML non-compliance, and the SSNF supervises the non-financial obligated parties. Beyond the sanction, a file without evidence of the PEP check cannot answer an inspection, and the reputational damage can cost correspondent banking relationships.

Resolution S-008-2026, issued by the Superintendence of Non-Financial Subjects (SSNF) on 24 February 2026, is its comprehensive guide on the positions that make someone a PEP, and on who counts as a close associate or a close family member of one. It complements Law 23 of 2015.

Yes. COX screens individual persons (natural persons) and legal entities (juridical persons) including their beneficial owners, directors, and related parties. For legal entities, COX also supports composite entity structures where one legal entity is linked to another, allowing deep PEP detection across complex corporate hierarchies.

Yes. COX serves Panama, Mexico, Colombia, Guatemala, the Dominican Republic and Venezuela, in Spanish and English, and each company configures its own regime. The PEP screening page explains how the rule changes in each of them.

This page is provided for informational purposes only and does not constitute legal advice. Regulatory references are based on publicly available information as of September 2026. For specific compliance guidance, consult a qualified legal professional.

Explore more compliance solutions:

PEP Screening in Every Country SSNF Panama Compliance Digital Onboarding All Services

Guides on this topic:

What the Clinton List is What a PEP is Due diligence and KYC

COX also covers these countries:

Panama Mexico: PLD software Mexico: LFPIORPI Colombia Ecuador Guatemala Dominican Republic Venezuela
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