The 40 FATF Recommendations: What They Ask of a SONF in Panama

How the international standard against money laundering, terrorist financing and proliferation financing is organised, and the recommendations a non-financial obligated entity works with every day.

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The Financial Action Task Force (FATF) sets the international standard for preventing money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction: 40 recommendations, last updated in December 2025, grouped into seven sections.

The Recommendations are addressed to countries. What binds a SONF is the Panamanian law that brings them in: Law 23 of 2015, its regulations and the rules of the SSNF. In Spanish, the FATF text says "lavado de activos" and Panama's Law 23 of 2015 says "blanqueo de capitales": both name the same offence.

The Seven Sections of the 40 Recommendations

Section	Recommendations
AML/CFT policies and coordination	1 and 2
Money laundering and confiscation	3 and 4
Terrorist financing and proliferation financing	5 to 8
Preventive measures	9 to 23
Transparency and beneficial ownership of legal persons and arrangements	24 and 25
Powers and responsibilities of competent authorities	26 to 35
International cooperation	36 to 40

The preventive measures are the section that reaches obligated entities most directly. Sections 1 to 3, 6 and 7 mostly ask things of the State: criminalising the offences, confiscation, supervision and cooperation between countries.

The Recommendations a SONF Works With

In the FATF's words, the SONF are designated non-financial businesses and professions (DNFBPs). These are the recommendations that reach them.

Recommendation 1: risk-based approach

Countries must require financial institutions and DNFBPs to identify and assess their risks and to take effective, risk-based action to mitigate them: identifying risks, assessing threats and vulnerabilities, and applying controls proportionate to them.

In Panama, Agreement JD-02-2022 asks the SONF for its own risk assessment, reviewed at least once a year, which the SSNF can request.

Recommendation 10: customer due diligence

Four measures: identify the customer and verify their identity with reliable, independent sources; identify the beneficial owner and understand the ownership and control structure; understand the purpose and nature of the relationship; and monitor the relationship on an ongoing basis.

If the measures cannot be completed, the relationship is not started or is ended, and a suspicious operation report is considered.

Recommendation 11: record keeping

Transaction records kept for at least five years, sufficient to reconstruct each transaction; and the due diligence records, account files, business correspondence and the results of any analysis, for at least five years after the relationship ends.

Everything must be available to the competent authorities, which is what a supervision checks.

Recommendation 12: politically exposed persons

For a foreign PEP, as customer or beneficial owner: systems to detect them, senior management approval, reasonable measures to establish the source of wealth and of funds, and enhanced ongoing monitoring.

For a domestic PEP or one from an international organisation, the same measures when the relationship is higher risk. They extend to family members and close associates.

Recommendations 22 and 23: DNFBPs

Recommendation 22 extends due diligence and record keeping to lawyers, notaries and accountants when they carry out transactions for their clients (buying and selling real estate, managing money or assets, creating or managing companies), to real estate agents, to dealers in precious metals and stones on cash transactions at or above the threshold, to company and trust service providers and to casinos.

Recommendation 23 adds internal controls and the suspicious operation report. In Panama that report is the ROS, filed with the UAF.

Recommendations 24 and 25: beneficial ownership

Adequate, accurate and up-to-date information on who ultimately owns or controls legal persons and arrangements, which the authorities can reach quickly through a registry or an alternative mechanism. No new bearer shares, and measures against the misuse of nominee shareholders and directors.

In Panama that registry is the RUBF, created by Law 129 of 2020 and fed by resident agents.

These Recommendations, Put to Work in COX

A risk matrix that scores each customer and leaves its reasoning on record, due diligence files with the beneficial owner and the ownership chain, list and PEP screening with enhanced due diligence when it applies, the ROS prepared with its review and approval trail, and every document and change kept as evidence for the SSNF.

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Frequently Asked Questions

Not by themselves. They are addressed to countries, and each country brings them into its own law. In Panama that law is Law 23 of 2015, with its regulations and the rules of the SSNF, and that is what a SONF must comply with.

Designated non-financial businesses and professions: the FATF's name for lawyers, notaries, accountants, real estate agents, dealers in precious metals and stones, company and trust service providers and casinos. In Panama they are the non-financial obligated entities (SONF) supervised by the SSNF.

Under Recommendation 22, when they prepare or carry out transactions for a client in the listed activities: buying and selling real estate, managing money, securities or other assets, managing accounts, organising contributions for companies, and creating, operating or managing legal persons or arrangements. The Panamanian rule says which activities make a lawyer a SONF.

At least five years: from the transaction for transaction records, and from the end of the relationship for due diligence records. The term that binds a SONF is the one in the Panamanian rule.

Recommendation 12, and Recommendation 22 extends it to DNFBPs. It asks for enhanced measures with every foreign PEP, and with domestic PEPs when the relationship is higher risk, including their family members and close associates.

This guide is for informational purposes only and does not constitute legal advice. It summarises the FATF Recommendations, updated to December 2025, without replacing them: confirm the obligations that apply to you in Panamanian law, with the SSNF or with a Panamanian adviser.

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