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Panama: SSNF Compliance

SSNF Compliance in Panama: Without the Headaches

COX helps non-financial obligated entities meet essential due diligence, risk assessment, and compliance documentation requirements under Panama's AML regulatory framework.

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SSNF Sector Coverage Audit-Ready Records AML Screening

This information is provided for general informational purposes and does not constitute legal advice.

What is the SSNF?

Panama's Intendencia de Supervisión y Regulación de Sujetos No Financieros (SSNF) supervises and regulates non-financial obligated entities to prevent:

Money Laundering
Terrorist Financing
Proliferation Financing

This information is provided for general informational purposes and does not constitute legal advice.

Panama AML Regulator
for Non-Financial Entities

Legal Framework

Key laws and regulations governing SSNF compliance

Law 23 of April 27, 2015

Establishes the legal foundation for Panama's AML/CFT framework and defines the obligations of non-financial regulated entities supervised by the SSNF.

Law 254 of November 11, 2021

Strengthens corporate transparency requirements in Panama, including obligations related to accounting records and beneficial ownership information for legal entities.

Executive Decree 35 of September 6, 2022 Key Update

Operationalizes Law 23 by requiring non-financial obligated entities to implement risk-based AML/CFT controls, maintain documented compliance policies, and generate auditable records for SSNF supervision.

Verify current text of regulations at the official Panama government portal. Laws may have been amended since publication.

Who Are Non-Financial Obligated Entities?

Organizations and professionals regulated by the SSNF in Panama

  • Colón Free Zone companies
  • Panama Pacífico entities
  • Free trade zone companies
  • Casinos and gambling operators
  • Real estate developers and brokers
  • Construction companies
  • Value transport companies
  • Pawn shops
  • Precious metals and gemstone traders
  • National lottery entities
  • Postal services
  • Vehicle dealerships
  • Professionals performing regulated activities (lawyers, CPAs, notaries)
Is your organization on this list? SSNF regulations impose concrete obligations: customer identification, beneficial owner verification, transaction monitoring, and compliance record-keeping. Non-compliance may result in administrative sanctions.

Sector Rules and Thresholds

Key transaction thresholds that trigger due diligence obligations

Pawn Shops

Resolutions JD-007-015 and JD-016-105

Customers exceeding B/.1,500 in one or multiple cumulative visits require Enhanced Due Diligence (EDD). The obligated entity must document customer identity and the purpose of the relationship.

Value Transport

Resolution JD-008-015

Companies providing value transport services must apply due diligence controls to all institutional clients. Compliance documentation must be maintained for regulatory review.

Precious Metals and Jewelry

Resolution JD-003-015

Enhanced controls required when:

  • Dealing with foreign buyers or suppliers
  • Operations exceed B/.10,000

Vehicle Dealerships

Resolution JD-004-015

Monthly operations exceeding B/.8,000 require the application of customer due diligence controls and documentation of the commercial relationship.

Always verify applicable thresholds against the current text of the relevant SSNF sector resolution for your activity.

Customer Due Diligence Requirements

Minimum compliance controls required for SSNF-regulated entities

Standard Due Diligence

  • Customer identification and identity verification
  • Beneficial owner identification for corporate clients: every individual holding 25% or more, per Executive Decree 35/2022
  • Documentation of the purpose of the business relationship
  • Transaction monitoring based on customer risk profile
  • Maintenance of compliance documentation for regulatory review

Enhanced Due Diligence (EDD)

Required when a customer is identified as a higher-risk profile:

  • Politically Exposed Persons (PEPs): current or former holders of prominent public functions
  • Close relatives of PEPs: family members within prescribed degree of relationship
  • Key associates of PEPs: persons with close business or personal relationships
EDD requires senior management approval and additional documentation of the legitimacy of funds.

How COX Supports SSNF Compliance

Practical tools to implement required AML controls efficiently

Digital Onboarding

Send customers a secure digital form to collect identification documents, contact data, and source of funds information: all without paper.

Compliance Workflow Automation

Configure onboarding workflows that match your sector's SSNF requirements. Approvals, document checklists, and escalation paths are managed systematically.

Risk Matrix Configuration

Define risk scoring rules based on customer profile, sector, geographic origin, and transaction patterns. Automatically classify customers as low, medium, or high risk.

Customer Compliance File

Each customer record consolidates identification documents, screening results, risk scores, and due diligence decisions in a single exportable compliance file.

Audit-Ready Documentation

Every action is logged with user identity and timestamp. Compliance logs are immutable and structured to support SSNF inspection and internal audit processes.

Watchlist and AML Screening

Screen customers against international sanctions databases, PEP lists, and configurable internal watchlists. Match scoring is adjustable to reduce false positives.

Exportable Compliance Reports

Generate PDF and CSV compliance reports by customer, date range, or risk category. Share with regulators, auditors, or senior management on demand.

API Integration Roadmap

Planned integration with AgileCheck AML for advanced automated screening, expanded watchlist coverage, and real-time alert feeds.

Encrypted Data Storage
Full Audit Trails
Role-Based Access Control
Secure Cloud Hosting

Start Building an Audit-Ready Compliance Process

COX provides the tools your organization needs to meet SSNF obligations with confidence, from customer onboarding to compliance reporting.

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Frequently Asked Questions

Common questions from compliance teams and regulated entities

SSNF regulations apply to all entities within regulated sectors regardless of size, including small businesses operating as vehicle dealers, pawn shops, real estate brokers, or precious metals traders. Sector-specific resolutions define the transaction thresholds that trigger due diligence obligations.

When a customer is identified as a Politically Exposed Person (PEP), SSNF regulations require applying Enhanced Due Diligence (EDD). COX flags PEP matches automatically during screening and prompts the compliance team to collect additional documentation and apply heightened monitoring.

No. COX is a compliance management tool that supports and documents the work of compliance officers and responsible parties. The platform automates data collection, screening, and documentation, but the legal responsibility for compliance decisions remains with the designated compliance officer or business owner.

For non-financial obligated entities the threshold is 25% or more of the shares, voting rights or interests, directly or indirectly, or effective control by other means: Law 23 of 2015 and Executive Decree 35 of 2022. Panama also has a second, lower threshold that does not replace it: Executive Decree 25 of 2026 (Official Gazette 30556-C) reduced the controlling person threshold for entity accounts from 25% to 10%, but only for FATCA and CRS reporting by financial institutions to the DGI. A law firm, accountant, real estate broker or casino does not move to 10% because of that decree. An entity subject to both regimes carries both numbers at once, for two different reports. In COX the percentage is a company setting, so your onboarding forms ask applicants for the threshold your own regime requires.

Executive Decree 35/2022 operationalizes Law 23 by requiring non-financial obligated entities to implement risk-based AML/CFT controls calibrated to their sector and customer profile. It mandates documented internal policies and procedures covering customer due diligence, beneficial ownership identification, and transaction monitoring. It also requires that all compliance activities generate auditable records: customer files, screening results, risk assessments, and decision logs: available for SSNF inspection at any time. Entities unable to demonstrate documented, risk-based compliance processes are subject to administrative sanctions even if no specific incident has occurred.

Yes. COX is modular. You can begin with essential customer identification and watchlist screening, then progressively add risk matrix scoring, enhanced due diligence workflows, and compliance reporting as your operations grow.

Yes. The platform includes screening against configurable watchlists and international sanctions databases. Match scoring is adjustable to reduce false positives while ensuring comprehensive coverage for your sector.

COX generates exportable compliance files per customer that include identification documents, screening results, risk scores, due diligence notes, and decision logs with timestamps. These records are structured to support regulatory inspections by the SSNF.

Thresholds vary by sector: pawn shops must apply enhanced controls for customers exceeding B/.1,500; vehicle dealers when monthly operations exceed B/.8,000; precious metals traders for operations exceeding B/.10,000 or involving foreign buyers. Always verify the applicable SSNF sector resolution for your specific activity.

COX is built on Odoo 19 and integrates natively with Odoo's sales, invoicing, and portal modules. API integration with AgileCheck AML for advanced screening capabilities is on the product roadmap.

This page provides general information about regulatory obligations in Panama and does not constitute legal advice. Regulated entities should consult with qualified legal counsel to determine their specific compliance obligations under SSNF regulations.

COX also serves:

Law Firms Accountants Real Estate Agents

COX also covers these countries:

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