SSNF Supervision in Panama: How to Prepare and What to Do
The four stages of a supervision by the Superintendency of Non-Financial Entities, the difference between on-site and off-site, and what the SSNF expects from you before and during the process.
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The Superintendency of Non-Financial Entities (SSNF) supervises how Panama's non-financial obligated entities (SONF) prevent money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction. This guide follows the consultation guide the SSNF itself gives to the SONF.
The Four Stages of a Supervision
1. Notification
The supervisory team sends a Start Note with the list of documents it will request and the date the supervision begins.
2. Execution
The supervisory team reviews the Prevention Programme and interviews the staff.
3. Analysis
The supervisory team analyses the information and documentation it received.
4. Closing
The supervisory team communicates the result of the supervision to the SONF.
The SSNF describes the aim of the process as confidential, transparent, efficient and agile.
How the SSNF Classifies Supervisions
Depending on where it takes place, a supervision is one of two kinds:
| Kind | Where each stage takes place |
|---|---|
| On-site supervision | Notification, analysis and closing take place at the SSNF; the execution stage takes place at the SONF's registered address |
| Off-site supervision | Every stage takes place at the SSNF |
By scope, a supervision is comprehensive, thematic, follow-up or special, and the SSNF also carries out beneficial owner verifications.
An on-site supervision means a visit: the supervisory team works at your premises during the execution stage.
How to Prepare for an SSNF Supervision
- Have the information and documentation up to date and at hand.
- Know how your business operates and be able to describe its activity to the supervisory team.
- Set aside a space at your premises for the supervision to take place.
- If you have a question about the process or the information requested, the SSNF has a team that can answer it or hold a meeting with you before the supervision.
What to Do During the Supervision
- Confirm promptly to the SSNF supervisory team that you are available to start the supervision.
- Deliver the information and documentation the supervisory team requires on time and in the format it asks for.
- Make sure the liaison person, or failing that the legal representative or the natural person, is available throughout the supervision to hand over what is required and to answer the team's requests and questions.
- Make sure you understand the process, including the tasks the supervisory team will carry out, and ask whenever something is unclear.
- Keep assertive and respectful communication with the supervisory team at all times.
What the SSNF Can Ask For
Lawyers and accountants
When they carry out supervised activities for a client, Agreement JD-02-2022 has them hand over on request the support for their due diligence, the list of clients of those activities (including the ones they stopped serving, and why), the support for the services provided, and their risk methodology with its results. Their own risk assessment is reviewed at least once a year, and the SSNF can ask for it and require changes to the manual.
A SONF that is not operating
A SONF that has not started or has stopped its activities is still registered with the SSNF. Under Resolution S-036-2026 the SSNF can ask it for information, documentation and support, including self-assessment questionnaires and on-site or off-site supervisions.
The Start Note says what will be requested in each supervision. Treat it as the list to answer, not as a summary.
Your Evidence, Ready Before the Start Note
One file per client with its due diligence and beneficial owners, list and PEP screening with a certificate of what was searched, a risk matrix, training records and an immutable trail of every decision. When the Start Note arrives, the documentation is already there.
COX for SSNF complianceFrequently Asked Questions
This guide is for informational purposes only and does not constitute legal advice. It summarises the SSNF's consultation guide for SONF without replacing it: confirm what applies to you with the SSNF or with a Panamanian adviser.
A Supervision Is Answered With Evidence
Start keeping it today, so the next Start Note finds it in order.
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