Crypto Licence in Panama: Complete Guide to Registration, AML Compliance & Banking

Entrepreneurs researching a crypto license in Panama need to start from one key fact: as of today, Panama has no enacted, standalone virtual asset service provider (VASP) licensing regime. Draft Law No. 314, the Ley Marco Integral de Tecnologías Financieras, was introduced to the Asamblea Nacional on 13 January 2026 to create such a framework, but it remains at the draft stage. This does not mean crypto businesses cannot operate lawfully or access Panamanian banks — it means that the practical route to a Panama crypto license today is corporate and compliance-driven rather than licence-driven. SBSB Fintech Lawyers helps clients build exactly this kind of bankable structure, combining company formation, tax registration, AML compliance, and a documentary pack that satisfies local banks.

Current Regulatory Status of a Crypto License Panama Operators Rely On

Panama currently addresses crypto activity through existing legislation rather than a dedicated virtual-asset framework. The Superintendencia de Bancos de Panamá (SBP) supervises licensed banks and trust companies but does not issue a crypto or VASP license and does not supervise crypto businesses themselves. Panama’s core anti-money laundering statute, Law 23 of 2015, sets out AML/CFT obligations for financial and non-financial obligated subjects (sujetos obligados), which are supervised by the SBP and other financial regulators or by the Intendencia de Supervisión y Regulación de Sujetos No Financieros, respectively. The Unidad de Análisis Financiero (UAF), Panama’s financial intelligence unit, receives and analyses suspicious-transaction and other reports from obligated subjects.

Draft Law No. 314 would change this landscape by proposing a technology-neutral licensing framework covering virtual asset service providers, custodial wallets, e-money issuers, and payment-service providers, and by designating supervisory authorities for these activities in line with Financial Action Task Force (FATF) guidance. Until the Asamblea Nacional enacts the bill, however, businesses seeking a crypto license in Panama should rely on the corporate-plus-AML pathway described below rather than wait for legislative approval.

Step-by-Step Process for a Crypto License Panama Companies Can Build Toward

Because there is no enacted VASP regime, obtaining what is commonly called a crypto license in Panama really means assembling a bundle of corporate, tax, and AML measures that together allow lawful operation and, most importantly, access to a bank account. The process generally follows eight sequential stages.

1. Choose the entity and corporate form. The standard vehicle is a Sociedad Anónima (S.A.), Panama’s joint-stock company, requiring at least three directors and three officers (president, secretary, treasurer), a Panamanian registered agent, and articles of incorporation drafted in Spanish with an object clause broad enough to cover digital-asset services.

2. Complete tax registration (RUC). Once the S.A. is registered, the company obtains its Registro Único de Contribuyente with the Dirección General de Ingresos, a prerequisite for both the operating notice and bank account opening.

3. File the Aviso de Operación. This operational notice, filed electronically through the Panamá Emprende portal, formally authorizes the company to conduct business and is typically issued within a few business days once supporting documents are uploaded.

4. Obtain a certified Public Registry extract. This document confirms the company’s good standing, directors, officers, and registered agent, and is required by every bank approached afterward.

5. Assess AML/CFT status and complete registrations. Depending on its business model, the company may qualify as an obligated subject under Law 23 of 2015. In that case, it must complete the registrations required by the competent supervisory authority and the UAF and designate a compliance officer. This assessment should be made with local counsel before launch.

6. Design and document an AML/CFT programme. A written compliance framework covering customer due diligence, transaction monitoring, suspicious-activity reporting, and record retention is essential both for meeting AML/CFT obligations and for convincing banks that the operation is well-controlled.

7. Build operational and technical controls. Custody architecture, transaction-monitoring technology, reconciliation procedures, and a cybersecurity framework should all be documented before approaching a bank.

8. Assemble the bank documentary pack. This final and often most challenging step brings together every document a bank’s compliance team will request before scheduling an onboarding call.

Operators who present their full documentary pack proactively, rather than waiting for banks to request documents piecemeal, consistently experience shorter onboarding timelines, our regulatory team notes when advising clients preparing for the Panamanian banking process.

AML Compliance for a Crypto License in Panama

AML/CFT compliance is the single most critical element of the pathway toward a crypto license in Panama. Where a crypto business qualifies as an obligated subject, or where a bank requires equivalent controls as a condition of onboarding, the compliance framework generally includes:

• designating a compliance officer and documenting their identification, professional background, and appointment by board resolution;
• adopting a written AML/CFT programme, a risk-assessment matrix, and a staff training plan;
• filing suspicious-transaction reports (Reportes de Operaciones Sospechosas) with the UAF and cash-transaction reports where applicable thresholds are met;
• conducting customer due diligence, including identification of beneficial owners;
• reviewing the risk assessment and updating compliance-officer details on an annual basis.

Recordkeeping obligations are not optional: supervisory authorities may request transaction logs, due-diligence files, and internal investigation notes during an inspection, and Law 23 of 2015 generally requires these records to be retained for at least five years.

Bank Access: The Documentary Pack Behind a Panama Crypto License

Securing a Panamanian bank account is widely regarded as the hardest practical hurdle for any digital-asset business, since banks supervised by the SBP carry their own regulatory exposure and remain cautious about crypto-related clients. The table below summarizes the core documents typically requested.

When a bank raises concerns about crypto-related risk, addressing them directly — explaining the company’s AML/CFT status, an AML programme aligned with FATF standards, and documented, auditable custody controls — tends to resolve most objections. Businesses that cannot secure a direct bank account often turn to Banking-as-a-Service partnerships with a sponsor bank or an international electronic money institution as an interim solution.

Corporate Structure, Substance, and Cost Considerations

The S.A. remains the default corporate vehicle for fintech operations in Panama, and its formation involves several practical steps.

Substance considerations matter beyond formal paperwork. While Panamanian law does not impose a minimum employee requirement for an S.A., banks increasingly expect genuine local presence — a physical office, at least one Panama-resident director, and local payroll. Nominee directors remain legally permissible but can trigger enhanced due diligence during bank onboarding. Panama’s territorial tax system generally exempts income sourced outside the country from local income tax, although transactions involving Panamanian clients or infrastructure may create separate tax obligations, so professional guidance is essential before finalizing a corporate structure.

Obligations by Entity Type Seeking a Crypto License Panama Recognizes

Not every digital-asset business faces the same compliance burden. The comparison below outlines how obligations differ across common business models.

• Custody and exchange platforms exchanging fiat for crypto or executing transfers on behalf of clients face the fullest compliance burden: a complete AML programme, suspicious-transaction reporting, a full bank-facing documentary pack, and demonstrable custody and technology controls.
• Payment and e-money service providers handling customer funds must maintain payment-flow diagrams, reconciliation policies, and the registrations required where AML obligations apply.
• Non-custodial services, such as wallet-viewing or data-only platforms, carry comparatively lower compliance risk but still require company registration and an Aviso de Operación to access banking services.

Get Legal Support for Your Crypto Business in Panama

Since 2013, SBSB Fintech Lawyers has supported fintech and crypto businesses in navigating jurisdictions where regulation is still evolving, including building bankable, compliant structures in Panama. Our team handles company formation, RUC and Aviso de Operación filings, AML/CFT status assessment and registrations, AML/CFT programme development, and the preparation of a complete documentary pack tailored to the expectations of Panamanian banks. Contact our team at yuliya_barabash@sb-sb.com to discuss your business model and receive professional legal support with building a compliant crypto business structure in Panama.