---
title: "Panama Crypto Regulation Monitor | cryptoassets.gi"
canonical: https://cryptoassets.gi/jurisdictions/panama/
source_html: /jurisdictions/panama/index.html
description: "Panama crypto asset regulation: 9 categories, 25 sourced findings, updated 2026-11-04. Licensing, token classification, stablecoins, tax treatment."
generated_at: 2026-11-07T14:19:44Z
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---
# Panama Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed unregulated gap overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/panama/), [World Payments](https://payments.gi/jurisdictions/panama/)

Last updated 2026-11-04 · 9 categories · 25 sourced
findings · 30 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-11-04 · Position last changed: 2026-11-04 · Record history & provenance &#9662; Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

[Open in Co-Pilot &#8599;](/reports/?type=copilot&j=PANAMA)[Build Report](/reports/?j=PANAMA)[Compare](/compare/?j=PANAMA)

Framework posture Unregulated gap 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority Órgano Judicial de Panamá Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) 2026-Q4 Anteproyecto de Ley 314 VASP/CASP licensing framework progression

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

9 Categories

0 Moved this cycle 0 Key judgments 4 Open gaps 25 Findings

7 Tier-1 sources

Confidence mix 9 unpopulated
(sums to 9 rendered categories; click to filter)

No categories moved this cycle.

## Jurisdiction lead brief

###### Latest update · 4 November 2026

#### Lead Signal

Panama&#x27;s crypto tax position moved from entirely silent to partially signposted this period, though the signpost itself is thin. Secondary commentary reports that the Direccion General de Ingresos began implementing the OECD&#x27;s Crypto-Asset Reporting Framework in 2026, which would be the first concrete sign of Panama&#x27;s tax authority treating crypto-asset holdings and transactions as a distinct reporting category rather than leaving them entirely outside the territorial tax net. No primary DGI instrument was found to confirm this, so the claim should be read as a reported direction of travel rather than an enacted obligation. For anyone tracking Panama as a low-friction jurisdiction for crypto activity, this is the one data point worth watching closely: if CARF reporting is confirmed in a DGI circular or resolution, it would be the first dedicated crypto-tax instrument the jurisdiction has produced.

#### Other Developments

Everything else in Panama&#x27;s crypto framework held its existing shape this period. There is still no dedicated crypto-asset or virtual-asset-service-provider law in force, and the Superintendencia de Bancos continues to disclaim regulatory competence over crypto exchange, investment and commercialisation activity. Draft Law No. 314, the comprehensive fintech framework that would introduce dedicated licensing categories for virtual-asset service providers, payment-service providers and electronic-money institutions aligned to FATF and OECD standards, remains in committee with no confirmed advancement since its introduction in January 2026. The Superintendencia del Mercado de Valores and the Superintendencia de Bancos continue to take the position that cryptocurrencies are not securities, financial instruments, legal tender or electronic money under current law, leaving token holders without a statutory classification to rely on. On consumer protection, the only instrument on record remains the Superintendencia de Bancos&#x27; 2018 public risk warning on Bitcoin and other cryptocurrencies, which is guidance rather than a binding custody, disclosure or market-conduct regime.

#### Cross-Monitor Connections

Panama&#x27;s crypto framework continues to lean heavily on general corporate and anti-money-laundering law rather than a crypto-specific regime, which means the jurisdiction&#x27;s AML/CFT posture carries disproportionate weight in practice for anyone assessing crypto-sector risk there; that broader AML/CFT picture is tracked elsewhere and is not re-derived here. No cross-border transfer rule specific to crypto-assets was identified this period beyond that general AML framework. No developments bearing on payments infrastructure more broadly, or on the jurisdiction&#x27;s gambling-sector regulatory posture, were connected to the crypto picture this period.

#### Outlook

The near-term question for Panama&#x27;s crypto framework is whether Draft Law 314 advances out of committee, which would be the first comprehensive statutory basis for virtual-asset licensing the jurisdiction has produced. In the interim, the reported move toward CARF reporting is the more immediate variable: if a primary DGI instrument confirming CARF scope and timing surfaces, it would mark Panama&#x27;s first dedicated crypto-tax rule and would warrant a closer look at compliance implications for exchanges and custodians with Panamanian touchpoints. Until then, the jurisdiction&#x27;s crypto-asset activity continues to sit in the gap between an absent licensing regime and a tax authority reportedly moving, but not yet confirmed to have moved, toward international reporting alignment.

4 earlier updates not shown here.

###### Standing brief · as of 25 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Panama&#x27;s crypto regulatory posture this cycle is defined by a widening gap between current practice and a pending legislative fix. Today, Panama crypto businesses are not subject to a dedicated virtual-asset-service-provider licence; instead, they are treated as obligated subjects under Law 23 of 2015, which requires AML/CFT compliance but was not designed as a crypto-specific licensing instrument. Anteproyecto de Ley N° 314, introduced 13 January 2026, would change this materially: it would require VASPs and CASPs to obtain a licence, implement a comprehensive AML/CTF programme, meet capitalisation and governance standards, and submit to supervision by the Superintendencia de Bancos de Panamá (SBP) and the Unidad de Análisis Financiero (UAF). The draft has not been enacted, and confirmation of its progress through the Assembly&#x27;s required debates was not located this cycle.

#### Other Developments

Tax treatment shifts on the horizon via CARF. Panama signed the OECD&#x27;s Crypto-Asset Reporting Framework (CARF) agreement in December 2025, with cross-border data exchange due to begin in 2027. This is a known forthcoming reporting obligation layered onto Panama&#x27;s current, comparatively favourable territorial tax treatment of crypto, under which foreign-sourced crypto income is generally exempt and no capital-gains tax applies. Whether Ley 314 itself would materially change this territorial tax treatment, as distinct from the CARF reporting obligation, has not been established this cycle.

#### Cross-Monitor Connections

Anteproyecto de Ley N° 314&#x27;s licensing dimension is the same draft law tracked by the financial-integrity monitor (D5, D7) and the world-payments monitor (W1a) for its PSP/EMI licensing effect; this brief treats the draft only from the crypto-specific licensing and tax-treatment angle, without re-analysing the underlying AML/CFT architecture, which those monitors cover directly.

#### Outlook

The single most consequential item to watch next cycle is confirmation of Ley 314&#x27;s progress through the Assembly&#x27;s three required debates; a T1 Asamblea source would resolve the current gap in legislative-status confidence. On tax treatment, the approaching 2027 CARF data-exchange start date is the clearer near-term milestone, while any change to Panama&#x27;s underlying territorial/capital-gains treatment of crypto under Ley 314 remains unconfirmed and worth tracking as the draft develops.

Read full brief · 880 words

Key regulatory facts for Panama Regulatory Dimension Panama Standing Position

Jurisdiction Panama (PA)

Regulatory Scope Crypto & Digital Asset Regulation (9 modules, 25 sourced findings)

Crypto Licensing Panama has no dedicated crypto/VASP licensing statute in force.

Token Classification Panama has no statutory taxonomy for crypto-assets (no per-se definitions of utility token, security token, e-money token, or stablecoin).

On-Chain Activity Regime No Panamanian statute, regulation, or published regulator guidance specifically addresses staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization.

Stablecoin Regime Panama has no statute or regulatory framework authorising, licensing, or imposing reserve/redemption requirements on stablecoin issuers.

Primary Instruments Cited Órgano Judicial de Panamá, Superintendencia del Mercado de Valores de Panamá, World Bank Group / Superintendencia de Bancos de Panamá, Superintendencia de Bancos de Panama (SBP), Draft Law No. 314 (Ley Marco Integral de Tecnologias Financieras)

Last Confirmed / Updated 2026-11-04 (30 sources in cumulative register)

9 of 9 categories

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### Panama: C1 Crypto LicensingRedEnacted in forceModule confidence: Probable&#9662;

Panama has no dedicated crypto/VASP licensing statute in force. Bill 697 (2022) was struck down as unconstitutional in July 2023. Two successor efforts are pending: Bill 247 (introduced March 2025) and Draft Law 314 (introduced January 2026), which would create licensing for VASPs, PSPs and EMIs together.

Horizon · 2026-Q4 (± six months) Anteproyecto de Ley 314 VASP/CASP licensing framework progression Proposed · Tier 3 source

Horizon · 2027-Q1 (± a year) Draft Law 314 fintech/VASP licensing framework Consultation · Tier 3 source

Horizon · 2026-Q4 (± six months) Draft Law 314 / Bill 326 VASP-PSP-EMI framework expected movement Proposed · Tier 3 source

Horizon · 2027-Q1 (± a year) Anteproyecto de Ley N.314 fintech/VASP framework Consultation · Tier 3 source

#### Crypto Licensing

Panama currently has no dedicated virtual-asset-service-provider licensing regime. Crypto businesses operating in Panama are not subject to a specific licence but are treated as obligated subjects under Law 23 of 2015, which requires AML/CFT compliance from a broad range of financial and non-financial actors without establishing a crypto-specific supervisory perimeter. This is a standing baseline position with no change this cycle.

The material development is Anteproyecto de Ley N° 314, introduced in the National Assembly on 13 January 2026, which would require virtual-asset and crypto-asset service providers to obtain a licence, implement a comprehensive AML/CTF programme, meet capitalisation and governance standards, and submit to joint supervision by the Superintendencia de Bancos de Panamá and the Unidad de Análisis Financiero. This would be Panama&#x27;s first dedicated crypto-licensing instrument. The draft remains unenacted, and whether it has advanced beyond its January 2026 introduction through the Assembly&#x27;s three required debates has not been confirmed this cycle; only secondary legal commentary, not a direct SBP, UAF or Asamblea source, was available.

#### Outlook

The key development to watch is whether Ley N° 314 advances through the Assembly&#x27;s remaining legislative stages. Until enactment, Panama&#x27;s crypto-licensing posture remains an unregulated gap bridged only by general AML obligations under Law 23 of 2015, rather than a licensed regime.

Read full sub-brief · 212 words Periodic update · new data 2026-09-14

#### Crypto Licensing

Panama has no dedicated crypto or virtual-asset service provider licensing law in force. Bill 697, the jurisdiction&#x27;s first comprehensive attempt at crypto legislation, was declared unconstitutional in its entirety by the Supreme Court in July 2023, a ruling confirmed via press corroboration though direct retrieval of the court&#x27;s own text was not achieved this cycle. That ruling left Panama without any dedicated crypto legislation, a status that persists into this cycle at confirmed confidence.

Since the 2023 ruling, two separate legislative efforts have emerged to fill the gap, and their relationship to one another remains unresolved. Bill 247, introduced 20 March 2025, proposes VASP licensing alongside stablecoin recognition and a special tax regime for crypto; it was referred to a National Assembly subcommittee on 30 September 2025 and remained unenacted as of May 2026. Separately and more recently, Draft Law 314, the Ley Marco Integral de Tecnologías Financieras, was introduced 13 January 2026 and proposes a broader licensing framework covering virtual-asset service providers together with payment-service providers and electronic-money issuers, positioned as the country&#x27;s first dedicated licensing framework for VASPs specifically. Neither bill has been enacted, and whether one is intended to supersede the other, whether they are complementary, or whether they are simply competing drafts has not been resolved this cycle; confirming this would require direct review of the Asamblea Nacional&#x27;s own record.

The supervisory authority most closely associated with crypto-adjacent activity today is the Superintendencia de Bancos de Panamá, which oversees AML exposure for bank-touching crypto businesses, though this is a general banking-supervision function rather than a dedicated crypto mandate. In the absence of any licence requirement, crypto businesses operating in or from Panama today do so without a bespoke authorisation regime, while AML exposure remains real through the general banking-supervision channel.

#### Outlook

Draft Law 314 carries a regulatory-horizon expectation of 2027-Q1 at the consultation stage, while Bill 247&#x27;s own progression is expected around the same broad window but remains at the earlier proposed stage. Until the relationship between the two competing tracks is clarified and one, both, or neither receives a confirmed enactment path, Panama&#x27;s crypto-licensing status should be read as genuinely unsettled rather than trending toward regulation on a fixed timeline. The most consequential development to watch for is any Asamblea Nacional record clarifying whether Bill 247 and Draft Law 314 are being reconciled into a single track.

1 earlier distinct update(s) Periodic update · new data 2026-09-06

#### Crypto Licensing

Panama has no comprehensive crypto-licensing statute in force. The Superintendencia de Bancos de Panama (SBP) has maintained, since 2018, that crypto exchange, investment, and commercialisation activities are not specifically regulated and fall outside its stated supervisory competence absent dedicated legislation. This is a confirmed structural finding, assessed with probable confidence from a Tier-3 legal-commentary source describing the regulator&#x27;s own longstanding position, and it defines the baseline: Panama is, and has been, an unregulated-gap jurisdiction for crypto licensing.

Anteproyecto de Ley 314, filed 13 January 2026, is the current legislative vehicle attempting to close this gap. It would create Panama&#x27;s first dedicated VASP/CASP licensing framework, with prudential supervision vested in the SBP and AML/CFT oversight vested in the UAF. This is assessed with confirmed confidence as to the bill&#x27;s content and filing, sourced from a Tier-3 publication, though the bill has not been enacted, is not binding, and requires further Assembly debates and presidential assent before it could take effect.

The bill&#x27;s context matters for assessing enactment probability. It is the third legislative attempt at this reform: Bill 697 was found partially unconstitutional, and Bill 247 of 2025 also failed to advance to enactment. Whether Bill 247 remains live in parallel with Anteproyecto de Ley 314 was not established this cycle, which is itself a gap worth flagging, since parallel or competing legislative vehicles could affect the timeline and shape of any eventual reform.

Separately, token classification in Panama continues to rest on a fact-specific, activity-based test applied by the Superintendencia del Mercado de Valores (SMV), assessing whether a token structure functions as a security, involves a public offering, intermediation, or custody, rather than applying a technology-based classification framework. This is a stable, in-force approach assessed with probable confidence, and it operates independently of whatever VASP/CASP licensing perimeter Bill 314 might eventually establish; a token could be caught by the SMV&#x27;s securities-law test regardless of the separate VASP licensing question.

#### Outlook

The committee and plenary progression of Anteproyecto de Ley 314 is the determinative item to watch for Panama&#x27;s crypto-licensing landscape, with an expected impact window in the fourth quarter of 2026 and a half-year uncertainty band reflecting the bill&#x27;s early stage. Given the precedent of two prior failed attempts at this same reform, enactment should be treated as genuinely uncertain rather than a near-certainty, and the current committee or debate stage of the bill as of September 2026 remains unestablished pending further primary-source research.

1 further periodic run re-emitted the standing brief unchanged and is not shown.

Sources and findings (8)
- T1[Órgano Judicial de Panamá](https://www.organojudicial.gob.pa/cendoj/files/fallos-de-interes?page=4) — Panama&#x27;s National Assembly-approved virtual-asset bill (Proyecto de Ley No. 697 de 2021), which would have created a licensing/registration regime for virtual asset service providers, was declared wholly unconstitutional (&#x27;inexequible&#x27;) by the Pleno of the Supreme Court of Justice, per a ruling published 4 May 2023, and therefore never entered into force as an operative licensing framework.
- T1[Superintendencia del Mercado de Valores de Panamá](https://supervalores.gob.pa/download/opinion-07-2018/) — A Panama-incorporated company operating a virtual/cryptocurrency exchange platform using bitcoin as the exchange medium, without offering registered securities, is not required to notify or register with the Superintendencia del Mercado de Valores (SMV), per SMV Administrative Opinion 07-2018, unless the crypto-asset structure itself qualifies as a &#x27;valor&#x27; (security) under general Securities Law.
- T1[World Bank Group / Superintendencia de Bancos de Panamá](https://www.superbancos.gob.pa/documentos/evaluaciones_fmi/NT-SPN-Pagos-Panama-Payments-TN.pdf) — As of August 2026, Panama has no dedicated statute establishing a crypto-asset/virtual-asset service provider licensing regime; other integrated payment-system bills prepared with Inter-American Development Bank assistance deliberately excluded the controversial crypto provisions and have not been presented to the National Assembly.
- T3[Superintendencia de Bancos de Panama (SBP)](https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/panama/trends-and-developments) — Cryptocurrency exchange, investment and commercialisation activities are not within SBP&#x27;s regulatory competence
- T3[Draft Law No. 314 (Ley Marco Integral de Tecnologias Financieras)](https://lexlatin.com/entrevistas/anteproyecto-ley-314-panama-regular-fintech-inversion) — Dedicated VASP, PSP and EMI licensing categories aligned to FATF/OECD standards; introduced 13 January 2026, not yet enacted
- T3[Superintendencia de Bancos de Panamá (SBP) / UAF](https://vantegris.com/blog/panama-crypto-regulation/) — No VASP/CASP licence is currently required to exchange, custody or transfer virtual assets in Panama; only AML registration with the UAF under Law 23/2015 applies to obligated subjects
- T3[Anteproyecto de Ley N.314](https://lexlatin.com/entrevistas/anteproyecto-ley-314-panama-regular-fintech-inversion) — Dedicated VASP/PSP/EMI licensing under SBP supervision with a regulatory sandbox, filed 13 January 2026, remains at draft/committee stage
- T3[Anteproyecto de Ley N.314](https://lexlatin.com/entrevistas/anteproyecto-ley-314-panama-regular-fintech-inversion) — Administrative fines of up to USD 2 million for non-compliant fintech/VASP activity once enacted

### Panama: C2 Token ClassificationAmberEnacted in forceModule confidence: Probable&#9662;

Panama has no statutory taxonomy for crypto-assets (no per-se definitions of utility token, security token, e-money token, or stablecoin). The Superintendencia del Mercado de Valores (SMV) instead evaluates token structures case-by-case against the general statutory definition of &#x27;valor&#x27; (security) under the Securities Law, as illustrated by its 2018 administrative opinion addressing both bitcoin and gold-backed tokens.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

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### Panama: C3 On-Chain Activity RegimeAmberEnacted in forceModule confidence: Probable&#9662;

No Panamanian statute, regulation, or published regulator guidance specifically addresses staking, DeFi lending, DEX operation, mining, node operation, validator activity, or tokenization. These activities fall outside any existing licensing perimeter absent an ad hoc securities or banking characterisation by SMV or SBP respectively.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-11-04

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### Panama: C4 Stablecoin RegimeRedEnacted in forceModule confidence: Probable&#9662;

Panama has no statute or regulatory framework authorising, licensing, or imposing reserve/redemption requirements on stablecoin issuers. Stablecoins such as USDC and USDT circulate informally, including acceptance by the Panama City municipal government for local tax and fee payments via a bank-conversion arrangement announced in April 2025, entirely outside any national stablecoin-specific prudential regime.

Horizon · 2027-Q1 (± a year) Bill 247 crypto/stablecoin licensing bill progression Proposed · Tier 3 source

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-11-04

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### Panama: C5 Consumer ProtectionAmberEnacted in forceModule confidence: Probable&#9662;

General consumer-protection matters (misleading advertising, commercial quality/warranty complaints) fall to the Autoridad de Protección al Consumidor y Defensa de la Competencia (ACODECO) under Law 45 of 2007, but ACODECO has no crypto-specific rulebook. Consumer-protection jurisdiction over banks is separately reserved &#x27;exclusively&#x27; to the Superintendencia de Bancos under Article 198 of the Banking Law, and the World Bank FSAP assessment flagged this SBP/ACODECO split as difficult for consumers to navigate. Separately, the SMV has issued public investor warnings on cryptocurrencies and ICOs.

Absence reason not determinable No sub-brief exists and the JID records no gap or review marker explaining why. The renderer will not invent a reason.

No periodic updates recorded in this cycle

Sources and findings (3)
- T1[World Bank Group / Superintendencia de Bancos de Panamá](https://www.superbancos.gob.pa/documentos/evaluaciones_fmi/NT-SPN-Pagos-Panama-Payments-TN.pdf) — General consumer-protection complaints regarding crypto-adjacent products/services would fall under ACODECO pursuant to Law 45 of 2007 (misleading advertising, commercial quality complaints), while consumer-protection jurisdiction over banks is separately reserved exclusively to the Superintendencia de Bancos under Article 198 of the Banking Law, creating a fragmented perimeter for crypto-adjacent products.
- T1[Superintendencia del Mercado de Valores de Panamá](https://supervalores.gob.pa/smv-advertencia-sobre-criptomonedas-y-icos/) — The Superintendencia del Mercado de Valores has issued public investor warnings regarding cryptocurrencies and Initial Coin Offerings (ICOs), cautioning investors and the general public about associated risks, without this constituting a binding disclosure regime for crypto issuers.
- T4[Superintendencia de Bancos de Panama (SBP)](https://newhedge.io/buy/panama) — SBP has issued public risk warnings about Bitcoin and other cryptocurrencies (Aviso 5 of 2018) rather than binding custody/disclosure/market-abuse rules specific to crypto-assets

### Panama: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable&#9662;

Panama operates a territorial tax system under which tax rules apply only within Panamanian territory (Código Tributario, Artículo 15), so foreign-source income is generally outside the scope of Panamanian income tax. However, no crypto-specific statute currently codifies how this territorial principle applies to crypto-asset gains after the 2022-2023 virtual-asset bill (which would have expressly classified crypto as foreign-source income exempt from capital-gains tax) was declared wholly unconstitutional. Crypto tax treatment therefore rests on the general territorial principle applied case-by-case by the Dirección General de Ingresos (DGI), rather than a codified crypto rule.

Periodic update · new data 2026-10-18

#### Tax Treatment

Panama signed the OECD&#x27;s Crypto-Asset Reporting Framework (CARF) in December 2025, with CARF-based reporting reported to have begun in 2026. This is uncertain in confidence; the pinpoint commencement date and the specific implementing instrument were not independently verified against a primary OECD or Panamanian government source this cycle. The CARF commitment introduces an information-exchange reporting obligation applicable to crypto-asset service providers, requiring them to report crypto-asset transactions for exchange with partner tax authorities under the framework&#x27;s standard.

Importantly, this reporting commitment does not itself establish a crypto-specific domestic tax rule in Panama. Panama&#x27;s underlying tax treatment of crypto-asset gains and income continues to be governed by its general territorial tax system, under which income sourced outside Panama is generally not subject to Panamanian tax, with no crypto-specific carve-out or clarification identified this cycle. The practical effect of CARF, once its commencement is confirmed, is therefore primarily informational and cross-border in nature: Panama would begin exchanging crypto-asset transaction information with CARF partner jurisdictions, independent of any change to how crypto gains are taxed domestically.

The absence of independently verified primary-source confirmation for the commencement date is a meaningful gap. Secondary commentary describes reporting as having begun in 2026, but without a verified instrument or effective date, the precise scope of obligated crypto-asset service providers and the specific transactions covered cannot be stated with confidence at this time.

#### Outlook

Primary confirmation from the OECD&#x27;s CARF implementation tracker or Panama&#x27;s Ministry of Economy and Finance would resolve the current uncertainty around commencement date and implementing instrument. Until such confirmation is available, crypto-asset service providers operating in Panama should treat the reporting obligation as reported but not fully verified in its operational detail. No indication was found this cycle of a parallel domestic tax-law change addressing crypto-asset income directly.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

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### Panama: C7 Cross-Border TransferAmberEnacted in forceModule confidence: Probable&#9662;

No crypto-specific cross-border transfer restrictions, outbound limits, or crypto-specific reporting thresholds have been identified in Panamanian law. Cross-border crypto transfers appear to be governed only by general foreign-exchange, banking, and AML/CFT rules applicable to regulated financial institutions, which were not researched in crypto-specific detail in this run (deferred in part to the FIM aml_ctf subscription).

Periodic update · new data 2026-10-25

#### Cross-Border Transfer

Panama&#x27;s cross-border crypto-asset transfer posture is defined this cycle by an international commitment that has outpaced domestic implementing legislation. The Direccion General de Ingresos signed the OECD&#x27;s Crypto-Asset Reporting Framework Multilateral Competent Authority Agreement in December 2025, roughly a month before Panama&#x27;s National Assembly received the Anteproyecto de Ley N.314, the draft comprehensive financial-technology law that would eventually create a licensing regime for virtual-asset service providers, payment companies and electronic-money institutions under the Superintendencia de Bancos de Panama. This sequencing, an international tax-information-exchange commitment preceding domestic licensing legislation, is the key structural fact for anyone assessing Panama&#x27;s cross-border crypto-asset-transfer exposure.

The Crypto-Asset Reporting Framework operates by requiring reporting crypto-asset service providers to collect and report information on transactions to their home tax authority, which then automatically exchanges that information with the tax authorities of account holders&#x27; jurisdictions of residence. For this mechanism to function as intended, there generally needs to be a clear domestic legal basis identifying which entities qualify as reporting crypto-asset service providers and what data they must collect. In Panama&#x27;s case, no dedicated virtual-asset-service-provider or crypto-asset-service-provider licence currently exists; the only applicable requirement for entities exchanging, custodying or transferring virtual assets is general anti-money-laundering registration with the Unidad de Analisis Financiera under Law 23 of 2015. This means Panama&#x27;s CARF commitment currently sits without a bespoke domestic reporting-entity framework specifically tailored to crypto-asset activity, relying instead on the broader anti-money-laundering registration population as the closest existing analogue.

From the perspective of firms or counterparties engaging in cross-border crypto-asset transfers involving Panama, this combination, an international automatic-exchange commitment layered onto a general AML registration regime rather than a specific VASP licensing and reporting framework, creates some uncertainty about how CARF reporting obligations will practically be operationalised domestically until the Anteproyecto de Ley N.314 or an equivalent instrument is enacted. The draft law remains at committee or draft stage with no confirmed date for a first legislative debate, so the timeline for closing this implementation gap is not yet established.

#### Outlook

Panama&#x27;s CARF commitment is enacted at the international level but not yet effective in practical domestic-reporting terms, pending either the enactment of the Anteproyecto de Ley N.314 or some other mechanism identifying and obligating domestic crypto-asset reporting entities. As scheduled, this gap is likely to persist until the draft law, or an equivalent, advances beyond its current committee stage; no first-debate date has yet been confirmed, so the practical cross-border reporting architecture for Panama&#x27;s crypto-asset sector remains unsettled for the near term.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 2 traced claims · Re-verified 2026-11-04

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### Panama: C8 AML/CFT RegimeGreenEnacted in forceModule confidence: Probable&#9662;

Crypto subscribes to the FIM aml_ctf module at the consumer level; no aml_cft_regime claims are produced in this baseline to avoid duplication. For disambiguation context only: Panama&#x27;s general AML/CFT framework is led by the Superintendencia de Bancos (e.g., Rule 1-2026 on prevention of misuse of banking and fiduciary services, and Rule 3-2026 on administrative sanction criteria), but these instruments are not crypto-specific and were not researched for crypto-specific applicability in this run.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

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### Panama: C9 Commercial Activity limited signal unpopulated &#9662;

## Commercial Activity

P2P.me, a Panama-domiciled crypto entity, closed a Series A funding round of $7.2 million on 28 March 2026, led by Coinbase Ventures with participation from Multicoin Capital. This is uncertain in confidence, sourced from a vendor data aggregator rather than a company press release or a primary regulatory filing, and the reported amount and closing date should accordingly be treated as reported rather than independently confirmed.

The round is notable for its investor composition: both Coinbase Ventures and Multicoin Capital are established, internationally active crypto-focused venture investors, and their participation in a Panama-domiciled round signals continued international investor interest in Panama as a base for crypto-sector commercial activity, notwithstanding the jurisdiction&#x27;s continued operation without a dedicated VASP licensing statute. Broader sector context reported by the same vendor aggregator places aggregate Panama crypto-sector funding at approximately $21.5 million across three rounds through May 2026, though this aggregate figure carries the same sourcing caveat as the P2P.me round itself.

No other crypto-sector commercial event, merger, acquisition or product launch dated within this cycle&#x27;s window was identified for Panama. — Outlook: Confirmation of the P2P.me round against a primary filing or company disclosure would strengthen confidence in this finding. Continued investor interest from internationally recognised crypto-venture funds in Panama-domiciled entities, despite the jurisdiction&#x27;s unregulated-gap licensing status, is a trend worth tracking into subsequent cycles as a potential indicator of how commercial activity and regulatory status interact in practice.

Open gap — crypto-int-4 No Panama-incorporated or Panama-headquartered crypto-sector commercial event (M&A, investment, partnership, product launch) was identified this cycle. no under-indexing note recorded

No periodic updates recorded in this cycle

Sources and findings (1)
- T4[P2P.me](https://tracxn.com/d/explore/cryptocurrencies-startups-in-panama/__-tLpks05Qs8FQ1B_D5oSeyCitJf9BT6fqg5X5JYGJes) — P2P.me closed a Series A funding round of $7.2M on 28 March 2026, led by Coinbase Ventures and Multicoin Capital; stage completed per vendor data aggregator, not independently confirmed against a primary filing.
