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Licensing · Crypto · Panama

Structuring a crypto business in Panama

Panama does not currently issue a crypto or virtual asset service provider licence. Earlier attempts to legislate failed, and a new bill introduced in 2025 is still before the National Assembly. Crypto businesses can still operate from Panama, but they must be structured carefully around existing anti-money-laundering, securities and payments laws.

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Key facts
Crypto-specific licence
None in force as of October 2026
Pending legislation
Draft Bill 247 of 2025 (would create a National Council of Digital Assets)
AML framework
Law 23 of 2015
Adjacent regimes
Securities (SMV), money remittance (Law 48 of 2003), financial companies (Law 42 of 2001)
Previous attempt
Bill 697 struck down as unconstitutional (ruling published August 2023)
Legislative process
Three debates in the National Assembly, then Executive sanction
Currency
US dollar in circulation alongside the balboa
01

Overview

Panama has debated crypto regulation for several years without producing a dedicated statute. In 2022 the National Assembly passed Bill 697, which would have regulated the use and trading of crypto-assets, tokenisation and digital payments. The Executive partially vetoed it, and when the Assembly reworked the text beyond the objected articles, the Supreme Court declared it unconstitutional on procedural grounds; the ruling was published in the Official Gazette in August 2023. Crypto trading and use therefore remain outside Panama's financial legislation.

In April 2025 the Commerce and Economic Affairs Commission introduced Draft Bill 247 of 2025, which would regulate the use, commercialisation and supervision of cryptocurrencies and create a National Council of Digital Assets to coordinate the regime. As of early 2026, around seven fintech-related bills had been presented at different stages and none had been enacted. Any bill must pass three debates before going to the Executive for sanction or veto, so timing remains uncertain.

In the absence of a crypto law, regulators assess each business model against the existing perimeter. Tokens with investment characteristics may engage securities legislation supervised by the Superintendency of the Securities Market; fiat transfer services may require authorisation as a money remittance business under Law 48 of 2003; and lending models may fall under Law 42 of 2001 on financial companies. Law 23 of 2015 sets the risk-based AML framework for supervised financial entities, non-financial reporting entities and certain professions.

Panama is therefore best viewed as a corporate and banking base rather than a licensing jurisdiction for crypto. Operators serving regulated markets will typically pair a Panamanian holding or service company with a licence elsewhere, while keeping Panama operations within existing law and monitoring the progress of Bill 247.

02

Key benefits

  • Established corporate and foundation law widely used for international holding structures
  • US dollar economy, simplifying treasury and accounting
  • Territorial tax system for income not sourced in Panama (subject to specific rules)
  • No crypto-specific capital or licensing burden for activities outside existing regulated perimeters
  • Regional hub for Latin American operations with good connectivity
  • Can be combined with Panamanian residence options for founders
03

Requirements

  • Legal analysis of each product against securities, remittance and financial company laws
  • Panamanian corporation or foundation with registered agent and accurate beneficial ownership filings
  • Risk-based AML/CFT programme aligned with Law 23 of 2015 and FATF standards
  • KYC, sanctions screening and transaction monitoring proportionate to the client base
  • Separate licence where the activity falls within an existing regulated category
  • Banking relationships supported by transparent source-of-funds documentation
  • Ongoing monitoring of Bill 247 and any implementing regulations
04

Licence options & capital

Unregulated service company

For software, technology or non-custodial services that do not fall within securities, remittance or lending laws, supported by a formal legal opinion.

Securities route

Where tokens or services have investment characteristics, structuring under Panama's securities legislation with the Superintendency of the Securities Market.

Money remittance authorisation

For fiat transfer components of the business, authorisation under Law 48 of 2003.

Panama holding plus foreign licence

A Panamanian holding or treasury company owning a VASP licensed in another jurisdiction that serves regulated markets.

05

Step-by-step process

  1. 1

    Perimeter review

    Map products, flows and customers to existing Panamanian law and identify any regulated components.

  2. 2

    Structure design

    Decide on corporation or foundation, holding layers and where any licensed activity will sit.

  3. 3

    Incorporation

    Form the entity through a registered agent and file beneficial ownership information.

  4. 4

    Compliance build

    Implement AML/CFT, KYC and sanctions programmes and document the legal analysis.

  5. 5

    Banking and payments

    Approach banks and payment partners with a complete compliance pack.

  6. 6

    Regulatory watch

    Track Bill 247 and be ready to apply promptly if a licensing regime is enacted.

06

Typical documents

  • Legal opinion on the regulatory characterisation of the business
  • Articles of incorporation or foundation charter
  • Beneficial ownership information and registered agent due diligence
  • Passports, proof of address and CVs of directors and owners
  • Source of funds and source of wealth evidence
  • Business plan and token or product documentation
  • AML/CFT policy, risk assessment and KYC procedures
07

How Legal Wealth helps

Legal Wealth gives clients a candid view of what Panama can and cannot offer a crypto business today. We analyse the business against the existing perimeter, design a structure that combines a Panamanian entity with licences elsewhere where needed, and prepare the compliance documentation that banks and counterparties expect. We work discreetly with local counsel and registered agents, and we can integrate the structure into the principals' wider residence, holding and succession planning.

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08

Frequently asked questions

Can I get a crypto licence in Panama?

Not at present. There is no crypto-specific licence in force. Bill 247 of 2025 proposes a framework, but it had not been enacted as of early 2026.

Is crypto activity illegal in Panama?

No. It is not prohibited, but it is not specifically regulated either, so each model must be checked against existing securities, remittance and AML rules.

What happened to the 2022 crypto law?

Bill 697 was passed, partially vetoed and then declared unconstitutional by the Supreme Court on procedural grounds, with the ruling published in August 2023.

Will a Panamanian company help me access banks?

Banks will focus on the activity, ownership and compliance framework rather than the incorporation alone. A clear legal analysis and strong AML documentation are essential.

Should I wait for Bill 247?

If your model depends on a licence, it is usually better to license elsewhere now and keep Panama for holding or regional functions, reassessing once a law is enacted.

Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.

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