PANAMA Trends and Developments Contributed by: Teresa Carballo and Edgar Young, Pacifica Legal
risk that operators in this space should be tracking, alongside the territoriality rules that determine when an online activity is treated as conducted “from Pan- ama”, which is why geo-blocking Panamanian users is a common precautionary measure while the debate continues. Asset managers One area deserves a clear warning, because it is a common point of confusion for clients arriving from tra- ditional finance. A regulated Panamanian asset man- ager, meaning a licensed investment adviser or bro- kerage firm, cannot currently manage crypto-assets as part of its regulated activity. The SMV’s opinions, taken together, are explicit that crypto-assets are not securities or financial instruments and are therefore not within the list of permissible activities for these licensees; Opinion 5-2023 in particular states that the management of cryptocurrencies is not encompassed by the regulated activities of investment advisers and brokerage firms, and Opinion 1-2023 confirms the related limits on what licensed securities houses may do with digital assets. In practice, this means that crypto “asset management” in Panama is carried out through unregulated structures rather than licensed entities, which is the opposite of the situation in many other jurisdictions and something clients often need to have explained early in the conversation. Part 3 – regulatory proposals on the horizon Panama’s permissive environment exists against a backdrop of recurring legislative attempts to change it. Over the years, roughly a dozen bills have touched crypto in some way, most notably Draft Bill No 697/2021 on cryptocurrencies (approved by the National Assembly in 2022), but it never entered into force, as it was partially vetoed by President Lauren- tino Cortizo and later struck down by the Supreme Court of Justice of Panama. In 2023 and 2024, there were no significant proposals made to the National Assembly concerning crypto- assets. This changed in 2025, when we saw a signifi- cant increase in the number of proposals and in inter- est in crypto among assembly members and across different industry sectors.
The current cluster of bills At present, several proposals are in circulation that would, in different ways, regulate crypto-assets; most are before the National Assembly, while at least one has been submitted to the executive. Without going into the full text of each proposal, the cluster includes, among others: • Draft Bill No 247/2025, “Establishing the Regula- tory Framework for the Use of Cryptocurrencies and Promoting the Digital Economy in Panama”: This draft mainly concerns public policies on the use, commercialisation, and supervision of cryp- tocurrencies in Panama; the promotion of a digital economy; alignment with international standards; and consumer protection. • Draft Bill No 326/2025, “Establishing the Compre- hensive Legal Framework for the Supervision, Reg- istration and Control of Virtual Asset Service Pro- viders in Accordance with International Standards on Anti-Money Laundering and Counter-Terrorist Financing”: This bill establishes a legal framework for the supervision, registration, and control of VASPs in Panama. Its main goal is to establish a VASP regime compliant with FATF standards. • Draft Bill No 424/2025, “Establishing the Regula- tory Framework for Virtual Asset Service Provid- ers in Panama and Enacting Other Provisions”: It proposes a VASP framework. Its main goal is to create a licensing and supervision regime to ensure legal clarity, consumer protection, and the integra- tion of the virtual asset sector into national AML/ CFT systems. • In late 2025, the Panamanian Capital Markets Association (APAMEC) put forward a draft bill on virtual assets and VASPs. Submitted to Panama’s Ministry of Finance for consideration, it aims to regulate crypto-asset activities and establish a legal framework to support the digital transforma- tion of Panama’s financial system. It touches on digital assets, VASP licensing, a proposed regu- latory sandbox, and broad modifications to the securities markets and the tax regime. • Draft Bill No 427/2026, “Comprehensive Frame- work Law on Financial Technologies (Fintech) in Panama”: This draft bill establishes a legal frame- work to regulate, promote, and supervise fintech companies in Panama (for example, PayTech,
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