Fintech 2026

PANAMA Trends and Developments Contributed by: Kharla Aizpurua Olmos, Roberto Vidal, Miguel Arias and Eduardo Oteiza, Morgan & Morgan

guiding principles for regulation and designates the Superintendency of the Securities Market as the com - petent authority, proposing to empower it to conduct inspections, require records, order audits and issue binding rules for the industry. In parallel, the bill pro - poses a tax co-operation framework under which the Tax Authority would develop specific rules to support voluntary tax compliance in the virtual‑asset environ - ment, including a simplified electronic declaration regime. Finally, the bill provides that banks may engage in operations involving virtual assets voluntarily, always subject to institutional risk policies, enhanced KYC traceability procedures, and risk matrices in compli - ance with Law 23 of 2015. VASPs would be required to obtain a special licence to operate as such, which licence would be recorded and published in a pub - lic official registry with core transparency data, that would also list the services that the relevant licensed VASP is authorised to provide pursuant to its corre - sponding licence. 4. Draft Bill 487 of 2026, which aims to introduce a general legal framework for fintech in Panama The most recent legislative initiative regarding fintech regulation was introduced to the National Assembly in early January 2026. Out of all the draft bills being discussed, this one is probably the most exhaustive in attempting to regulate and lay the grounds for fintech expansion in Panama. The main goal of this proposal is to modernise the Panamanian financial system, attract investment and expand digital financial inclusion, all while protecting the system’s users. In essence, the framework would apply to fintech activities across defined “verticals” such as paytech/e‑wallets, crowd - funding, neobanks/digital banks, micro-lending, digi - tal assets (cryptocurrencies, tokens, NFTs, stable - coins, etc), wealthtech, insurtech and regtech, plus other modalities set out by regulation. In essence, the aim of this proposed law would be to bring together all the topics previously discussed in this article within a fintech-focused framework, hence the importance of individually regulating every one of these aspects as well. As with the draft bills discussed above, Draft Bill 487 of 2026 proposes a defined institutional structure for

fintech oversight. It would create a Special Fintech Regime administered by the Superintendency of Banks in co-ordination with the Superintendencies of the Securities Market, of Insurance and Reinsurance and of Non-Financial Entities. Within that framework, the bill would also establish a public‑private Interinsti - tutional Fintech Council to support policy co-ordina - tion and recommendations regarding regulation and supervision, financial‑digital education, incentives and international co-operation. To operate under the proposed fintech regime, a fin - tech provider would be required to register in a pub - licly accessible National Fintech Registry and obtain the relevant fintech licence from the Superintendency of Banks with licence categories depending on the activity performed. Non‑compliance would be sanc - tioned on a graduated basis (minor, serious and very serious infractions), and very serious breaches might carry fines of up to USD2 million, along with other measures such as licence suspension or revocation. In addition, the bill lays the groundwork for a “regula - tory sandbox”, co-ordinated by the Superintendency of Banks with participation from the Interinstitutional Fintech Council. The sandbox is conceived of as a controlled, supervised environment where potential and incumbent fintech companies can test innova - tive models with defined limits and for a limited period before either applying for the corresponding Fintech Licence or concluding the pilot. Finally, the bill includes specific chapters on Open Banking and on the use of AI in financial services, setting principles such as transparency, non‑discrimi - nation, proportionality and human oversight for critical decisions. Conclusion Panama’s current legislative efforts reflect a jurisdic - tion in the midst of defining a coherent, modern and risk‑sensitive framework for fintech, virtual assets and emerging technologies. While the draft bills under dis - cussion vary in scope and regulatory technique, they show a clear institutional intention to provide legal certainty, strengthen supervisory capacity and align with international standards, particularly in the areas of AML, consumer protection and market integrity.

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