Panama's Superintendency of Non-Financial Obligated Parties (Superintendencia de Sujetos No Financieros, SSNF) supervises the businesses and professions outside the banking system that must run anti-money laundering controls. Its Resolution S-033-2026 of June 19, 2026 sets guidelines for two things: checking clients against the United Nations Security Council sanctions lists and other applicable lists, and carrying out a preventive freeze in cases of money laundering, terrorist financing and financing of the proliferation of weapons of mass destruction.
The resolution took effect on publication in Official Gazette 30557-B on June 30, 2026. For a foreign investor or a compliance officer with Panamanian operations, the practical point is that your Panamanian lawyer, resident agent or real estate broker now works under written rules on what happens when a name comes back as a hit.
What the resolution sorts into two tiers
The resolution separates the lists a business must screen against into two categories with very different consequences. The table shows what changes when a client's name matches one or the other.
| UN Security Council lists | Control or reference lists | |
|---|---|---|
| Legal force | Mandatory and immediate in Panama | A tool for assessing risk only |
| Effect of a match | The assets must be frozen | No freeze and no automatic legal effect |
| Residual exposure | Administrative liability if ignored | Financial, contractual and reputational risk |
The UN lists name the persons and entities sanctioned under Security Council resolutions: Resolutions 1267 (1999) and 1988 (2011) on Al-Qaida, the Islamic State (Da'esh) and the Taliban; Resolution 1373 (2001) on terrorist financing; and Resolutions 1718 (2006) and 2231 (2015) on weapons of mass destruction and the programs that fund them. These lists change constantly, so screening is an ongoing duty rather than a one-time check at onboarding.
How a preventive freeze works
The resolution defines a preventive freeze (congelamiento preventivo) as the immediate retention of funds, property or assets owned or controlled by a person or entity on a UN list, together with a ban on disposing of them. The ban covers transferring, converting, disposing of or moving those resources. It is an administrative and precautionary measure, so no prior court order is needed, and it should not be confused with a court-ordered attachment in civil litigation under Panama's new Civil Procedure Code.
The legal basis is Article 49 of Law 23 of April 27, 2015, which orders an immediate preventive freeze once the UN lists distributed by the Financial Analysis Unit (Unidad de Análisis Financiero, UAF) are received. Executive Decree 587 of August 4, 2015 is the implementing regulation. In Panama an executive decree is issued by the President with the relevant minister to develop a statute, and it cannot go beyond the law it regulates. Article 41 of the same Law 23 adds enhanced due diligence for business with countries that, according to the Financial Action Task Force (FATF), do not apply sufficient anti-money laundering measures.
Which businesses have to screen
The duty falls on the non-financial obligated parties (sujetos obligados no financieros, SONF) described in Article 40 of Law 124 of January 7, 2020, as amended by Law 254 of November 11, 2021, and supervised by the SSNF. International standards call this group designated non-financial businesses and professions. It includes, among others:
- lawyers, accountants and resident agents, the licensed Panamanian lawyers or firms every local company must appoint;
- companies in the Colón Free Zone and other free zones;
- real estate developers and real estate brokers;
- casinos and gaming venues;
- dealers in precious metals and stones, pawnshops and other designated activities.
Each of them must check the lists during due diligence on clients, operations and transactions, and freeze when a match appears. If you hold a Panamanian company, this is one reason your resident agent keeps asking for updated information, the same logic behind Panama's ultimate beneficial owners registry.
Why this matters for Panama and its clients
List screening and preventive freezing are requirements of the FATF, specifically its Recommendations 6 and 7 on targeted financial sanctions. Panama left the FATF list of jurisdictions under increased monitoring in October 2023, and keeping this regime working is a condition for not being placed back on it. For clients, that translates into more questions at onboarding and less tolerance for incomplete files.
Failure to comply carries administrative liability before the SSNF, separate from any civil or criminal consequences that may apply. For a broader view of how these duties fit into a company's control framework, see our guide to regulatory compliance in Panama.
What obligated businesses should do now
The resolution is operational, so the work is mostly internal. A business under SSNF supervision can adapt in this order:
- Update the anti-money laundering manual and policies to reflect the two tiers of lists.
- Build screening against the UN lists into due diligence on every client, operation and transaction.
- Write a freezing and reporting protocol that can run immediately and without notice to the client.
- Train the staff responsible for compliance on both the screening and the freezing procedure.
Foreign clients setting up in the country can expect these checks from the start, as explained in our guide to starting a business in Panama.