By means of Agreement No. 0002-2019, the Banking Superintendence of Panama modified Agreement No. 10-2015 on the prevention of improper use of banking and fiduciary services. The new Agreement includes certain additional requisites which banks and fiduciary companies must take into account when determining their clients' profiles and when assigning them risk profiles, including the Tax ID number from their country of origin and an affidavit stating that the flows of income and the exiting of funds towards the banking or fiduciary entity comply and will continue to comply with the tax obligations in place in their country of tax residence.
Additionally, Panamanian offshore entities will have to submit to banks and fiduciary companies an affidavit which demonstrates they comply with their respective tax obligations.
With respect to a client's transactional profile, there are now rules in place for banks and fiduciary companies to follow up on their clients' transactional movements, in order to determine if there are any material inconsistencies with the profile established when the relationship started, as well as to establish the client's risk profile.
Finally, notifications on suspicious transactions to the Financial Analysis Unit shall be made immediately.