Panama International Banking License

It is one of the three classes of banking licence established by Article 41 of the Banking Law. It permits a bank to direct, from an office established in Panama, transactions that are perfected, consummated or produce their effects abroad, together with such other activities as the Superintendency of Banks of Panama authorises. It is a full prudential banking authorisation, not a registration.

Those falling within the international scope described in Article 41, together with other activities specifically authorised by the Superintendency, which has issued rules identifying certain additional activities and interbank arrangements available to internationally licensed banks. The permitted activity set is defined by the licence, the regulations in force and any conditions attached to the resolution — not by the bank’s own commercial ambitions.

The licence is designed for transactions that are perfected, consummated or produce their effects abroad. It is not a licence for unrestricted domestic banking with Panama residents. Whether any particular relationship with a Panamanian resident is permissible must be analysed under Article 41 and the regulatory criteria in force before it is offered.

Deposit-taking is possible within the international scope of the licence, subject to regulatory analysis, the authorised activity set and any conditions imposed. Deposit products should never be assumed; they are designed, documented in the business plan and reviewed as part of the application.

Lending is likewise possible within the scope of the licence and subject to the credit-risk, concentration, capital and provisioning rules applicable to banks. The lending model, target markets and underwriting standards form part of the business plan submitted with the application.

Card issuance is not automatic. It requires legal and regulatory analysis of the product, the scheme relationships, the settlement model and the associated operational, fraud and technology risk, and it may require specific authorisation. Card-network membership is a separate commercial matter decided by the networks.

Payment and transfer services must be analysed individually against the licence scope, the transfer-of-funds and electronic-banking rules and the AML framework. They are neither automatically included nor automatically excluded.

Yes, a licensed bank may deliver its services through digital channels, subject to the electronic-banking, technology-risk, operational-risk, outsourcing and data-protection requirements applicable to banks. Digital delivery is a channel decision; it does not change the licensing category.

No. Agreement No. 3-2001 contemplates applications for General, International and Representative licences. “Neobank” is a business model description and not a separate licence category.

No. Some models do not involve the business of banking. The correct question is what the project actually does with customer funds and credit, not what it calls itself. That analysis must be completed before any licensing strategy is chosen.

A startup with only a concept, a website or an application is normally not ready. What matters is whether the project has capital, an experienced banking team, governance, risk and compliance frameworks and a viable plan. Some startups reach that standard by assembling a credible team and sponsor first.

An individual may be a promoter, but the applicant must demonstrate proven banking experience, financial capacity and a suitable management body. An individual with capital and no banking background will normally need to build a qualified team before a filing is realistic.

Agreement No. 3-2001 requires the applicant bank or its promoting group to possess proven experience in the operations for which the licence is sought, with a record showing gradual growth of financial capacity without significant or repeated setbacks. Experience is examined individually and collectively across the proposed directors, officers and executives.

It can, provided the project is supported by a genuinely qualified banking-management team, documented capital, transparent ownership and a viable business plan. Wealth alone does not substitute for banking competence.

Yes, subject to the requirements applicable to foreign applicants, including home-regulator authorisation or non-objection, consolidated and cross-border supervision, and evidence of physical presence and substantial operations in the home jurisdiction. The capital allocated to a Panamanian subsidiary must be constituted with funds additional to the head office’s capital.

Yes, on a similar basis. For branches the application also identifies the general attorneys-in-fact who will act as legal representatives, who must be resident in Panama, at least one of them of Panamanian nationality, and additional financial and portfolio information may be required.

It is an office in Panama established under a Representative Licence by an existing foreign bank that has physical presence, a head office incorporated abroad, substantial administration and operations in its home country and supervision by a foreign banking regulator. The licence must be requested by the bank to be represented.

No. Under Agreement No. 3-2001 the holder of a Representative Licence may not carry out any banking operation in or from its office in Panama under that licence, whether asset or liability operations, operations with generally or internationally licensed banks, with residents or non-residents, credit intermediation, intermediation in collections or payments, or the administration of capital or assets in trust.

A General Licence permits the business of banking anywhere in Panama as well as transactions effective abroad; an International Licence is built around directing, from a Panamanian office, transactions perfected, consummated or effective abroad. The General Licence carries a materially higher minimum capital and a broader domestic supervisory perimeter.

USD $3,000,000 of paid-in or assigned capital, net of losses, under Article 68 of the Banking Law. Of that amount, USD $250,000 is held as a guarantee deposit at Banco Nacional de Panamá or Caja de Ahorros, constituted exclusively in favour of the Superintendency.

USD $10,000,000 of paid-in or assigned capital, net of losses, under Article 68 of the Banking Law. The bank may not at any time allow its capital to fall below the applicable minimum.

No. It is a statutory regulatory capital floor. It excludes incorporation, offices, technology, staffing, consultants, audit, compliance systems, liquidity and operating runway. The total capital and operating budget must be developed through a project-specific financial and regulatory feasibility study.

Yes. Additional capital may be required according to the risk profile, the business plan or conditions imposed on the licence, and capital-adequacy, conservation-buffer and liquidity rules may require the institution to maintain resources above the statutory minimum on a continuing basis.

Article 68 refers to the minimum amount of paid-in or assigned share capital, net of losses, required to apply for and to maintain a banking licence, and the definitive licence stage requires compliance with that capitalisation requirement. Evidence of the capital and of the legitimate origin of the funds forms part of the file.

No. No licence of any class is issued to a bank in formation organised under Panamanian law whose capital is represented in whole or in part by bearer shares, nor where the capital of the legal person that would control the bank is so represented. The same exclusion applies to banks incorporated under foreign law with bearer shares.

Yes. The application requires detailed and reliable information confirming the identity, domicile, address, nationality and occupation of shareholders, directors and officers, together with ownership percentages and shareholdings. Nominee arrangements cannot be used to conceal the true owners.

Proven experience in the operations for which the licence is sought, held by the applicant bank or its promoting group, plus a management body whose experience in financial business, professional competence, integrity and background can be assessed individually and collectively.

Consolidated audited comparative financial statements of the applicant or promoting group for the two most recent fiscal year-ends, accompanied by interim financial statements. For foreign applicants these must be prepared under international accounting standards or US GAAP, and the interim statements are subject to a recency requirement.

Yes. A business plan demonstrating the viability of the bank and its contribution to the Panamanian economy is an express approval criterion under Article 48 of the Banking Law, and Agreement No. 3-2001 requires a description of the activities to be developed, with short-, medium- and long-term objectives.

Yes. Agreement No. 3-2001 requires a feasibility study containing the applicant’s financial projections, projected organisational functions and the expected profitability of the bank.

Yes. The application must include the procedures, policies, manuals and other documents developing the management of significant banking risks, including credit, interest-rate, operational, liquidity and legal risk, supplemented by the prudential agreements relevant to the proposed model.

Yes. A complete financial-crime framework is expected, aligned with the prevention rules in force. The current framework for the prevention of the misuse of banking and fiduciary services is Agreement No. 1-2026, published in Official Gazette No. 30450-A of 23 January 2026, which entered into force six months after promulgation.

Documentation of the core-banking environment, hosting and cloud governance, information security and cybersecurity architecture, access control, vendor due diligence and outsourcing contracts, business continuity and disaster recovery, incident response, fraud and transaction monitoring, authentication and onboarding, audit trails, regulatory reporting and data protection, proportionate to the proposed model.

A licensed bank is expected to have a real establishment in Panama, and the preoperational inspection verifies the location of the principal offices and the institution’s capacity to deliver its services. The scale and configuration of premises depend on the model and are confirmed with the Superintendency. Subject to the current Banking Law, applicable banking agreements and regulatory review by the Superintendency of Banks of Panama.

Yes. Agreement No. 3-2001 contemplates a meeting between the Superintendent, or the official designated, and representatives of the applicant bank or promoting group or their appointed attorneys, before the formal submission of the application. The meeting is not an approval.

The Banking Law sets review periods for the Superintendent’s decision which run from the complete submission of the required documentation and which may be extended at the Superintendent’s discretion. In practice the elapsed time is driven mainly by how long the promoting group takes to build a complete file. We do not commit to a fixed timeline.

Yes. The Superintendent has the power to grant or refuse the licence by reasoned resolution, and the grant may be made subject to particular quantitative or qualitative conditions requiring a signed commitment from the applicant or promoting group.

No. Completeness is necessary but not sufficient. The Superintendency assesses the substance of the applicant, the promoting group, the beneficial owners, the capital, the management, the plan, the technology, the governance and the risk and compliance framework, and retains full discretion.

The institution must complete its corporate registration and capitalisation, implement its operating platform, satisfy the preoperational requirements, pass inspection and then commence operations, after which it is subject to continuing prudential supervision, reporting and inspection.

Yes. Banks are inspected by Superintendency personnel before beginning operations under the licence, in order to verify their capacity to offer the proposed services.

Under the compiled text of Agreement No. 3-2001 published by the Superintendency, a bank granted a licence must commence operations within six months of the date of the resolution granting it, and must give the Superintendency at least sixty days’ advance written notice of the commencement of operations and the location of its principal offices. These periods remain subject to any later agreement, resolution or circular and to determinations by the Superintendency in a particular case.

No. Correspondent relationships are commercial decisions taken by other banks on the basis of their own risk appetite and due diligence. A Panamanian licence does not oblige any correspondent to open an account, and we do not guarantee correspondent banking.

No. Card-network membership and sponsorship are decided by the networks and sponsoring institutions under their own criteria. We do not guarantee card-network access.

Any crypto-asset component requires separate legal, risk, AML, technology and regulatory analysis and may affect the project’s viability. Nothing on this page should be read as indicating that such activity is accepted, permitted or straightforward.

Any crypto-asset component requires separate legal, risk, AML, technology and regulatory analysis and may affect the project’s viability. Source of funds, source of wealth, counterparty exposure, custody arrangements and the transparency of the promoting group would all be examined closely.

This page does not make representations about tax treatment. Panamanian tax consequences depend on the source and character of the income and on the rules in force, and must be confirmed with qualified Panamanian tax advisers. Tax advice and tax structuring are outside the legal fee for the application.

USD $25,000 in legal fees for the preparation and submission of one banking-licence application before the Superintendency of Banks of Panama. The written engagement letter controls the final scope.

The USD $25,000 fee applies to legal services for the regulatory application only. It does not include the incorporation of the banking entity, regulatory capital, government or supervisory charges, notarial expenses, Public Registry expenses, consultants, auditors, manuals, financial models, translations or any third-party cost.

Among other items: incorporation of the banking entity, resident-agent fees, notarial and Public Registry expenses, government and supervisory charges, regulatory capital, additional and operating capital, liquidity, office setup, technology and core-banking implementation, cybersecurity, business-plan, financial-model, feasibility, AML, risk and governance consultants, manuals, external and internal audit, accounting, CPA services, tax advice and structuring, foreign legal advice, apostilles, legalisations, certified translations, courier, travel, accommodation, immigration and employment matters, directors and executives, compliance personnel, correspondent-banking, card-network and payment-processor arrangements, vendor charges, insurance, preoperational implementation, post-licence compliance and any third-party professional fee.

No. Incorporation of the Panama corporation or banking entity is not included in the USD $25,000 legal fee and is quoted separately.

No. Business-plan, financial-model and feasibility consultants are engaged separately by the applicant and are not included in the legal fee. We provide legal review and regulatory coordination in relation to their output.

No. External audit, internal audit outsourcing, accounting and CPA services are not included and must be provided by independent qualified professionals.

Much of the preparatory work can be handled remotely through counsel, and the application is filed in Panama by the appointed attorneys. However, the Superintendency may require meetings, and the pre-filing meeting and preoperational stage may make attendance in Panama appropriate.

Not necessarily at every stage, but promoters should expect that senior representatives may need to attend meetings in Panama, particularly around the pre-filing meeting and the establishment of the institution. Requirements are confirmed case by case.

A high-level description of the promoting group, its banking experience, the ownership and ultimate beneficial owners, the available regulatory capital and separate operating budget, the proposed products, target clients and jurisdictions, the delivery and technology model, and any prior regulatory contact or adverse history. Please send a summary by email before transmitting any documents.