Law 23/2015 establishes measures to prevent money laundering, financing of terrorism and financing of proliferation of weapons of mass destruction. A recently published resolution adds requirements for all non-financial obliged individuals and professionals who perform activities under supervision.
Resolution N.I-REG-003-017 from May 8, 2017 establishes that all non-financial obliged persons and professional who perform activities under supervision, either natural or legal persons are obliged to complete the Extra Situ Assessment Form.
This obligations are applicable to companies performing activities/transactions with:
1. Real estate company and construction
- Promoters
- Construction companies
- Real estate agent
- General contractors
- Specialized contractors
- Real estate broker
2. Free Zones and Foreign Trade
- Free zone
- Pacific Panama
- Barú Free Zone and Free Trade Zones
3. Casinos and gambling
4. Gubernamental entities
5. Professional activities
- Accountants
- Lawyers
- Notary Public
- Others
6. Mixed
- Bags with diamonds
- Metals and gemstones trade
- Automobile
- Pawnshop
- Securities transportation
Take action
Liable persons, non-financial liable persons and professionals must submit the Extra Situ Assessment Form in Excel format with the requested information on or before September 29, 2017. Once completed, the forms must be sent electronically through the link dully registered at the UAF and by email at int-extrasitu@mef.gob.pa, directly sent by the legal representative.
This form will not be extended as an affidavit. Noncompliance of said regulation involves monetary penalties ranging from B/.5, 000 to B/.1, 000,000, and administrative sanctions such as: cancellation, restriction or removal of licences and suitability certificates.
For more information, please contact us.