Panama’s Superintendency of Banks has added an exception to its illustrative catalogue of politically exposed positions through Agreement 10-2026. Signed on October 15 and published in Official Gazette No. 30639-D on October 21, 2026, the measure took effect upon promulgation. The amendment is confined to a paragraph in Annex 1 of Agreement 1-2025, rather than replacing the broader framework governing politically exposed persons.

Article 1 defines the exception: members of the boards referred to in the annex who were appointed by a state institution solely to perform oversight functions established by law, provided they have no voting rights. For the purposes of this guide, those individuals are not considered politically exposed persons. State appointment alone is insufficient, as is simply describing a board member as a representative of a public institution.

The combined conditions matter when banks and trust companies classify customers and beneficial owners. The wording requires consideration of the function for which the person was appointed and whether voting powers exist. Excluding every board member would extend the exception beyond the text and disregard the restrictions expressly retained in the new provision. It is a specific classification rule, not a general exemption for public-sector representatives.

The recitals recall that Law 23 of 2015 defines politically exposed persons by reference to prominent public functions and other covered positions. They also state that the catalogue adopted in 2025 is illustrative rather than exhaustive. The amendment therefore does not turn that catalogue into a closed list. Nor does the exception alone establish that an individual has no other position or circumstance relevant to classification under the applicable framework.

Agreement 10-2026 does not remove general anti-money-laundering obligations. Its reasoning refers to Agreement 10-2015 and the enhanced customer due diligence applicable to customers or beneficial owners classified as politically exposed. The operational implication is narrower: distinguish qualifying oversight appointments from other positions and retain the corresponding assessment, rather than treating the amendment as a broad waiver of controls or an automatic release from monitoring.

For supervised institutions, application depends on establishing that an individual case satisfies the new paragraph’s conditions. For board members, the appointment instrument and the rules governing their powers consequently become relevant to that assessment. Nexo Capital will follow any implementation criteria published by the Superintendency. Until then, the exception’s wording, its limited purpose within the guide and the wider prevention framework remain distinct elements of the analysis.

Research assisted by Sentinel, with editorial verification of official sources. Discover Legislat.ai