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Panama to Face Key GAFI Anti-Money Laundering Evaluation Starting August 2027

Panama will formally begin its Fifth Round evaluation by the Financial Action Task Force (GAFI) in August 2027, a process that will scrutinize the effectiveness of the country’s anti-money laundering and counter-terrorism financing framework, with the final report scheduled for discussion and approval in December 2028, according to the calendar presented by GAFILAT, the Financial Action Task Force of Latin America.

What Happened

The evaluation timeline was explained by Guillermo Hernández Rodríguez, a technical expert at the Executive Secretariat of GAFILAT, during a presentation titled “Fifth Round of GAFI Evaluation 2027: What Panama Must Demonstrate and the Role of Non-Financial Obligated Subjects.”

Hernández said the fifth round involves a longer and more intensive process than previous evaluations, lasting approximately 16 to 18 months between the formal start and the approval of the report, with earlier involvement between the evaluating team and the country under review.

The process will begin with a high-level visit, in which GAFILAT representatives meet with national authorities to explain the procedure and its implications, and deliver the formats needed to begin the formal exchange of information. Panama will then undergo two training processes: one strategic in nature and another focused specifically on preparing the formats and presenting the information to be examined.

Hernández noted that a common problem for countries has not necessarily been a lack of information, but how to present it so the message reaches the evaluating team clearly and effectively.

After Panama submits information on technical compliance and effectiveness, evaluators will prepare preliminary findings, giving the country the opportunity to provide additional information, clarifications, and corrections. A subsequent on-site visit will bring the evaluation team to Panama for roughly two weeks to meet with authorities, private sector representatives, and other actors in the anti-money laundering system, contrasting what they see with the documentation previously submitted.

Once the visit concludes, the report will be drafted in three successive versions shared with Panama for comment, followed by external reviews to verify that the methodology was applied consistently. After approval in December 2028, the report will undergo a quality and consistency review within the global network before publication.

Background

The Fifth Round marks a significant shift in approach. According to Hernández, the focus will be primarily on effectiveness — analyzing in much greater detail the risk, context, and materiality of each country — rather than on technical compliance alone. Legal and regulatory aspects that have not changed since prior reviews will not necessarily be re-examined with the same depth, freeing evaluators to devote more time to determining whether the system is actually producing results.

The new round also changes how non-financial obligated subjects are examined. Problems identified internationally during the fourth round included gaps in the coverage of some obligated subjects, supervisory regimes that were still incipient or insufficiently risk-based, and deficiencies in the quality of suspicious transaction reports. Panama’s non-financial obligated sector includes entities such as those linked to the Colón Free Zone.

Panama’s Superintendency of Non-Financial Subjects (SSNF) reports progress as the country prepares. Superintendent Isabel Fernández said the institution has reached 92% compliance in the single registry of final beneficial owners, a core requirement of the non-financial regulatory framework. According to the SSNF indicator dashboard, with data as of August 31, 2026, there are 13,167 registered obligated subjects.

On the enforcement side, the superintendency has accumulated 14,763 supervisions, of which 2,013 correspond to 2026. It has also imposed 124 accumulated sanctions: 103 pecuniary (83.06%) and 21 disciplinary (16.94%). Fernández highlighted the sector’s response to compliance demands, saying it demonstrates a real commitment to raising standards and building a more robust and competitive compliance system.

What This Means for Panama

The stakes of the evaluation are considerable. GAFI assessments directly influence how international counterparties, banks, and investors perceive a jurisdiction’s financial integrity, and a poor result can affect Panama’s standing in international financial markets and its service-based economy.

The emphasis on effectiveness means Panama will need to demonstrate concrete outcomes — quality supervision, meaningful suspicious transaction reporting, and real risk-based enforcement — rather than pointing solely to laws on the books. The SSNF’s reported figures on registration, training, and supervision will be central to that demonstration.

The timeline gives Panamanian authorities and the private sector roughly a year to strengthen systems before the formal process begins in August 2027, with the on-site visit, multiple report drafts, and the final determination stretching to December 2028.

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