What Law 23 is
Law 23 of 2015 is Panama's framework law adopting measures to prevent money laundering, the financing of terrorism and the financing of the proliferation of weapons of mass destruction (ML/TF/PF). It sets out the compliance regime that certain companies and professionals must follow, aligning the country with the international standards of the FATF.
In practice, it turns those standards into concrete obligations: know who you are doing business with, assess their risk, report anything suspicious and keep evidence of the entire process.
What it aims to prevent
The law aims to prevent companies from being used —knowingly or not— as a vehicle to move money of illicit origin or to finance prohibited activities. Its three focuses are:
- Money laundering: giving an appearance of legality to funds of criminal origin.
- Terrorist financing: providing resources to terrorist activities.
- Proliferation financing: financing weapons of mass destruction.
Who it applies to
Law 23 reaches both financial-sector entities and a broad group of non-financial activities. In general terms:
- Financial obligated entities: banks, insurers, securities firms, cooperatives and others supervised by the financial system regulators.
- Non-financial obligated entities and activities carried out by professionals: lawyers, accountants, notaries, casinos and gaming rooms, real estate developers and agents, free trade zones, dealers in precious metals and stones, trust companies, among others.
Is your activity on the list? Take a closer look at who the non-financial obligated entities are and what they must do.
Main obligations
Although the scope varies by type of entity, the obligations usually include:
- Customer due diligence (CDD): identify and verify customers and their beneficial owner.
- List and PEP screening: check individuals and companies against sanctions lists and politically exposed persons.
- Risk-based approach: classify each relationship and apply enhanced due diligence when the risk is higher.
- Suspicious activity reporting (ROS): inform the FIU when appropriate.
- Record keeping: keep the due diligence evidence for the period required by the law.
- Compliance program: policies, manual and, depending on the case, a compliance officer.
Oversight and the FIU
Compliance is overseen by different supervisory bodies depending on the sector. For non-financial entities there is a specialized superintendency. For its part, the Financial Analysis Unit (UAF) is the financial intelligence unit that receives and analyzes suspicious activity reports; it does not supervise or sanction directly, but produces intelligence for the competent authorities.
How Akifue helps
Akifue turns a good part of these obligations into a simple, traceable flow: sanctions screening, PEP screening and KYC in a single search, with a score, analyst decision and an exportable case file that serves as evidence.
This content is informational and does not constitute legal advice. The interpretation and scope of Law 23 of 2015 and its regulations may be updated; consult the official text in the Official Gazette and a professional for your specific case.