What the FIU is
The Financial Analysis Unit (UAF) is Panama's financial intelligence unit (FIU): the body in charge of receiving, requesting and analyzing information related to possible cases of money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction. It is the central point where the information reported by obligated entities converges.
What it does
Its main role is intelligence, not operational. In practical terms, the FIU:
- Receives Suspicious Activity Reports (ROS) and other reports required by regulations.
- Analyzes that information, cross-references it and puts it in context.
- Produces financial intelligence and refers it to the competent authorities when there are relevant indications.
- Cooperates with counterpart units in other countries and international bodies.
What the FIU does not do
This is a point that causes confusion. The FIU does not supervise companies directly or impose penalties, and it does not conduct criminal investigations. Those functions belong to the supervisory bodies of each sector and to the investigation and justice authorities. The FIU is the intelligence analyst, not the supervisor or the prosecutor.
The ROS: suspicious activity report
The ROS is the mechanism by which an obligated entity informs the FIU about transactions that, by their nature or circumstances, could be linked to illicit activities. It does not require certainty of a crime: reasonable suspicion is enough. Reporting in good faith is an obligation and, at the same time, a protection for the company.
Good due diligence is what allows you to detect in time the signals that give rise to a ROS. That is where sanctions screening and adverse media analysis make the difference.
Relationship with obligated entities
Obligated entities are the FIU's source of information: they are expected to know their customers, monitor their transactions and report anything suspicious. The better their due diligence and their evidence, the stronger the whole system —and the better protected the company itself is in an audit.
This content is informational and does not constitute legal advice. The functions and procedures of the FIU may be updated; consult the official sources of Panama's Financial Analysis Unit and a professional for your specific case.