What licensing steps are required to launch a digital wallet service in Panama, and what AML/KYC obligations apply?

 Response from MOLINA & CO.

Thank you for your inquiry.

In Panama, electronic wallets and cross-border payment services are principally regulated by:

1) Primary Regulator

• Superintendencia de Bancos de Panamá (SBP) – when activities resemble issuance of electronic money, payment services, stored-value, or financial intermediation.
• If services involve securities or tokenized instruments, the Superintendencia del Mercado de Valores (SMV) may also participate.

2) Licensing Framework

A fintech offering e-wallets and cross-border payments generally requires:

1. Submission of a license application to SBP
2. Corporate formation in Panama
3. AML/KYC compliance structure
4. Business plan, risk assessment, and cybersecurity policies
5. Identification of shareholders, directors, and key personnel
6. Fit & proper requirements for management
7. Approval followed by operational authorization

Processing time typically ranges 4–8 months, depending on project scope and regulatory review.

 

3) Minimum Capital

Minimum capital depends on activity classification under banking / payment services regulations.
Typical requirements range from approximately USD 250,000 – 1,000,000+, depending on scope, product design, risk exposure, and cross-border operations.

 

4) Ongoing Obligations

• Periodic financial statements
• Transaction reporting
• Cybersecurity controls
• Operational audits
• Regulatory inspections
• Adequate data-protection compliance

 

5) AML / KYC Requirements

The entity must:

• Maintain a documented AML program
• Appoint a compliance officer
• Conduct identity verification of users (KYC)
• Monitor transactions, including cross-border
• Report suspicious activities (ROS)

Panama applies FATF-aligned standards, including enhanced due-diligence for higher-risk profiles.

 

6) Fees – Legal & Government (Estimate)

• Regulatory / Government costs:
  Approx. USD 5,000 – 15,000 depending on license type
• Professional fees (MOLINA & CO.):
  From USD 18,000 – 45,000, depending on scope, structure, and regulatory complexity

Ongoing compliance support can be provided under separate service agreements.

 

If you would like assistance with feasibility analysis, licensing, compliance design, or incorporation, our firm would be pleased to guide you.

— MOLINA & CO. – Panama

Roderigo Julio Molina O

 

Response from MOLINA & CO.

Thank you for your inquiry.

In Panama, electronic wallets and cross-border payment services are principally regulated by:

1) Primary Regulator
- Superintendencia de Bancos de Panamá (SBP) – when activities resemble issuance of electronic money, payment services, stored-value, or financial intermediation.
- If services involve securities or tokenized instruments, the Superintendencia del Mercado de Valores (SMV) may also participate.

2) Licensing Framework
A fintech offering e-wallets and cross-border payments generally requires:
- Submission of a license application to SBP
- Corporate formation in Panama
- AML/KYC compliance structure
- Business plan, risk assessment, and cybersecurity policies
- Identification of shareholders, directors, and key personnel
- Fit & proper requirements for management
- Approval followed by operational authorization

Processing time typically ranges 4–8 months, depending on project scope and regulatory review.

3) Minimum Capital
Minimum capital depends on activity classification under banking / payment services regulations.
Typical requirements range from approximately USD 250,000 – 1,000,000+, depending on scope, product design, risk exposure, and cross-border operations.

4) Ongoing Obligations
- Periodic financial statements
- Transaction reporting
- Cybersecurity controls
- Operational audits
- Regulatory inspections
- Adequate data-protection compliance

5) AML / KYC Requirements
The entity must:
- Maintain a documented AML program
- Appoint a compliance officer
- Conduct identity verification of users (KYC)
- Monitor transactions, including cross-border
- Report suspicious activities (ROS)

Panama applies FATF-aligned standards, including enhanced due-diligence for higher-risk profiles.

6) Fees – Legal & Government (Estimate)
- Regulatory / Government costs:
Approx. USD 5,000 – 15,000 depending on license type
- Professional fees (MOLINA & CO.):
From USD 18,000 – 45,000, depending on scope, structure, and regulatory complexity

Ongoing compliance support can be provided under separate service agreements.

If you would like assistance with feasibility analysis, licensing, compliance design, or incorporation, our firm would be pleased to guide you.

— MOLINA & CO. – Panama

Roderigo Julio Molina O