VASP Compliance Framework
AML/CFT compliance framework registration with Panama's Financial Analysis Unit (UAF) for virtual asset service providers operating under general corporate law pending dedicated VASP legislation.
Law 23 of 2015 (AML/CFT), UAF Regulations
Capital Required
No statutory minimum; USD 50,000-250,000 recommended
Timeline
1-2 months (registration with UAF)
Fees
USD 500-2,000 registration + USD 1,000-5,000 annual compliance
Regulatory Body
SBP (Banking Superintendent) / SMV (Securities Superintendent) / UAF (Financial Analysis Unit)
Legislative Framework
Commercial Code, Law 23 of 2015 (AML/CFT), Decree Law No. 1 of 1999 (Securities Market Law)
Last updated: June 2025
Key Requirements
Develop comprehensive AML/CFT compliance program addressing customer identification, beneficial owner verification, and transaction monitoring.
Implement Know Your Customer (KYC) procedures including customer identification documents, address verification, and beneficial owner documentation.
Establish transaction monitoring system identifying suspicious activity patterns including unusual amounts, rapid transfers, or unusual customer behavior.
Implement Suspicious Activity Reporting (SAR) procedures documenting detection and reporting of suspicious transactions to UAF.
Maintain detailed transaction records including customer identity, amounts, dates, addresses, and destination information for minimum 7 years.
Conduct annual compliance audits documenting AML/CFT procedures, transaction monitoring results, and suspicious activity reporting.
Establish compliance officer role responsible for AML/CFT program oversight, training, and regulatory reporting.
Maintain AML/CFT documentation including policies, procedures, training records, and SAR filing copies for UAF inspection.
Application Process
Develop comprehensive AML/CFT compliance policies addressing customer identification, beneficial owner verification, and suspicious activity detection.
Establish transaction monitoring system and documented suspicious activity reporting procedures.
Prepare compliance program documentation including compliance officer designation, training procedures, and audit protocols.
Register virtual asset service provider with UAF (Financial Analysis Unit) providing company information and compliance framework overview.
Provide AML/CFT policy documentation, customer identification procedures, and transaction monitoring system descriptions.
Establish compliance officer position and provide contact information to UAF.
Implement AML/CFT procedures and maintain documentation available for UAF inspection and regulatory oversight.
Expected Total Timeline
1-2 months (registration with UAF)
Ongoing Obligations
After obtaining your VASP Compliance Framework, these are the continuing compliance requirements you must maintain.
Maintain comprehensive AML/CFT documentation with annual policy reviews and updates addressing identified risks.
Conduct quarterly transaction monitoring with documented suspicious activity reporting to UAF for any flagged transactions.
File annual compliance certifications with UAF confirming AML/CFT procedure implementation and compliance status.
Maintain detailed customer identification records with beneficial owner documentation for all customer accounts.
Report Suspicious Activities (SARs) to UAF within 10 days of detection with detailed transaction information and context.
Conduct annual compliance audits documenting AML/CFT procedure effectiveness with management sign-off and remediation of identified gaps.
Maintain compliance training records for all employees with annual training completion documentation.
Cost Summary
Capital Requirement
No statutory minimum; USD 50,000-250,000 recommended
Application & Licensing Fees
USD 500-2,000 registration + USD 1,000-5,000 annual compliance
Jurisdiction Setup Cost
$3,000-$8,000
Annual: $2,000-$5,000
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