By Law 23 of April 27, 2015, Panama included new subjects, controls and mechanisms that must be applied in attention of the prevention of Money Laundering, Financing of Terrorism and the Financing for Proliferation of Weapon of Mass Destruction.
A law from the 2000s is repealed through this. The country aims to strengthen its financial system and improve its international image to be more attractive to foreign investors and to the international trade, therefore with the purpose of being removed from the high risk jurisdictions list.
Thus, the recent law includes other professionals as supervised agents among these, lawyers, certified public accountants and notaries. The Ministry of Finance of Panama recently, through a Resolution No JD - 014 - 015 of August 14, 2015, which determined that only when these professionals are in the exercise of certain activities on behalf of a client, they should make a simplified or enhanced due diligence depending on ( i ) if it is a high risk client, ( ii ) his political position, ( iii ) his nationality or the country represented by him or his funds.
The main activities subject to scrutiny are:
- Purchase of property, through legal entities or other legal structures;
- Management of money or the assets of the client;
- Management of bank accounts;
- Intermediation for the creation, operation or management of companies or legal structures, such as private foundations, corporations, trusts and other;
- Brokerage paid by the lawyer or lawyer firm to the position of director or agent of a company or participant in a trust or similar;
- Provide registered address;
- Provide the service of Resident Agent to legal entities.
Mainly, reports are aimed to those suspicious situations where there is no connection between the financial profile of the client and his transactional movement and there is no way to sustain or justify it.