Panama Beneficial Ownership in 2026: After the Papers, the Private Register

Last updated: 27 October 2026 · Reviewed against Law 129 of 2020 as amended by Law 254 of 2021, the Government of Panama’s Beneficial Ownership Guide (February 2026), Delegated Regulation (EU) 2025/1184, the EU Council’s tax-list revision of 9 October 2026 and the FATF list of June 2026

No place on earth is more bound up with the idea of hidden ownership than Panama. The 2016 leak from a single Panama City law firm turned the country's name into a global shorthand for offshore secrecy. What is far less understood is what Panama did next: it built a beneficial-ownership register, cleared the FATF grey list, shed the EU's money-laundering list and, on 9 October 2026, left the EU's tax blacklist too — while keeping the register itself almost entirely private. Understanding that combination is the key to verifying any Panama UBO in 2026.

01The name that became a byword

The Panama Papers made "Panama" a verb for concealment, but the jurisdiction underneath the headline has changed materially since. Panama runs a central register of beneficial owners, a regime of licensed gatekeepers who must know their clients, and a supervisor with real sanctioning power. The catch, for anyone doing due diligence, is that almost none of it is open to the public — by design.

So the Panama question is not "is it still a secrecy haven" — the honest answer is that the framework has moved a long way. It is "where does the ownership data now sit, who can reach it, and how do you get to the natural person when the register is closed to you." That is a specific discipline, and it runs through one figure above all: the resident agent.

02The scale beneath the scandal

The headline obscures how large Panama actually is as a corporate domicile. Its Public Registry, created in 1913, holds one of the world's biggest populations of international companies, built on a century-old territorial tax system that taxes only Panama-source income and leaves foreign-source income untaxed. That combination, not secrecy alone, is what made Panama a default incorporation venue for the world.

There is a second, less-discussed dimension: the sea. Panama operates one of the world's largest ship registries, an open system dating to 1917; UNCTAD's 2023 Review of Maritime Transport put the Panama-flagged fleet at 16.1% of world deadweight tonnage, second only to Liberia. That matters for beneficial ownership because a flag is an ownership question too — and a sanctions one. When the European Parliament initially rejected Panama's money-laundering delisting in 2024, it pointed to Panamanian-flagged "ghost ships" suspected of evading sanctions on Iran and Russia. The maritime register is a reminder that Panama's opacity risk was never only about shell companies.

03What the Papers changed

The reform arc is unusually clean to trace. The FATF added Panama to its grey list in June 2019 over strategic deficiencies; Panama worked through the action plan and was removed in October 2023, with the FATF citing progress on transparency, supervision and beneficial-ownership registration. The European Union followed: Delegated Regulation (EU) 2025/1184 of 10 June 2025, published in July, removed Panama from its list of high-risk third countries for money laundering with effect from 5 August 2025. The last of the three listings fell on 9 October 2026, when the Council took Panama off the EU tax blacklist after it passed an economic-substance law for foreign-source passive income and its implementing decree (EU Delegation to Panama, 9 October 2026). For how the EU list now feeds the new AML Regulation, see our EU beneficial-ownership guide.

Panama's transparency arc

From the leak to delisting — and the tail that remains

2016

The Panama Papers

A leak from a single resident-agent firm exposes the global use of Panamanian structures.

2020

Law 129: the private register

Panama creates a restricted beneficial-ownership register, custody held by a new supervisor.

Oct 2023

Off the FATF grey list

The action plan is completed; the FATF acknowledges progress on beneficial ownership.

Aug 2025

Off the EU AML list

Delegated Regulation 2025/1184 removes Panama from the EU's high-risk third-country list.

Oct 2026

Off the EU tax blacklist

The Council moves Panama from Annex I to Annex II after six years on the list of non-cooperative tax jurisdictions.

Pending

The Global Forum review

Panama stays on Annex II until the OECD Global Forum completes an in-depth review of its exchange of information.

04The framework: Law 129 and the private register

Panama's beneficial-ownership regime sits in Law 129 of 17 March 2020, which created the Sistema Privado y Único de Registro de Beneficiarios Finales — the Private and Unique System of Registration of Beneficial Owners. It was amended by Law 254 of 11 November 2021 and regulated by Executive Decree 13 of 2022; the government keeps a consolidated text that shows each article as Law 254 rewrote it. The register is administered by the Superintendence of Non-Financial Subjects (Superintendencia de Sujetos No Financieros), and it is, in the words of the law itself, a restricted database.

The purpose is explicit and narrow: to give competent authorities — the Superintendence, the Financial Analysis Unit, the Public Ministry, the Ministry of Economy and Finance and the tax authority — access to beneficial-ownership information for fighting money laundering, terrorist financing and proliferation. Article 8 calls the system free, private and of limited access. It is a compliance tool for the state, not a transparency tool for the public. That single design choice explains almost everything a verifier will encounter.

05The resident agent: gatekeeper and custodian

Every legal entity incorporated in Panama must appoint a resident agent — a licensed Panamanian lawyer or law firm. This is the pivot of the entire system, and the irony is hard to miss: the firm at the centre of the Panama Papers was itself a resident agent. Where that role was once the weak point, it is now the mandated control.

To operate, each resident agent must register with the Superintendence and receive a Unique Registration Code (CUR). The agent uses that code to file and update beneficial-ownership information for every entity it serves. The enforcement lever is elegant and severe: a corporate document cannot be registered at the Public Registry unless the resident agent's CUR is included, and an agent whose CUR is inactivated can no longer provide the service at all. In practice, no active Panamanian company exists without a resident agent who has attested to knowing its beneficial owner.

06Who counts as a beneficial owner

The definition is broad and control-focused, reaching past simple shareholding.

The Panama beneficial-owner test

A natural person captured by any of these

1

Ownership — 25%Any natural person who directly or indirectly owns or controls 25% or more of the shares or voting rights (10% for the financial sector).

2

Control or significant influenceAnyone who controls or exercises significant influence over the entity by other means.

3

Trust and foundation partiesFor a trust holding 25% or more: the settlor, trustee, protector and beneficiaries — and the equivalent roles in a foundation.

07What the register records — and by when

For each entity, the resident agent files identifying data on every beneficial owner: full name, identity document, nationality, date of birth, and the date the person became a beneficial owner. The timing is tight. Under articles 11 and 12, as rewritten by Law 254, the resident agent must complete the registration within 15 business days of incorporation or of its own appointment; on any change, the entity has 15 business days to tell its agent, and the agent then has 5 business days to update the system.

The CUR ties the whole thing together. Because the Public Registry will not register corporate acts without the resident agent's active code, the register is not a voluntary add-on that can quietly lapse — it is wired into the act of keeping a company alive. That structural coupling is what makes Panama's private register more reliable than its "restricted" label might suggest.

What the register records on each beneficial owner

The identifying data a resident agent must file under Law 129

Field	Recorded?	Note
Full name	Yes	The natural person identified as a beneficial owner
Identity document	Yes	Passport or ID number and type
Nationality	Yes	Including multiple nationalities where they apply
Date of birth	Yes	Part of the core identifying set
Date became beneficial owner	Yes	When the qualifying interest arose
Resident agent & CUR	Linked	The filer of record, tying the entity to its gatekeeper

08Access: the most private register in the corpus

If Monaco gates its register behind a judge and Australia has no register at all, Panama sits at the far end of a third axis: the data exists and is disciplined, but access is deliberately minimal.

Who can access Panama's beneficial-ownership register

Access under Law 129, as amended

Who	Access	Basis
The resident agent	Own entities only	Files and views data for the entities it serves — nothing else
Superintendence officials	Two designated officers	Relay information to competent authorities under strict controls
Competent authorities	On request	FIU, Public Ministry, tax authority and others, for AML/CFT purposes
Obliged entities & the public	No direct access	No public search; article 9 makes any court or administrative action for access by anyone else inadmissible

09The Public Registry: what's actually public

Panama does have an open register — the Registro Público — but like Australia's companies register, it is ownership-blind. It records the legal shell, not the people behind it.

The Registro Público: public vs private

What an open search of Panama's Public Registry returns

Data point	Public?	Note
Company existence, officers, directors	Yes	Searchable online, free of charge
Resident agent	Yes	Named on the record — the route to the gatekeeper
Foundation charter (council names)	Yes	The council appears; often professional or nominee members
Shareholders / beneficial owners	No	Not recorded at the Public Registry
Foundation beneficiaries & regulations	No	Held in the private regulations — confidential

Reaching that public layer is straightforward, and worth knowing precisely. Panama's Public Registry is searchable online at no cost, per the government's Beneficial Ownership Guide, and the document that matters for due diligence is the Certificado de Vigencia (certificate of good standing): it confirms an entity is active (vigente), that its annual franchise tax has been paid, and who its current directors and resident agent are.

Searching the Registro Público

What to request, and what it tells you

What you want	How	Note
Company profile & status	Online	Spanish-language extract of current registered information
Good standing (Certificado de Vigencia)	Certificate	Confirms active status, franchise tax paid, current directors
Directors, officers, resident agent	Extract	The identity anchors — the resident agent above all
Franchise tax (Tasa Única) status	On the certificate	US$300 per year for companies, US$400 for foundations (DGI); unpaid signals an entity not in good standing
Shareholders / beneficial owners	Not available	Never recorded at the Public Registry

10The Sociedad Anónima and bearer shares

The workhorse Panamanian vehicle is the Sociedad Anónima (SA), the corporation governed by Law 32 of 1927 — the structure that filled the Panama Papers. Its shareholders have never appeared in the Public Registry; only its directors, officers and resident agent do. Historically, that opacity was deepened by bearer shares — certificates whose owner was simply whoever physically held the paper.

Panama did not abolish bearer shares; it immobilised them. Under Law 47 of 2013, any bearer certificate must be deposited with an authorised custodian — a Panamanian lawyer, law firm, bank, fiduciary or brokerage — together with a sworn declaration identifying the true owner and the resident agent. The share loses its mobility, and its owner becomes known to a regulated custodian. For a verifier, a bearer-share company is no longer a dead end, but it is a flag: the owner's identity sits with a custodian and the resident agent, not on any public file.

11Nominee directors and the professional council

One feature explains why the Public Registry is ownership-blind in practice, not just in law: nominee directors and officers are legal and routine in Panama. A Sociedad Anónima needs at least three directors, and a foundation council at least three members — roles very often filled by the staff of the resident-agent firm, precisely to keep the principals off the public file. Professional nominee services are openly offered and inexpensive.

For a verifier, this is the decisive reading instruction. The names you can see — directors, officers, council members — are frequently placeholders, not principals. Treat them as a route to the resident agent rather than as the answer, and assume the real controller sits behind a nominee arrangement whose terms are private. It is the same discipline a nominee-friendly common-law structure demands, but in Panama it is the norm rather than the exception.

12The Private Interest Foundation

Panama's signature wealth structure is the Private Interest Foundation (Fundación de Interés Privado), created by Law 25 of 1995 — the civil-law cousin of the Liechtenstein foundation, used for succession and asset protection. It owns itself: there are no shareholders, which is exactly what makes beneficial ownership a question of control rather than equity.

Inside a Panama Private Interest Foundation

Who holds control, and who is visible

Role	Function	Public?
Founder	Creates the foundation; may retain no ongoing role	Charter
Foundation Council	Governs like a board — min. three persons or one entity	Yes
Protector	May appoint/remove the council, approve or veto distributions	Private
Beneficiaries	Benefit from the assets; named in the regulations	Private

13Tax transparency: the EU list and the CRS

Panama's rehabilitation is now complete on paper, and the nuance still matters for risk-rating. The country cleared the two money-laundering listings — the FATF grey list in 2023 and the EU's AML high-risk list in 2025 — and on 9 October 2026 it left Annex I of the EU's separate list of non-cooperative jurisdictions for tax purposes, where it had sat since 2020. It did not leave the list altogether: the Council moved it to Annex II, alongside Viet Nam, pending an in-depth review by the OECD Global Forum of how it exchanges information on request (European Commission, 9 October 2026).

These are two different lists policing two different things: money laundering versus tax transparency. Many enterprise risk models still carry a Panama tax flag set while it sat on Annex I; those models are now out of date. Annex II is a watch-list, not a blacklist, and because the tax list is revised twice a year, check the current position at the point of use rather than assuming either the headline or the exit.

There is a parallel channel worth noting, because it cuts the other way. Panama participates in the OECD's Common Reporting Standard, exchanging financial-account information automatically with partner jurisdictions since 2018. So while the beneficial-ownership register stays shut to the public and foreign counterparties, financial-account data on Panamanian structures does flow — to foreign tax authorities, through government-to-government exchange. Closed to you, in other words, is not the same as closed to everyone: the state-to-state pipes are open even where the public ones are not.

14Penalties and enforcement

The Superintendence enforces the regime through the resident agents, and the sanctions bite in two ways — money, and the licence to operate.

The fines sit in article 23 of Law 129 as rewritten by Law 254: B/.1,000 to B/.50,000 per entity, plus a daily B/.500 until the breach is cured. Article 24 adds the entity-level sanction: the Superintendence orders the Public Registry to suspend the corporate rights of any entity its agent has not registered or updated, so no act can be recorded and no certificate issued for it. The agent-level lever is the sharper one. A fine is a cost; losing the CUR is existential, because an agent without an active code cannot file at the Public Registry for any client. That aligns the incentives of the entire resident-agent profession with the register — the mechanism Panama chose instead of opening the data to the public.

15Multi-layer structures: Panama in the chain

Panama rarely sits alone. The classic structure the leaks exposed threaded a Panamanian company or foundation together with entities in other offshore centres — and that pattern is exactly what a verifier still has to unwind.

Where a Panama ownership chain resolves

A typical structure, asset to ultimate individual

1

The asset or accountHeld by a Panama Sociedad Anónima or foundation — the visible legal shell.

2

Panama SA or foundationPublic Registry shows directors, council and resident agent — not the owner.

3

Offshore holding layerA BVI or Cayman company, or a nominee arrangement, above the Panama entity.

4

Natural-person UBOThe controller, protector or beneficiary — resolved via disclosure, the resident agent and the chain above.

16A worked example

Put the pieces together in a structure a verifier meets constantly. A Panama Sociedad Anónima holds an investment account. Its shares are held not by an individual but by a Panama Private Interest Foundation. The foundation's council is made up of staff from the resident-agent firm. The protector and the beneficiaries are named only in the foundation's private regulations.

Run the standard playbook against it. A Public Registry search returns the SA's directors and resident agent, and the foundation's charter and council — every visible name potentially a nominee, none of them the owner. The 25% ownership test returns nothing, because the foundation owns itself and has no shareholders. The chain does not resolve on the public file at all.

The answer sits in exactly two places: the foundation's private regulations — where the protector and beneficiaries are named — held by the resident agent, and any entity sitting above the foundation offshore. Resolving the UBO means obtaining the regulations through customer disclosure and following any upstream layer into a register that is actually open. The public file tells you the structure exists; it never tells you whose it is.

17Common failure modes

The recurring mistakes on Panama files come from misreading either the reputation or the register.

18How to verify a Panama UBO: workflow

A practical sequence for resolving a Panama beneficial owner from outside the country:

1. Identify the vehicle. Is it a Sociedad Anónima, an SRL, or a Private Interest Foundation? A foundation shifts the question from shareholding to control and benefit.
2. Pull the Public Registry record. Start from the entity in our Panama company directory or the registry itself, and capture the directors, officers, foundation council and — critically — the resident agent, the regulated party who holds the beneficial-ownership file.
3. Apply the test. Look for a 25% owner, then for control or significant influence, treating public directors and council members as potential nominees.
4. Get the disclosure. Obtain the beneficial-ownership declaration from the customer or its resident agent; for bearer shares, confirm the custodian and the sworn owner declaration.
5. Follow the chain. Resolve any offshore holding layer above the Panama entity in a jurisdiction where the register is reachable — our global ownership data index maps where that data exists.
6. Screen and evidence. Screen the resolved person against sanctions, PEP and adverse-media sources, note Panama's current EU tax-list status, and keep an auditable trail.

19Practical takeaways

Panama is the jurisdiction the world remembers for hiding owners and rarely credits for the register it built. Both things are true. The data now exists, disciplined by a licensed profession and wired into the act of keeping a company alive — but it is held privately, reachable by the resident agent and the state, not by you. Build the workflow around the vehicle type, the resident agent behind it, and the offshore layer above — and rate the risk on Panama's current listings, not its most famous one. To verify a Panama UBO in one lookup, resolve the Panama entity and the layers above it through one API call.

20Glossary

21Frequently asked questions