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, and shed the EU's money-laundering blacklist — 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 — well over 350,000 active entities — 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, with around 16% of global shipping flying its flag under an open system dating to 1917. 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, removing Panama from its list of high-risk third countries for money laundering in July 2025.
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 reinforced by Law 254 of 2021 and regulated by Executive Decree 13 of 2022. 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. 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.
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. Entities formed after the law took effect must have their beneficial owner registered within 30 business days of formation; any change must be updated within 30 business days; and entities that predated the system were given a transition window to comply.
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.
| 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 | 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; even courts cannot compel access outside the law |
When the register is closed, resolve the structure around it
You cannot search Panama's beneficial-owner register, and you will not be added to the list of people who can. What you can do is map the structure — the Sociedad Anónima, the foundation, the holding layers above — and resolve the natural person from the Public Registry filings and the jurisdictions where the data is reachable. Zavia.ai connects directly to government registries in 100+ countries, follows ownership across borders, and returns an auditable map to the UBO with sanctions and PEP overlays, flagging where a foundation or nominee council breaks the trail.
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.
| Data point | Public? | Note |
|---|---|---|
| Company existence, officers, directors | Yes | Searchable online with a registered account |
| 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, 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.
| 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; 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.
| 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 real but incomplete, and the nuance matters for risk-rating. The country has cleared the two money-laundering listings — the FATF grey list in 2023 and the EU's AML high-risk list in 2025 — but it has remained on the EU's separate list of non-cooperative jurisdictions for tax purposes, where it has sat since 2020.
These are two different lists policing two different things: money laundering versus tax transparency. A Panama entity can therefore be low-risk on the AML axis and still carry a tax-transparency flag that many enterprise risk models treat as material. Because the tax list is revised twice a year, it is worth checking 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 second 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.
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.
| The mistake | Why it fails |
|---|---|
| Expecting a public beneficial-owner search | The register is restricted to the resident agent and two Superintendence officials |
| Reading directors or council as owners | They are frequently professional or nominee; ownership sits in private records |
| Treating a foundation like a company | It has no shareholders — beneficial ownership is a question of control and benefit |
| Assuming bearer shares are untraceable | They are immobilised with a custodian who holds a sworn owner declaration |
| Judging Panama on the 2016 headline | The framework has cleared the FATF grey list and the EU AML list since |
| Assuming AML delisting means tax-clean | Panama has remained on the EU's separate tax-transparency list |
| Ignoring the resident agent | It is the identity anchor, the filer of the UBO, and the route to disclosure |
18How to verify a Panama UBO: workflow
A practical sequence for resolving a Panama beneficial owner from outside the country:
- 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.
- Pull the Public Registry record. Capture the directors, officers, foundation council and — critically — the resident agent, the regulated party who holds the beneficial-ownership file.
- Apply the test. Look for a 25% owner, then for control or significant influence, treating public directors and council members as potential nominees.
- 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.
- 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.
- 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
| Scenario | What you can rely on | What you must supplement |
|---|---|---|
| Sociedad Anónima | Public Registry: directors, officers, resident agent | Shareholders — via disclosure and the chain above |
| Bearer-share company | Custodian holds a sworn owner declaration | Owner identity, obtained via the custodian and resident agent |
| Private Interest Foundation | Public charter and foundation council | Protector and beneficiaries — private, via the resident agent |
| Any Panama entity | The named resident agent as identity anchor | The beneficial-ownership declaration and offshore chain |
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.
Panama & cross-border ownership data — however you build
Skip the structure-by-structure unwinding. Get Panama corporate data and cross-border ownership resolution sourced directly from official registries — mapped through the foundation, bearer-share and holding layers to the natural person at the top.
20Glossary
21Frequently asked questions
Does Panama have a public beneficial ownership register?
No. Panama maintains a central register of beneficial owners under Law 129 of 2020, but it is a private, restricted database. Access is limited to the entity's own resident agent and two designated officials of the Superintendence of Non-Financial Subjects, who make information available to competent authorities such as the Financial Analysis Unit, the Public Ministry and the tax authority. There is no public search, and even courts cannot compel access outside the terms of the law.
Is Panama still on the FATF grey list in 2026?
No. The FATF added Panama to its grey list in June 2019 and removed it in October 2023, after Panama completed its action plan and the FATF acknowledged progress on transparency, supervision and beneficial-ownership registration. The European Union followed by removing Panama from its list of high-risk third countries for money laundering in July 2025. Panama has, however, remained on the EU's separate list of non-cooperative jurisdictions for tax purposes.
What is a resident agent in Panama?
A resident agent is the licensed Panamanian lawyer or law firm that every Panamanian legal entity must appoint. Under Law 129, the resident agent registers with the Superintendence, receives a Unique Registration Code (CUR), and files and updates the beneficial-ownership information for each entity it serves. Because a corporate document cannot be recorded at the Public Registry without an active CUR, the resident agent is both the gatekeeper of company filings and the custodian of the beneficial-ownership record.
What is the beneficial ownership threshold in Panama?
25%. A beneficial owner is any natural person who directly or indirectly owns or controls 25% or more of the shares or voting rights of a legal entity, or who otherwise controls or exercises significant influence over it. For a trust that holds 25% or more, the settlor, trustee, protector and beneficiaries are treated as beneficial owners, and equivalent roles apply to a foundation.
How do you verify a UBO in Panama?
You reconstruct it, because the register is closed. Start with the Public Registry record for the entity — its directors, officers, foundation council and, critically, its resident agent. Apply the 25%, control and influence tests, treating public directors and council members as potential nominees. Obtain the beneficial-ownership declaration from the customer or resident agent, confirm any bearer-share custodian, resolve any offshore holding layer above the Panama entity, and screen the resolved person against sanctions and PEP sources.
Are bearer shares still legal in Panama?
Yes, but they are immobilised. Panama did not abolish bearer shares; under Law 47 of 2013 it requires any bearer certificate to 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 cannot circulate freely, and its owner is known to a regulated custodian, so a bearer-share company is traceable through that custodian rather than being an anonymous dead end.
How is a Panama Private Interest Foundation treated for beneficial ownership?
A Private Interest Foundation, created under Law 25 of 1995, has no shareholders — it owns itself — so beneficial ownership turns on control and benefit rather than equity. The foundation council appears on the public charter but is often professional or nominee. The protector, who can appoint or remove the council and direct distributions, and the beneficiaries are named in the private regulations and are not on the public file. Identifying them means going to the resident agent and the customer's documentation.
What can you find on the Panama Public Registry?
The Registro Público is a public, online register that shows a company's existence, its officers and directors, its resident agent, and a foundation's charter and council. It does not record shareholders or beneficial owners, and it does not hold a foundation's beneficiaries or private regulations. Like Australia's companies register, it shows the legal shell rather than the people behind it — useful for the directors and the resident-agent anchor, but not a source of ownership.
What are the penalties for beneficial ownership breaches in Panama?
Under Law 254, a resident agent can be fined between $1,000 and $50,000 for each legal entity whose beneficial-ownership information is not registered or kept up to date. The more serious sanction is the inactivation of the agent's Unique Registration Code (CUR): without an active CUR, the agent cannot file documents at the Public Registry for any client, effectively ending its ability to service Panamanian entities. Entities and their agents share responsibility for compliance.
Is Panama still a secrecy jurisdiction?
Panama's framework has changed substantially since 2016. It now runs a central beneficial-ownership register, immobilised bearer shares, a licensed resident-agent regime, and a supervisor with real sanctioning power, and it has cleared both the FATF grey list and the EU's money-laundering list. What it has not done is make ownership public: the register is deliberately private, reachable by the resident agent and the state rather than by counterparties. So the accurate description is disciplined but closed, not lawless — and it should be risk-rated on its current listings, including the EU tax list it remains on.
