Circular 14-2026: Compliance with Obligations Related to Updates of United Nations Security Council Lists

[Logo: SMV Superintendency of the Securities Market Republic of Panama]

Panama, July 13, 2026. Circular No. SMV- 14 - 2026.

Dear Compliance Officers Financial Obligated Entities Panama City

Subject: Compliance with obligations related to updates to the Lists of the United Nations Security Council communicated by the Financial Analysis Unit (UAF).

The Superintendency of the Securities Market (SMV), in accordance with the provisions of Law No. 23 of April 27, 2015, and Executive Decree No. 587 of August 4, 2015, reminds all obligated entities under its supervision of the obligation to promptly address communications sent by the Financial Analysis Unit (UAF) regarding updates to lists issued by the United Nations Security Council (UNSC), as well as to carry out the corresponding verifications and submit the required response in accordance with the procedures established in current regulations.

Regulated subjects are urged to maintain effective monitoring and validation mechanisms that allow for the immediate identification of possible matches with persons or entities included in said lists and to comply with reporting and preventive freezing obligations when applicable. In cases where no matches are identified between the client database and those designated in the listings, this must be reported to the sending authority in this manner, in accordance with what is established in Executive Decree 587 of 2015, in its Article 6.

In this sense, it is recalled that current regulations provide for a sanctioning regime for cases of non-compliance with established obligations, which may entail the imposition of fines ranging from B/.5,000.00 to B/.5,000,000.00, without prejudice to other measures that may legally apply.

Timely collaboration and strict compliance with these obligations are fundamental to strengthening the system for the prevention of money laundering, terrorism financing, and financing of the proliferation of weapons of mass destruction in the Republic of Panama.

Sincerely,

[Signature] Maruquel Murgas de González. Superintendent IBA/ea

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