Circular 21-2026: Update of Liaison Person Records with the Financial Analysis Unit

Panama, August 5, 2026. Circular No. SMV- 21 - 2026.

Dear Compliance Officers Financial Obligated Entities Panama City

Reference: Update of Liaison Person Records with the Financial Analysis Unit

The Securities Market Superintendence of Panama (SMV), in exercise of its supervisory functions and with the purpose of strengthening compliance with obligations provided for in the normative framework for the prevention of money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction, reminds all Financial Obligated Entities under its supervision of the following:

Article 12 of Law No. 23 of April 27, 2015 establishes the obligation of financial obligated entities to designate a liaison person to maintain communication and coordination with the Financial Analysis Unit for the Prevention of Money Laundering, Terrorist Financing, and Financing of the Proliferation of Weapons of Mass Destruction (UAF).

Similarly, Article 30 of Agreement No. 6-2015 of the Securities Market Superintendence provides that the Compliance Officer of the Financial Obligated Entity shall be the liaison person with the Financial Analysis Unit and the Securities Market Superintendence. In the temporary absences of the Compliance Officer, the liaison person will be the legal representative of the Financial Obligated Entity, for reports related to the crimes of money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction.

In view of the foregoing, the SMV reiterates to Financial Obligated Entities the obligation to permanently keep updated the information corresponding to the liaison persons registered with the UAF, both of the main one and the substitute liaison, in order to guarantee the continuity of institutional communication and the adequate fulfillment of requirements emanating from said authority.

Calle 50, Edificio P.H. Global Plaza, Piso 8, tel.: (507) 501-1700 Fax: (507) 501-1709 www.supervalores.gob.pa Apartado 0832-0288 WTC Panamá, Rep. de Panamá

Particularly, it is recalled that:

1. The Compliance Officer must be registered as the primary liaison with the UAF.
2. The legal representative must be registered as substitute liaison to cover temporary absences or incapacities.
3. When the labor or contractual relationship of the Compliance Officer ends, the Financial Obligated Entity must promptly manage the removal of the outgoing liaison and the registration of the new liaison.
4. In the event that the legal representative registered as substitute liaison ceases to act as such, the corresponding update must be requested, including the removal of their records and the designation of their replacement when necessary.
5. Financial Obligated Entities are responsible for periodically verifying that the information of their liaison registered with the UAF is valid, complete, and up to date.

The lack of timely update of these records may affect the adequate reception and attention of communications, requirements, and coordinations carried out by the UAF and other competent authorities, as well as evidence deficiencies in compliance with applicable legal and regulatory obligations in matters of prevention of money laundering, terrorist financing, and financing of the proliferation of weapons of mass destruction.

In view of the foregoing, we require you to verify and update the information of your registered liaison in the UAF platform, no later than August 30, 2026.

The Securities Market Superintendence appreciates your collaboration and highlights the importance of keeping information up to date to comply with current regulations.

Sincerely,

Maruquel Murgas de González Superintendent Securities Market Superintendence