2026-08-21

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SBP-DPC-BHN-CIRCULAR-2026-0085 — Update and administration of contact links and authorized users before the Financial Analysis Unit and the Superintendence of Banks of Panama

Obligated subjects must maintain updated contact links, authorized users, and registered data before the Superintendence of Banks of Panama and the Financial Analysis Unit. They are required to periodically review compliance links, institutional contacts, and authorized users in enabled channels, immediately informing of any changes in designations, replacements, terminations, functions, or institutional emails. Additionally, entities must preserve the confidentiality of information exchanged with these authorities by maintaining internal controls that prevent unauthorized access, misuse, or disclosures contrary to current regulations.

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SBP Superintendence of Banks of Panama

August 21, 2026 SBP-DPC-BHN-CIRCULAR-2026-0085

Mr./Ms. General Manager At your offices

Reference: Update and administration of contact links and authorized users before the Financial Analysis Unit and the Superintendence of Banks of Panama

Mr./Ms. General Manager:

The Superintendence of Banks of Panama (SBP) reiterates to obligated subjects the importance of maintaining updated their contact links, authorized users and other data registered before this Superintendence and the Financial Analysis Unit (UAF).

The Compliance Link is the point of contact with the SBP and the UAF to receive, attend to and manage information requirements, guaranteeing timely, secure and confidential communications.

Therefore, each obligated subject must periodically review the information of their links, compliance officers or responsible parties, institutional contacts and authorized users in the enabled channels.

The lack of updating, especially when a person ceases to perform their functions or terminates their relationship with the obligated subject, can compromise confidentiality, information security and timely attention to information requirements.

Obligated subjects must validate, update, substitute or revoke accesses and contacts registered before the SBP and the UAF in a timely manner and immediately inform of any change in designations, replacements, terminations, functions, institutional emails or other relevant data.

Likewise, they must preserve the confidentiality and reserve of information exchanged with the SBP and the UAF, maintaining internal controls that prevent unauthorized access, improper use or disclosures contrary to current regulations.

We thank the Mr./Ms. General Manager for imparting to the staff under their charge the pertinent instructions for compliance with the present.

Sincerely,

[Signature] Milton Ayón Wong Superintendent

AR/nb

"Solidity and trust: guarantors of the rights of banking consumers" Av. Samuel Lewis, Panama Business Tower, ground floor - Phones.: (507) 506 7800 / (507) 506-7900 - Fax (507) 506-7700 / 506-7703 P.O. Box 0832-2397 W.T.C. Panama, Republic of Panama - www.superbancos.gob.pa - email: superbancos@superbancos.gob.pa Official document signed with Qualified Electronic Signature in the Document Transparency System - TRANSDOC of the Superintendence of Banks of Panama, in accordance with Law 83 of November 9, 2012 and Executive Decree No. 275 of May 11, 2018. Use the QR Code to verify the authenticity of the document or the URL: https://sigob.superbancos.gob.pa/consulta?id=ETof7Vf2NeA2B269PgTXutfw%2Feg7wH50%42BXO8p9Ri438%3D

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