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Non-financial obligated subjects (APNFD) in Panama: who are they and what must they comply with?

Strategic compliance: the roadmap for Obligated Subjects before the SSNF.
April 16, 2026 by
Non-financial obligated subjects (APNFD) in Panama: who are they and what must they comply with?
Barbara Ynojosa

In the Republic of Panama, the fight against money laundering, the financing of terrorism, and the financing of the proliferation of weapons of mass destruction (AML/CFT/FPADM) is not an exclusive task of the banking sector. There is a diverse group of professionals and companies that, by the nature of their activities, play a fundamental preventive role: Non-Financial Obligated Subjects.


Who defines these subjects in Panama?

The competent authority responsible for supervising, regulating, and overseeing compliance in this sector is the Superintendency of Non-Financial Subjects (SSNF). According to what is established in Law 23 of April 27, 2015, and its subsequent amendments, the SSNF is the entity mandated to ensure that these economic activities are not used for illicit purposes.


Who is considered a Non-Financial Obligated Subject?

Under the supervision of the SSNF, the activities that must strictly comply with prevention and due diligence standards include, among others:

  • Lawyers and public accountants: when they carry out operations for their clients such as managing money, securities, bank accounts, or creating and managing legal entities.

  • Real estate agencies and brokers: responsible for monitoring transactions of buying and selling real estate.

  • Free zones: companies established in the Colón Free Zone and other special economic zones (excluding the hotel sector).

  • Dealers in metals and precious stones: jewelry stores and luxury goods traders.

  • Pawn shops: institutions that provide loans through collateral.

  • Investment promoters and casinos: activities of gambling and management of third-party funds.


Key responsibilities before the SSNF

Citing the Superintendency of Non-Financial Subjects (SSNF) implies understanding that compliance is not optional. Companies must:

  1. Implement due diligence policies (KYC/KYB).

  2. Develop and update a prevention manual.

  3. Report suspicious activities to the Financial Analysis Unit (UAF).


AgileCheck: your technological ally in Panama

Regulatory compliance may seem complex, but with the right technology it becomes an operational advantage. At AgileCheck, we assist Non-Financial Obligated Subjects (APNFD) through our compliance software, specialized consulting, and the development of compliance manuals aligned with SSNF requirements.

Our solution allows for the integration of restrictive list verification, ultimate beneficiary identification, and report management in a single environment, ensuring that your company is always prepared for oversight.