Summary
- Project 697 never became an operative regulatory regime. On 2023-06-06, the Supreme Court declared the entirety of Project 697 of 2021 inexequible. It should therefore not be described as an existing law that was later repealed; it was constitutionally invalidated before acquiring operative force.
- Project 326 is a pending bill, not “Law 326.” The Assembly’s plenary record shows the underlying Anteproyecto 107 being prohijado by the Economy and Finance Committee in August 2025. Official Assembly materials in January 2026 continued to describe Project 326 as undergoing subcommittee analysis and legislative debate.
- No binding VASP-specific compliance deadline is currently running. In particular, I located no operative deadline for licensing, registration, grandfathering of existing operators, commencement of supervision, regulatory implementation, or filing by VASPs.
- The official Assembly referred to a 15-day period for the subcommittee to continue receiving proposals or produce a report. That was an internal legislative timetable, not a deadline imposed on VASPs or other private parties.
- A bill sponsor referred to a Panama FATF/GAFILAT evaluation in 2027. That is a policy and international-evaluation milestone, not a domestic statutory compliance deadline. GAFILAT confirms that a fifth-round calendar exists, but the public material reviewed does not identify a Panama-specific legal deadline.
Is a Panama VASP law currently in force?
No dedicated Panama VASP/PSAV law was identified as enacted and in force as of the stated date.
An initiative before the National Assembly is not an operative law merely because it has been introduced, prohijado, assigned a project number, or considered by a subcommittee. The legal text must complete the legislative and constitutional process and be promulgated and published through the Official Gazette. Articles 168 to 171 of the Constitution govern the formation of laws, and article 2 of Law 53 of 2005 gives legal validity to publication of the Gazette by internet, salvo prueba en contrario.
A bill declared entirely inexequible by the Supreme Court cannot serve as an operative statutory regime. Under article 171 of the Constitution, where the Executive objects to a bill as inexequible and the Assembly insists on its adoption, the bill passes to the Supreme Court to decide on its constitutionality, and only a ruling declaring the bill constitutional obliges the Executive to sanction and promulgate it. The Court characterises this as prior, preventive constitutional control, whose purpose is to prevent a bill considered contrary to the Constitution from becoming a Law of the Republic.
The first relevant initiative, Project 697 of 2021, was approved by insistence following executive objections. The operative part of the judgment states:
“DECLARA QUE ES INEXEQUIBLE todo el Proyecto de Ley No.697 de 2021 … aprobado por insistencia en tercer debate por la Asamblea Nacional, durante su sesión ordinaria correspondiente al veintiocho (28) de octubre de dos mil veintidós (2022).”
The judgment is dated 2023-06-06 (Entrada No. 8509-2023; ponente Magistrate María Eugenia López Arias, with one dissenting vote) and was promulgated in Gaceta Oficial Digital No. 29843 of 2023-08-09. The Court held that, for reasons of form, the whole of Project of Law 697 of 2021 is contrary to article 170 of the Constitution: on a partial objection the Assembly may consider the bill only as to the matters objected to, whereas it amended unobjected provisions and introduced new ones. Having so held, the Court found it unnecessary to rule on the substantive objections to articles 34 and 36. Consequently, Project 697 did not establish a surviving VASP licensing, registration or supervisory regime.
The present initiative followed a different legislative path. An official Assembly act records Anteproyecto 107, concerning supervision, registration and control of VASPs, as having been prohijado by the Economy and Finance Committee in August 2025. Subsequent official Assembly communications identify it as Project of Law 326 and show it continuing through subcommittee consideration in January 2026.
The Official Gazette homepage displayed Gazette No. 30593 A, dated 2026-08-19, as the latest issue when this review was performed. Searches of the official Gazette by the relevant titles and terms—including “activos virtuales,” “proveedores de servicios de activos virtuales,” “PSAV” and “VASP”—did not locate a promulgated VASP law or implementing regulation through that cutoff. The conclusion that no VASP law is in force is therefore an inference from the official legislative status materials, the Supreme Court judgment, and the absence of a corresponding promulgation in the authoritative publication channel.
Are any official VASP deadlines currently applicable?
No binding VASP-specific compliance deadline is currently in effect.
A private-sector deadline must arise from an enacted law, regulation, licence condition or binding administrative order. A committee’s timetable for receiving comments, preparing a report or continuing debate does not impose duties on businesses outside the legislature.
The official Assembly release dated 2026-01-15 stated that the subcommittee established a “plazo de 15 días” to continue considering recommendations and proposals. That period did not create any private-sector obligation. The period concerned the Assembly’s own legislative work.
A legislator also referred in the Assembly to Panama’s next FATF evaluation being in 2027. Even accepting that statement as the sponsor’s legislative motivation, it does not operate as a statutory deadline for a VASP. The public GAFILAT announcement relied on here is the conclusions of the XLVIII Plenary of 14 and 15 December 2023, which record that a calendar covering the on-site visit and mutual-evaluation report discussion for each of the 18 member countries was presented, without stating Panama’s individual timetable.
Any commencement, transition or implementation period appearing in a draft would remain contingent on the final text being adopted, constitutionally completed and promulgated. A proposed deadline in an unpassed bill does not begin to run.
Scope of the “no deadline” conclusion
The conclusion is limited to obligations created by a dedicated Panama VASP law.
It does not establish that every virtual-asset business may operate without authorization or compliance controls. A business could fall within existing law because, for example, its actual services constitute regulated securities activity, banking, custody, payments, money transmission or another regulated financial service. That determination requires an activity-by-activity analysis of the entity’s products, customer flows, custody arrangements, settlement mechanics, marketing and Panamanian nexus.
