Documents and due diligence to incorporate
Before forming your company, the resident agent must know who you are. For each owner we ask for a copy of the passport, a proof of address and at least one bank or commercial reference.
For a shareholder that is a company, we ask for its certificate of good standing and the people who run it, and we follow the chain up to the natural person at the top.
Before we start
Due diligence is done before the relationship begins, and it covers the client, the beneficial owner and the company itself. The rules that apply today are in Executive Decree 35 of 2022. Guides that cite Executive Decree 363 of 2015 cite a regulation that has been replaced.
Source: Executive Decree 35 of 2022, articles 31 and 33; due diligence guide of the Superintendency of Non-Financial Regulated Entities
For each individual
We also record your date and place of birth, nationalities, address, phone and email, profession, activity and tax ID. Based on the risk, we may ask for employment letters, bank statements, a tax return or financial statements.
- A copy of the passport data page.
- A proof of address, such as a utility bill, a sale or lease contract, or a letter from the building management.
- At least one bank and/or commercial reference that identifies who issues it and how to reach them.
- If it applies, the license or a document of your activity.
- Your taxpayer certificate, or a similar document from your country with a sworn statement that you are not a taxpayer in Panama.
Source: Executive Decree 35 of 2022, articles 9, 12 and 17; Law 23 of 2015, article 26B
For a company that is a shareholder
- Its certificate of existence and good standing, or the foreign equivalent, with its directors and representation.
- The identity and address of its officers, directors, attorneys-in-fact and signatories.
- A copy of its share register and current share certificates, or else its articles, bylaws, powers or minutes, or else a sworn statement by its representatives, to reach the natural person at the top.
Source: Law 23 of 2015, article 28; Executive Decree 35 of 2022, articles 13 and 18
Politically exposed persons and high-risk countries
A politically exposed person, a close relative or a close associate always goes through enhanced due diligence: more documents, the purpose of the relationship, the source of funds and of wealth, approval by the firm’s partners, closer follow-up and at least a yearly update. The status lasts while in office and for up to two years after. The same enhanced review applies to clients from high-risk countries and from those the FATF flags. A person who meets the due diligence cannot be refused for being politically exposed.
Source: Law 23 of 2015, articles 4 and 34; Executive Decree 35 of 2022, articles 15 and 16
How often we update it
Due diligence is updated at least once a year for high-risk clients and at least every three years for low-risk ones, and earlier if there are doubts, unusual transactions or a change in risk.
Source: Law 23 of 2015, article 29; Executive Decree 35 of 2022, article 11; due diligence guide of the Superintendency
Questions people ask
Does the passport copy need an apostille?
The rules ask for a copy. They do not say it must be authenticated or apostilled.
Is a professional reference from my lawyer or accountant accepted?
The rules ask for a bank and/or commercial reference. A commercial one is enough on its own; a professional reference is not named.
Do I need to sign a source of funds declaration?
In enhanced due diligence the rules require more information on the source of funds. A form with that name is not a basic legal requirement.
What the law does not say
- How recent the proof of address and the reference letter must be. No rule we have read sets an age, so any limit is the agent’s own policy.
- A required length of relationship behind a reference letter.
- How often medium-risk clients are reviewed, which the Superintendency’s agreement sets and we have not read.
Official sources
Last verified: October 28, 2026
Thinking of forming a company in Panama?
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