Contents of this guide
Why a bank can say no
Panamanian banks run due diligence on every customer before opening a relationship. Agreement 1 of 2026 of the Superintendency of Banks, issued on January 16, 2026 and in force since July, requires banks to place each customer in a risk category (high, medium or low) and to ask for documents according to that category (article 12). When the file does not show where the money comes from or what the applicant does for a living, the bank may not complete the opening.
Radar’s guide to opening a bank account in Panama as a foreigner explains what the rule requires and what each bank requires. This article starts from that point: what happens when an application does not go through, why it usually happens and what can be done next.
One fact helps locate the problem. The high-risk list in article 20 covers politically exposed persons, customers who handle large amounts of cash, and customers with capital or partners from countries the FATF considers non-cooperative, plus whatever criteria each bank sets. Non-residents are not a category on that list. Most refusals are therefore explained by the file and the profile rather than by the applicant’s nationality.
Documented reasons and what avoids them
The table lists the points the Agreement tells banks to review and the document or preparation that covers each one. The detail depends on each bank’s internal policy.
| Review point | What Agreement 1 of 2026 says | What usually avoids the problem |
|---|---|---|
| Source of funds not supported | The source of funds is supported with information the bank collects, public sources or documents from the customer (article 18). | Documents that explain where the money comes from and that the bank can verify. |
| Financial profile does not match the activity | The bank must hold one or more of: employment letter, social security record, sworn income declaration or proof of payment, and the profile must be consistent with the activity (article 18). | Providing at least one of those proofs and expecting activity that fits the income. |
| Expired or incomplete passport | The passport must be valid; the bank keeps a copy of the photo and data page and of the page with the entry stamp, with exceptions for customers recruited abroad (article 18). | A valid passport and legible copies of the requested pages. |
| Missing tax identification number | A foreign customer provides the tax number of each country where they are a taxpayer (article 18). | Having the tax number of every country of tax residence at hand. |
| Links to risky countries or capital | Geography (nationality, origin and destination of funds, country of domicile) is part of the risk profile; capital or partners from FATF non-cooperative countries count as high risk (articles 13 and 20). | Clear documentation of where money comes from and goes to; nationality cannot change, but the case can be explained with support. |
| Politically exposed person | Requires enhanced due diligence and senior management approval; the status lasts while in office and for 2 more years (article 27). | Declaring the status from the start, with asset documentation. |
| Large cash amounts | A high-risk criterion according to each entity’s policies (article 20). | Preferring traceable transfers and documenting their origin. |
| Inconsistent data in remote opening | Banks must use inferential geolocation (IP, VPN, proxies, time zone) to verify the declared address; adaptation period until June 30, 2027 (articles 14 and 53). | The declared address matching the place the application is made from. |
| Company whose beneficial owner is not identified | The bank must reach the natural person who controls the company and abstains from starting a relationship with suspended Panamanian companies (article 19). | Ownership chart, articles of incorporation and up-to-date certificates. |
What the bank asks for and the rule does not
Many refusals are blamed on a missing apostille, bank references or recommendation letters. The text of Agreement 1 of 2026 does not mention the apostille or bank references among its identification and profile requirements. When a bank asks for them, the request comes from its internal policy, according to the bank pages collected in Radar’s guide. That difference explains why the same file can go through at one bank and stall at another.
The Superintendency has acknowledged this variation. A preliminary diagnosis of the pilot plan to make account opening easier, reported by La Estrella de Panamá on April 3, 2026, lists differences in how compliance criteria are interpreted among the factors. The firm Legal Solutions Panamá says on its bank account opening page that each entity applies different compliance and risk criteria, so no single bank suits every profile.
How to apply again, step by step
There is no published official statistic on how many foreigners’ applications are rejected, and no official deadline for a bank to answer an account application. What can be put in order is the second attempt.
- Ask the bank for the reason, in writing if possible. Internal policy decides how much the bank explains, but any answer guides the fix.
- Compare the reason with the table above to see whether identification, source of funds, financial profile or geographic links are the problem.
- Complete the file with current documents: passport, tax number, proof of income and support for the origin of the money.
- Check that everything is consistent: declared activity, income, expected balance, address and application data.
- Choose another bank with care, asking first which documents it requests from a foreign applicant. Radar’s guide and the ranking of firms that handle openings from abroad are a starting point.
- Avoid several unordered simultaneous applications, because each bank records what it receives and the same source-of-funds story should be presented to all of them.
The firm Legal Solutions Panamá states that it reviews each case before starting the procedure and that some of its plans include alternatives if the first route proves unsuitable.
Anyone who wants the profile reviewed before applying again can consult the bank account opening page of Legal Solutions Panamá.
Complaining to the Superintendency of Banks
The Superintendency publishes a guide to filing complaints and Agreement 9 of 2025, in force since November 2025, which updates the procedure. The order is:
- First, the complaint is filed with the bank’s own complaint system, which has 30 calendar days to answer.
- If the bank does not answer within that period or the answer is unsatisfactory, the consumer has up to 30 calendar days to go to the Superintendency, in person or through its web platform.
- The filing includes a copy of a valid ID or passport, proof of the complaint filed with the bank and the bank’s answer, if any. The consumer can act personally or through a third party, a lawyer or not (article 3 of Agreement 9 of 2025).
- The process includes notice to the bank, a possible meeting between the parties, evidence for 5 business days, arguments and a final resolution that is binding on both sides.
The guide sets limits: claims above B/.20,000 and claims from people who do not fall into the bank consumer category go to the ordinary courts. The procedure is described for bank consumers, meaning bank customers. The sources reviewed do not say whether a denied account application goes through this channel, so it is advisable to ask the Superintendency before filing. Its phone number in the guide is (507) 506 7800.
What cannot be promised
- Guaranteed approval. No adviser controls the bank’s decision; risk policy belongs to each institution.
- Response times. There is no published official deadline for answering an account application; firms’ estimates are only indicative.
- Approval or rejection figures. The Superintendency does not publish a rejection rate for foreigners’ applications.
- That a complaint will reverse the refusal. The outcome depends on the case and on whether the channel applies.
On who handles these procedures, the note on how to verify a lawyer in Panama and the guide to lawyers for foreign investors help in choosing with care. Anyone who needs a company to operate can first read about corporations, LLCs and private foundations, and an interview with Kathia Rivera on incorporating a company without traveling adds context.
The information in this article is general and does not replace the advice of a qualified lawyer for the specific case.
Frequently asked questions
Why am I denied a bank account in Panama?
Because the bank could not complete its risk assessment with the file submitted. Agreement 1 of 2026 tells banks to review identification, source of funds, financial profile, country of domicile and tax residence, and each bank decides under its own policy.
What to do if the bank rejects my account?
Ask for the reason, fix the weak point in the file and apply again, at the same bank or at another whose policy fits the profile. If a complaint applies, it goes first to the bank’s complaint system and then, where it proceeds, to the Superintendency of Banks.
Can a bank deny an account to a foreigner?
Yes, a bank can decline to complete an opening if due diligence is not satisfied. Agreement 1 of 2026 does not classify a non-resident as high risk by itself; the decision rests on the profile’s risk and on each bank’s policy.
How long does a bank take to answer?
There is no published official deadline for answering an account application. The 30 calendar days set by the Superintendency apply to complaints a customer has already filed with their bank.
Can a complaint be filed with the Superintendency of Banks?
There is an official complaint procedure for bank consumers against general-license banks, capped at B/.20,000 and starting with the bank itself. The sources reviewed do not say whether it covers a denied opening, so it should be confirmed with the Superintendency.
Related articles
- Opening a bank account in Panama as a foreigner: what the rule requires and what each bank requires
- Opening a bank account in Panama from abroad: the firms that handle it, compared
- Panama’s eight residency routes compared
- Best lawyers in Panama for foreign investors: five firms compared
- How to verify an immigration lawyer in Panama
- Corporation, LLC or private interest foundation: which suits in Panama
- Documents to Open a Bank Account in Panama as a Foreigner: Checklist by Profile
- Panama Bank Account Without Residency: Limits and Options
Sources
All sources were checked on October 8, 2026. Official sources are in Spanish.
- Superintendency of Banks of Panama, Agreement 1 of January 16, 2026, articles 12 to 20, 27 and 53.
- Superintendency of Banks of Panama, Agreement 9 of November 12, 2025, complaints procedure.
- Superintendency of Banks of Panama, guide to filing complaints.
- La Estrella de Panamá, bank user complaints and account opening pilot plan, April 3, 2026.
- Legal Solutions Panamá, bank account opening.
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