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Enforcement – Information updated through July 9, 2023

Enforcement – Information updated through July 9, 2023

As provided for in (a) Article 189 of the Banking Law, which establishes, “The Superintendent is authorized to publish the sanctions imposed in accordance with the provisions of this Decree Law;” (b) Article 77 of Law 21 of 2017, which establishes the rules for the regulation and supervision of Trustees and the trust business and stipulates that “The Superintendent of Banks may inform the public of the fine imposed, either in hardcopy or electronically;” and (c) Article 20(5) of Law 23 of 2015, amended by Law 21 of 2017, that provides “[…] The sanctions imposed hereby will be published on the website of each supervisory entity, stating the name of the sanctioned entity, the type of sanction, and its amount, if the sanction is pecuniary.” Below you will find the pecuniary sanctions of over B/.5,000.00 imposed by the Superintendency in accordance with the Banking Law, Trust Law, and AML/CFT/WMD Law.

The sanctions listed below pertain to concluded processes, the resolutions of which are being administratively enforced. It should be noted that the imposed sanctions result from non-compliance or administrative breaches, and they serve the purpose of corrective actions and the enhancement of the Panamanian banking and trust system. The publication of these sanctions does not indicate a negative view of the supervised entity.


YEAR ENTITY AMOUNT DESCRIPTION
2015 BANCO AZTECA (PANAMÁ), S. A. 6,001.00 For the late submission of the affidavit signed by the Chairman of the Board of Directors, which must be attached to the Financial Statements.
2015 AUSTROBANK OVERSEAS (PANAMÁ), S. A. 6,001.00 For the late submission of the affidavits signed by the Chairman of the Board of Directors, the General Manager, and the senior Financial Officer of the bank.
2015 BANESCO, S. A. 400,000.00 For breaching AML/CFT regulations.
- Special examination conducted from November 18 to December 12, 2014 (closing date; October 31, 2014).
240,000.00 For breaching banking regulations.
- Special examination conducted from November 18 to December 12, 2014 (closing date: October 31, 2014).
2015 UNIBANK, S. A. 370,000.00 For breaching AML/CFT regulations.
- Special examination conducted from November 19 to December 5, 2014 (closing date: October 31, 2014).
210,000.00 For breaching banking regulations.
- Special examination conducted from November 19 to December 5, 2014 (closing date: October 31, 2014).
2015 CAJA DE AHORROS 260,000.00 For breaching AML/CFT regulations.
- Special examination conducted from November 24 to December 12, 2014 (closing date: October 31, 2014).
240,000.00 For breaching banking regulations.
- Special examination conducted from November 24 to December 12, 2014 (closing date: October 31, 2014).
2015 GLOBAL BANK CORPORATION 42,500.00 For breaching banking regulations.
- Special examination conducted from November 24, 2014 to January 6, 2015 (closing date: November 18, 2014).
2015 BANCO UNIVERSAL, S. A. 1,000,000.00 For breaching AML/CFT regulations.
- Follow-up examination through December 31, 2012, conducted from September 9 to October 4, 2013.
250,000.00 For breaching Corporate Governance regulations.
- Comprehensive examination conducted from July 14 to August 8, 2014 (closing date: March 31, 2014).
250,000.00 For breaching Risk regulations.
- Special examination conducted from November 24 to December 23, 2014 (closing date: October 31, 2014).
2015 BANCO FICOHSA (PANAMÁ), S. A. 90,000.00 For breaching AML/CFT regulatioins.
- Special examination conducted from January 6 to January 29, 2015 (closing date: December 31, 2014).
60,000.00 For breaching banking regulations.
- Special examination conducted from December 2 to December 17, 2014 (closing date: October 31, 2014).
YEAR ENTITY AMOUNT DESCRIPTION
2016 ST. GEORGE BANK & COMPANY, INC. 20,000.00 For breaching AML/CFT regulations.
- Special examination conducted from January 13 to January 30, 2015 (closing date: November 30, 2014).
7,500.00 For breaching banking regulations.
- Special examination conducted from January 14 to January 29, 2015 (closing date: November 30, 2014).
YEAR ENTITY AMOUNT DESCRIPTION
2017 MEGA INTERNATIONAL COMMERCIAL BANK CO., LTD. 1,000,000.00 For breaching AML/CFT regulations.
- Comprehensive examination conducted from August 24 to November 1, 2016, (closing date: June 30, 2016).
250,000.00 For breaching banking regulations.
- Comprehensive examination conducted from September 12 to October 21, 2016 (closing date: June 30, 2016).
2017 BANISTMO, S.A. 198,000.00 For breaching AML/CFT regulations.
- Special examination conducted from February 4 to February 27, 2015 (closing date: December 31, 2014).
- Comprehensive examination conducted from February 3 to June 17, 2014.
- Comprehensive examination from August 24 to October 5, 2015 (closing date: June 30, 2015).
67,500.00 For breaching banking regulations.
- Comprehensive examination conducted from August 24 to October 5, 2015 (closing date: June 30, 2015).
2017 MULTIBANK, INC. 300,000.00 For breaching AML/CFT regulations.
- Special examination conducted (closing date: June 17, 2015).
- Special examination from May 23 to June 8, 2016 (closing date: March 31, 2016).
100,000.00 For breaching banking regulations.
- Special examination conducted from May 18 to May 28, 2015 (closing date: April 30, 2015), updated during the Special examination conducted from October 21 to October 27, 2015 (closing date: September 30, 2015).
- Comprehensive examination conducted from August 17 to November 30, 2015 (closing date: June 30, 2015).
2017 BANCO PANAMEÑO DE LA VIVIENDA, S.A. 90,000.00 For breaching AML/CFT regulations.
- Comprehensive examination conducted from March 9 to April 9, 2015 (closing date: December 31, 2014).
40,000.00 For breaching banking regulations.
- Comprehensive examination conducted from March 9 to April 9, 2015 (closing date: December 31, 2014).
2017 BANCO NACIONAL DE PANAMÁ 106,750.00 For breaching AML/CFT regulations.
- Special examination conducted from November 24 to December 12, 2014 (closing date: October 31, 2014).
- Special examination conducted from May 18 to July 10, 2015 (closing date: December 31, 2014).
- Comprehensive examination conducted from May 18 to July 31, 2015.
21,875.00 For breaching banking regulations.
- Special examination conducted from November 24 to December 12, 2014 (closing date: October 31, 2014).
- Special examination conducted from May 18 to July 10, 2015 (closing date: December 31, 2014).
- Comprehensive examination conducted from May 18 to July 31, 2015.
YEAR ENTITY AMOUNT DESCRIPTION Administrative Lawsuit of Full Jurisdiction. Process result:
2018 CAPITAL BANK, INC. 175,000.00 For breaching AML/CFT regulations.
- Special examination conducted form January 15 to February 5, 2015 (closing date: December 31, 2014).
- Comprehensive examination conducted from February 23 to March 6, 2015, (closing date: May 31, 2015).
- Special examination conducted from June 8 to July 10, 2015, (closing date: May 31, 2015).
Through a Judgment dated December 19, 2022, issued by the Third Chamber of the Supreme Court of Justice (and a Resolution dated March 13, 2023), Resolution SBP-0031-2017 dated March 2, 2017, issued by the Superintendency of Banks of Panama, along with its confirming actions, and in light of the precedent statements, it is ordered to reimburse Capital Bank, Inc. the fines paid.
250,000.00 For breaching banking regulations.
- Special examination conducted from January 20 to February 4, 2015, (closing date: November 30, 2014).
- Special examination conducted from August 26 to September 23, 2015, to expand the scope of the comprehensive examination (closing date: December 31, 2014).
- Comprehensive examination conducted from August 24 to October 5, 2015 (closing date: June 30, 2015).
2018 BANCO CITIBANK (PANAMÁ), S.A. (ahora SCOTIABANK PANAMA, S.A.) 20,000.00 For breaching banking regulations.
- Special examination conducted from June 2 to September 30, 2015 (closing date: May 31, 2015).
2018 BANISTMO, S.A. 7,500.00 For breaching the Banking Law, specifically: Article 192; Article 193(5); Article 194(1) and (4); and Article 206; as well as Article 4(a) and (e) of Rule 1-2008, due to an administrative complaint.
2018 BANCO FICOHSA (PANAMÁ), S. A. 10,000.00 For breaching the Banking Law: Article 111 and Article 194(3); as well as Article 18 of Rule 6-2011, amneded by Article 2 of Rule 9-2014 dated September 23, 2014, due to an administrative complaint.
2018 AUSTROBANK OVERSEAS (PANAMÁ), S.A. 30,000.00 For breaching the Banking regulations as of October 31, 2017, specifically:
1. Article 70 of the Banking Law;
2. Article 10 of Rule 1-2015 dated February 3, 2015, amended by Rule 13-2015 dated December 13, 2015;
3. Article 38 of Rule 4-2013 dated May 28, 2013, amended by Rule 8-2014 dated September 16, 2014;
4. Article 5 of General Resolution 2-2017 dated May 18, 2017.
2018 CANAL BANK, S.A. 25,000.00 For breaching banking regulations as of March 31, 2017, specifically:
1. Article 70 of the Banking Law;
2. Article 10 of Rule 1-2015, amended by Rule 13-2015;
3. Article 38 of Rule 4-2013, amended by Rule 8-2014.
2018 FIDUCIARIA MOSSFON, S.A. 250,000.00 For breaching AML/CFT regulations.
- Comprehensive examination conductd from April 13 to April 30, 2015 (closing date: December 31, 2014).
- Special examination conducted from February 1 to February 2, 2016.
- Special examination conducted from April 12 to July 8, 2016, (closing date: March 31, 2016).
50,000.00 Trust Regime
- Special examination conducted from April 12 to June 24, 2016 (closing date: March 31, 2016).
2018 CREDICORP BANK, S.A. 500,000.00 For breaching AML/CFT regulations.
- Special examination conducted from October 16 to December 4, 2015 (closing date: August 31, 2015).
287,500.00 For breaching banking regulations.
- Special examination conducted from October 16 to December 4, 2015 (closing date: August 31, 2015).
YEAR ENTITY AMOUNT DESCRIPTION
2019 CAJA DE AHORROS 15,000.00 For breaching banking regulations, specifically: Banking Law: Article 192; Article 193(1), (5), and (6); as well as Article 2 of Rule 1-2011; and Article 17 of Rule 4-2013 due to an administrative complaint.
2019 MEGA INTERNATIONAL COMMERCIAL BANK CO. LTD 10,000.00 For breaching banking regulations, specifically: Banking Law: Article 192; Article 193(5); Article 194(1) and (4); Article 206; as well as Rule 1-2008: Article 2; Article 3(3); Article 4(a) and (e); Article 5 due to an administrative complaint.
2019 BANCO ALIADO, S.A. 210,000.00 For breaching AML/CFT regulations.
75,000.00 For breaching the Banking Law.
- Comprehensive examination conducted in two phases: Phase I from November 9 to December 18, 2015 (closing date: June 30, 2015); Phase II from February 15 to April 8, 2016 (closing date: December 31, 2015).
2019 BANCO PANAMÁ, S.A. 80,000.00 For breaching AML/CFT regulations.
- Special examination conducted from February 11 to March 3, 2015.
20,000.00 For breaching banking regulations.
- Follow-up examination conducted from June 1 to June 17, 2015 (closing date: April 30, 2015).
- Special examination conducted from February 11 to March 3, 2015.
YEAR ENTITY AMOUNT DESCRIPTION
2020 SCOTIABANK (PANAMÁ), S.A. 118,671.22 For breaching banking regulations, specifically: Article 111, Article 193(5) and (6), and Article 194(4) of the Banking Law; Article 2 and Article 3 of Rule 8-2005; as well as Article 4(b) of Rule 5-2011, amended by Rules 4-2012 and 5-2014; Article 14, Article 15(7), Article 16(a) of Rule 6-2011, amended by Rule 9-2014, due to an administrative complaint.
2020 BANCO GENERAL, S.A. 7,500.00 For breaching banking regulations, specifically: Article 192, Article 193(5); Article 193(6) of the Banking Law; as well as Article 2 of Rule 1-2011 dated January 4, 2011, amended by Rule 3-2011 dated March 17, 2011; Article 4(a) of Rule 1-2008 dated June 18, 2008, due to an administrative complaint.
2020 BANISTMO, S.A. 15,000.00 For breaching banking regulations, specifically: Banking Law: Articles 111, 192 and 194(3); as well as Article 2 of Rule 8-2005, due to an administrative complaint.
2020 QUIJANO TRUST CORPORATION 26,400.00 For breaching AML/CFT regulations, specifically:
- Follow-up examination conducted from November 29 to December 13, 2017 (closing date: September 30, 2017).
YEAR ENTITY AMOUNT DESCRIPTION
2021 BANCO AZTECA (PANAMÁ), S.A. B/. 5,100.00 For breaching banking regulations, specifically:
- Findings from the comprehensive examination conducted from June 10 to October 25, 2019 (closing date: July 31, 2019).
2021 The Bank Of Nova Scotia B/. 19,270.14 For breaching banking regulations, specifically: Article 111, Article 192, Article 193(1), (2) and (5), Article 194(1), (3) and (4), and Article 196(6) of the Banking Law; as well as Article 5 of Rule 3-2002 dated March 27, 2002; Articles 2, 4, and 9 of Rule 1-2011 dated January 4, 2011, amended by Rule 3-2011 dated March 17, 2011, due to an administrative complaint.
2021 Bank of China Limited B/.1,000,000.00 For breaching AML/CFT regulations, specifically:
- Comprehensive examination conducted from October 10 to December 16, 2016 (closing date: August 31, 2016).
- Follow-up examination from July 17 to August 4, 2017 (closing date: May 31, 2017).
- Follow-up examination conducted from October 29 to November 16, 2018.
- Special examination conducted from August 5 to September 10, 2019 (closing date: July 31, 2019)
B/.250,000.00 For breaching banking regulations, specifically: Articles 55 and 114 of the Banking Law; as well as Article 13(c) and (f) of Rule 4-2012 dated June 19, 2012; Rule 5-2014 dated July 22, 2014; and Rule 8-2019 dated August 13, 2019.
Year Entity Amount (in B/.) Description
2022 CAJA DE AHORROS 18,500.00 For breaching AML/CFT regulations.
- Rule 12-2005 dated December 14, 2005 (applicable to the date when the events under analysis occurred): Article 1; Article 4(1)(f), (h), (i), (2), and (6).
- Rule 10-2015 dated July 27, 2015, and its amendments: Article 9; Article 14(1), (3), (4), (5), and (6); Article 18; Article 21(1), (2), (3), and (5); Article 29(1), (2), (3), (4), and (5), due to an administrative complaint.
2022 BAC INTERNATIONAL BANK, INC. 40,500.00 For breaching AML/CFT regulations.
- Rule 12-2005 dated December 14, 2005 (applicable to the date when the events under analysis occurred): Article 1; Article 4 1(1)(f), (h), (i), (2), and (6).
- Rule 10-2015 of 2015 and its amendments: Article 9; Article 14(1), (3), (4), (5), and (6); Article 18; Article 21(1), (2), (3), and (5); Article 29(1), (2), (3), (4), and (5) due to an administrative complaint.
13,500.00 For breaching banking regulations, specifically: Article 112, Article 114 of the Banking Law; as well as Article 4, Article 11 of Rule 7-2003 due to an administrative complaint.
2022 BANCO GENERAL, S.A. 20,000.00 For breaching AML/CFT regulations (Rule 10-2015, amended by Rule 1-2017, Article 15(7)) due to an administrative complaint.
2022 BANCO LAFISE (PANAMÁ), S.A. 164,000.00 For breaching AML/CFT regulations.
- Comprehensive examination conducted from August 27 to October 2, 2015 (cut-off date: June 30, 2015).
- Comprehensive examination conducted from August 16 to September 28, 2016 (cut-off date: June 30, 2016).
100,000.00 For breaching banking regulations.
- Comprehensive examination from August 24 to October 9, 2015 (operational risk); and from August 24 to November 20, 2015 (banking law).
- Comprehensive examination conducted from August 16 to September 28, 2016, (cut-off date: 30 June 2016).
2022 BANESCO (PANAMÁ), S.A. 288,000.00 For breaching AML/CFT regulations.
- Comprehensive/Special examination conducted from July 25 to August 21, 2019 (cut-off date: July 31, 2019).
162,000.00 For breaching banking regulations.
- Comprehensive/Special examination conducted from July 25 to August 21, 2019 (cut-off date: July 31, 2019).
2022 MMG TRUST, S.A. 25,000.00 For breaching AML/CFT regulations.
- Comprehensive examination conducted from March 19 to April 15, 2015 (cut-off date: December 31, 2014).
- Follow-up examination conducted from May 30 to June 17, 2016.
- Special examination conducted from April 28 to June 8, 2016 (cut-off date: March 31, 2016).
2022 ILH TRUST (PANAMÁ), INC. (antes OWA TRUST (PANAMÁ), CORP.) 25,000.00 For breaching AML/CFT regulations.
- Comprehensive examination conducted from October 26 to November 20, 2015 (cut-off date: September 30, 2015).
2022 ATLAS BANK (PANAMÁ), S.A. 50,000.00 For breaching banking regulations.
- Comprehensive examination conducted from July 16 to October 5, 2018 (Article 48(1) of the Banking Law; Article 9(c) and (h) of Rule 3-2001 of 2001, amended by Rule 2-2006).
2022 GALA TRUST AND MANAGEMENT SERVICES, INC. 12,000.00 For breaching AML/CFT regulations.
- Follow-up examination conducted from October 16 to November 13, 2017 (cut-off date: September 31, 2017) (sic).
2022 BANCO PICHINCHA PANAMÁ, S.A. 12,000.00 For breaching banking regulations due to the late submission of the quarterly Economic Group and Related Parties Report (BAN03) for the quarter ending in December 2021, with a submission deadline of January 31, 2022.
2022 BAC INTERNATIONAL BANK, INC. 10,000.00 For breaching banking regulations, specifically of:
- Article 111, Article 194(3) of Banking Rule.
- Article 18 of Banking Rule 6-2011 dated December 6, 2022 (sic), amended by Article 2 of Rule 9-2014 dated September 23, 2014.
- Article 2 of Banking Rule 8-2005 dated September 21, 2005 due to an administrative complaint
2022 BANCO DELTA, S.A. 25,000.00 For breaching AML/CFT regulations, pertaining to findings from the Comprehensive Examination conducted from April 12 to May 7, 2021 (cut-off date: December 31, 2020).
10,000.00 For breaching banking regulations, pertaining to findings from the Comprehensive Examination conducted from April 12 to May 7, 2021 (cut-off date: December 31, 2020).
2022 FACTOR GLOBAL, INC. 75,000.00 For breaching AML/CFT regulations, pertaining to findings from the Comprehensive Examination conducted from August 2 to September 6, 2017 (cut-off date: June 30, 2017).
2022 GLOBAL BANK CORPORATION 50,000.00 For breaching AML/CFT regulations, pertaining to findings from the Comprehensive Examination conducted from Juy 10 to December 7, 2017.
175,000.00 For breaching banking regulations:
- Findings from the Special Examination conducted from July 10 to August 18, 2017.
- Findings from the Comprehensive Examination conduced from July 20 to December 7, 2017 (cut-off date: June 30, 2017).
- Findings from the Comprehensive Examination conducted from July 10 to November 24, 2017 (cut-off date: June 30, 2017).
Year Entity Amount (in B/.) Description
2023 Bac International Bank, Inc. 15,000.00 For breaching banking regulations, specifically:
- Article 111; Article 194(3) of the Banking Law
- Article 18 of Banking Rule 6-2011 dated December 6, 2022 (sic), amended by Article 2 of Rule 9-2014 dated September 23, 2014; Article 2 of Banking Rule 8-2005 dated September 211, 2005 (sic); Article 8 of Banking Rule 9-2005 dated October 19, 2005, due to an administrative complaint.

The following is a list of individuals how have been disqualified by the Superintendency of Banks of Panama for an additional period of two years beyond the primary penalty imposed by the Judicial Branch. They are barred from holding managerial positions in entities engaged in the banking and trust businesses. (Activities related to the illegal money service business).

Name Resolution No. Published in Official Gazette No.
Yulimar Trinidad Méndez Gonzales

Yohander Gregorio Vilela Arias
SBP-106-2021 dated September 3, 2021 29,578 dated Thursday, July 14, 2022
Norma Beatriz Campos Márquez SBP-0001-2022 dated January 4, 2022 29,562 dated Wednesday, June 22, 2022
Francisco Javier Rivera Munizaga SBP-0105-2021 dated September 3, 2021 29,839 dated Thursday, August 3, 2023
Carlos Enrique Huertas Pérez SBP-BAN-R-2023-01172 dated June 23, 2023 29,846 dated Thursday, August 14, 2023