Rating: Partially Compliant
Panama’s implementation of the AEOI Standard is partially compliant with respect to exchanging the information effectively in practice and in a timely manner. More specifically, while Panama is meeting expectations with respect to sorting, preparing and validating the information (SR 2.4), and providing corrections, amendments or additions to the information (SR 2.9), there are significant issues with respect to Panama correctly transmitting the information and in a timely manner (SRs 2.5 – 2.8). While Panama has shown an improvement over time, Panama should continue its implementation process to ensure its effectiveness, including by addressing the recommendations made.
SR 2.4 Jurisdictions should sort, prepare and validate the information in accordance with the CRS XML Schema and the associated requirements in the CRS XML Schema User Guide and the File Error and Correction-related validations in the Status Message User Guide (i.e. the 50000 and 80000 range).
Findings:
Five (or 8%) of Panama’s exchange partners reported rejecting more than 25% of the files received, of which four reported rejecting 50% or more of the files received, due to the technical requirements not being met. This is a relatively high amount when compared to other jurisdictions and it has not improved over time. It was noted that Panama is working to solve at least some of the issues.
Based on these findings it was concluded that Panama is partially meeting expectations in relation to sorting, preparing and validating the information. However, significant issues have been identified, including with respect to the procedures to sort, prepare and validate the information before it is sent to partners and with respect to contacting partners when issues have been raised. Panama should therefore continue its implementation process accordingly, including by addressing the recommendations made.
Recommendations:
Panama should work with its exchange partners to address the issues raised.
Panama should review its procedures to sort, prepare and validate the information to ensure they meet the requirements of the AEOI Standard.
SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.
Findings:
In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Panama linked to the CTS.
Based on these findings it was concluded that Panama is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Panama is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.
Findings:
Feedback from Panama’s exchange partners did not raise any concerns with respect to timeliness of the exchanges by Panama and therefore with respect to Panama’s implementation of this requirement.
Based on these findings it was concluded that Panama fully is meeting expectations in relation to exchanging information in a timely manner. Panama is encouraged to continue to ensure the ongoing effectiveness of its implementation
Recommendations:
No recommendations made.
SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.
Findings:
Feedback from Panama’s exchange partners did not raise any concerns with respect to Panama’s use of the agreed transmission methods and therefore with Panama’s implementation of this requirement.
Based on these findings it was concluded that Panama is fully meeting expectations in relation to sending the information in accordance with the agreed transmission methods and encryption standards. Panama is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.
SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.
Findings:
Fifteen exchange partners highlighted delays in the sending of status messages by Panama, representing 19% of its partners. This represents a very high proportion of partners and has only slightly improved over time. Panama noted that it is experiencing technical issues with the sending of status messages and that it is working to solve them. As a provisional solution, it has notified some partners manually that the information has been received. While Panama is working on solving the issues and is engaging with some of its partners, it has still not yet sent some of the status messages due to be sent in 2021, as well as some that were due to be sent in prior years.
Based on these findings it was concluded that Panama is partially meeting expectations in relation to the receipt of the information. However, significant issues have been identified, including with respect to the sending of status messages to its exchange partners. Panama should continue its implementation process to ensure its effectiveness, including by addressing the recommendations made.
Recommendations:
Panama should continue to engage with its exchange partners to address the issues raised.
Panama should ensure it send status messages to all of its exchange partners in a timely manner.
SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.
Findings:
Panama appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner and no such concerns were raised by Panama’s exchange partners and therefore with respect to Panama’s implementation of these requirements.
Based on these findings it was concluded that Panama is fully meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Panama is encouraged to continue to ensure the ongoing effectiveness of its implementation.
Recommendations:
No recommendations made.