Disclosure Requirements – Investment Funds – Panama


Disclosure Category: 2

Clearstream Banking S.A. (CBL) may be required, upon request, to disclose the identity and holdings of customers and ultimate beneficial owners in the case of holding Panama investment funds.


In order to comply with the local regulatory disclosure requirements, customers with holdings in Panama investment funds must consent and are hereby deemed to consent to the required legal disclosure. Such consent includes the appointment of the requestor (for example, the Fund Manager, Transfer Agent, Regulator) as their attorney-in-fact, under power of attorney, to collect from CBL the required information to be disclosed. Customers who do not grant such authority cannot hold such investment funds or financial instruments in their accounts with CBL.

Disclosure requirements

Customers are advised that under local laws and regulations, investment funds and its agents may require CBL, on request, to disclose information on CBL customers and ultimate beneficial owners.

Background and legal basis

Disclosure of information on CBL customers and ultimate beneficial owners may arise from the following Panama laws and regulations:

  • Law 23, 2015 (AML)


Non-compliance with the disclosure requirements may result in the fund manager or its agent refusing acceptance of the proposed investment, and/or mandatory redemption of the existing holdings.


The information contained in the Disclosure Requirements is based on a legal questionnaire obtained by CBL that was issued on  27 January 2023. CBL believes the information to be correct as at that datebut disclaims any responsibility as to the accuracy and completeness of the information. In the case of discrepancy between the information provided by CBL and the local laws and regulations, the latter shall prevail. The Disclosure Requirements do not constitute legal advice and customers should seek advice from independent professional counsel.

Customers are responsible for ensuring compliance with the disclosure requirements and agree to indemnify and hold harmless CBL, for any loss, expense, liability, damage, or claims, whether direct or indirect, against or incurred by CBL arising out of or resulting from such non-compliance.