The OECD have removed Panama from the Residence Blacklist on condition that Panamanian ID cards issued pursuant to the following programs:
Reforestation Investor Permit
Economic Solvency Permit, and
Friendly Nations Permit
contain reference to the relevant schemes under which the ID card is issued. This is intended to permit Financial Institutions presented with such ID cards to assess whether to apply the “High Risk” enhanced due diligence questions. http://www.oecd.org/tax/automatic-exchange/news/residence-citizenship-by-investment-update-panama-november-2018.htm
It remains uncertain whether compliance staff should continue to treat Panama issued proof of residence as High Risk in respect of existing financial accounts; removal of Panama from the Blacklist would seem to indicate that existing accounts are now not subject to review.
The OECD appear to be adopting an ad hoc approach in removing jurisdictions from the Blacklist. Malta and Cyprus remain on the list notwithstanding both jurisdictions are subject to CRS Mandatory Disclosure Rules.
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