(17)In June 2019, the FATF identified Panama as a jurisdiction having strategic AML/CFT deficiencies for which Panama has developed an action plan with the FATF. The Commission assessed the latest information received in this context from the FATF relating to these deficiencies and other relevant information. The deficiencies include: (1) a limited understanding of the national and sectoral money laundering/terrorist financing risk and consequent shortcoming in informing the related findings to the country’s national policies in a view to mitigate the identified risks; (2) deficiencies regarding proactive identification of unlicensed money remitters, the application of a risk-based approach to supervision of the DNFBP sector and the application of effective, proportionate, and dissuasive sanctions against AML/CFT violations; (3) lack of adequate verification and update of beneficial ownership information by obliged entities, lack of an effective mechanism to monitor the activities of offshore entities, shortcomings in assessing the existing risks of misuse of legal persons and arrangements to define and implement specific measures to prevent the misuse of nominee shareholders and directors, and shortcomings in ensuring timely access to adequate and accurate beneficial ownership information; and (4) deficiencies with regard to the effective use of FIU products for money laundering investigations, as well as with regard to the ability to investigate and prosecute money laundering involving foreign tax crimes and to provide constructive and timely international cooperation in relation to such offence, and unsatisfactory focus on ML investigations in relation to high-risk areas identified in the National Risk Assessment and Mutual Evaluation Report. On this basis, Panama should be considered as a country having strategic deficiencies in its AML/CFT regime under Article 9 of Directive (EU) 2015/849.