Panama passed its primary CRS legislation in 2016, then passed a second law in 2017, and for it to be applicable from 2018, the  regulatory decree  was published on December 26, 2017.

The same thing happened in the Bahamas where even the authorities published the obligations and deadlines for depositary, custodian and investment entities  here .

Some legal and tax advisors look for “holes” in CRS laws to bypass reporting, however the OECD is constantly moving forward to close any possible gaps. The latest anti-circumvention regulation published is called “Game over for CRS avoidance!” and refers to the obligation of lawyers, accountants, financial advisers and banks to report offshore structures that have the consequence of avoiding  CRS reporting . These strategies and structures are sometimes expensive and are always short-term solutions due to constantly advancing regulation.