Last updated: October 25, 2026
This U.S. Persons Policy (“Policy”) sets out the position of Gallostone & Partners (“the Firm”, “we”, “us”, or “our”) on the acceptance of clients who are citizens or residents of the United States of America. This Policy forms part of, and should be read together with, the Firm’s Terms and Conditions. By applying to become a client or engaging the Firm’s services, you confirm that you have read and understood this Policy.
1.1 The Firm does not accept, open accounts for, or provide services to any U.S. Person, as defined in Section 2.
1.2 This Policy applies to all of the Firm’s services, including digital-asset services, company formation, banking introductions and advisory services, in every jurisdiction in which the Firm operates.
1.3 This Policy reflects the Firm’s assessment of legal, regulatory and financial risk. It is not a judgement about any individual applicant or client.
2.1 For the purposes of this Policy, a “U.S. Person” means any of the following:
Under the U.S. Foreign Account Tax Compliance Act (“FATCA”), a financial institution that is required to withhold tax on certain payments is itself liable for that tax if it fails to withhold or remit it, together with any applicable interest and penalties. By way of illustration, a failure to apply the required 30% withholding to a payment of USD 1,000,000 could give rise to a liability of USD 300,000 before interest and penalties. Engaging a third-party service provider to perform compliance functions does not, in general, transfer that liability away from the institution.
An institution that is treated as a non-participating foreign financial institution may become subject to 30% withholding on certain payments it receives. This exposure would extend to the Firm’s own business and is not limited to the revenue derived from any single client. Under the intergovernmental agreements entered into between the United States and partner jurisdictions, significant non-compliance is generally subject to notification and an opportunity to remedy, and is not an automatic consequence of every reporting error. The Firm nonetheless considers this risk unacceptable.
The Republic of Panama approved its intergovernmental agreement with the United States by Law 47 of 2016. Law 51 of 2016 establishes the domestic framework for reporting, due diligence and record-keeping for tax-information exchange purposes. The Dirección General de Ingresos (“DGI”) audits compliance with these obligations and may impose penalties for late or missing reports, inaccurate information, or inadequate due diligence.
Knowingly assisting any person to conceal U.S. ownership, or deliberately circumventing FATCA reporting, may give rise to criminal liability for the institution and for its directors, officers and employees personally. The Firm will not place itself or its personnel in any position where such pressure could arise.
Where U.S. jurisdiction applies, violations of sanctions administered by the U.S. Office of Foreign Assets Control (“OFAC”) may result in civil penalties on a strict-liability basis, irrespective of intent. Serving U.S. Persons would increase the likelihood that U.S. jurisdiction applies to the Firm’s activities.
The provision of investment or digital-asset services to U.S. Persons may require registration as a broker-dealer with the U.S. Securities and Exchange Commission, depending on the nature of the services and transactions involved. The Firm is not so registered and does not intend to become so.
4.1 Every applicant must declare, as part of the Firm’s client acceptance procedures, whether they are a U.S. Person.
4.2 The Firm may request documents to verify any declaration, including passports, proof of residence and tax-residency certificates.
4.3 Where the Firm identifies any U.S. indicator — including a U.S. place of birth, residential or mailing address, telephone number, or standing payment instruction to a U.S. account — the applicant or client must provide a satisfactory explanation and supporting documents before the Firm will proceed.
4.4 The Firm reserves the right to decline any application, in its sole discretion, where it is not satisfied that the applicant is not a U.S. Person.
5.1 A client who becomes a U.S. Person after the commencement of an engagement must notify the Firm in writing within thirty (30) days of the change.
5.2 Upon becoming aware that a client is a U.S. Person, the Firm will terminate the relationship in an orderly manner in accordance with Section 14 (Termination) of the Firm’s Terms and Conditions.
6.1 Any false, misleading or incomplete declaration regarding U.S. Person status constitutes a material breach of the Firm’s Terms and Conditions and entitles the Firm to terminate the relationship with immediate effect.
6.2 The Firm may report false declarations to the competent authorities where required by applicable law.
7.1 This Policy describes the Firm’s client acceptance position. It does not constitute legal, tax or financial advice. Persons who are uncertain of their U.S. tax status should obtain independent professional advice.
8.1 The Firm may amend this Policy at any time. The current version is published on this website with the date of last update.
Questions regarding this Policy may be directed to:
Gallostone & Partners
Torre Bicsa Financial Center, Piso 36
Punta Pacífica, Panama City, Republic of Panama
contact@gallostonepartners.com