NextSpring

A Right to a Basic Account if You Live in the Union, and Enhanced Checks if You Live Somewhere the Commission Has Named

Answer

The general rule applies to you

No exception is recorded for citizens of Panama on this topic. That is the answer, not a gap - everything below is the rule you get, unchanged.

116 exceptions recorded across 45 countries · none match Panama to Ireland · Opening a bank account

Two instruments decide this and they pull in opposite directions. The European Union (Payment Accounts) Regulations 2016 give a consumer who is legally resident in the European Union a right to open and use a payment account with basic features, regardless of place of residence, and forbid a credit institution to discriminate by nationality when anyone applies for a payment account at all. The Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 goes the other way: section 33 requires the bank to identify and verify the customer before the relationship starts, on documents from a government source or another source it has reasonable grounds to rely on, and section 38A adds six further measures for a customer established or residing in a high-risk third country - a category defined by reference to a list the European Commission draws up, not the bank and not the Oireachtas.

Verified with official sourceMonitor - can change2026-10-10

At a glance

Right to a basic payment account
A consumer legally resident in the European Union has one

Regulation 15(3) of the European Union (Payment Accounts) Regulations 2016.

If you are not legally resident in the Union
No right under those Regulations, and the account is the bank's to refuse

Regulation 15(3) attaches the right to legal residence in the Union and nothing else replaces it.

Discrimination by nationality
Prohibited, for anyone legally resident in the Union applying for any payment account

Regulation 14(1), which reaches beyond the basic account.

What the bank must take
Documents from a government source, or a prescribed class of documents

Section 33(2)(a) of the 2010 Act. A foreign passport is a government source.

When it must be taken
Before the business relationship is established

Section 33(1)(a).

If you live in a high-risk third country
Six further measures, including source of funds and senior management approval

Section 38A(1), listing paragraphs (a) to (f).

Who names those countries
The European Commission, under article 9 of the Fourth Money Laundering Directive

The definition in section 24(1). The Commission's list itself was not read for this record.

Requirements

  • Documents the institution has reasonable grounds to rely on, government-issued or prescribed
  • For the basic account right: legal residence in the European Union

What applies to you

Nothing changes for a citizen of Panama

We have no rule recorded that treats your citizenship differently here, so the general rule above is the one that applies to you. That is an answer, not a gap.

What the law says

Text layer - verbatim verifiedEuropean Union (Payment Accounts) Regulations 2016 (S.I. No. 482 of 2016) · Regulation 14(1)
«14. (1) A relevant credit institution shall not discriminate against a consumer who is legally resident in the European Union (within the meaning of Article 2(2) of the Directive) by reason of his or her nationality, place of residence, or any other ground referred to in Article 21 of the Charter of Fundamental Rights of the European Union, when the consumer applies for or accesses a payment account.»
Read it at the source
About this source

The electronic Irish Statute Book: every Act of the Oireachtas since 1922 and every statutory instrument, each at a stable ELI address built from year, type and number. A full Act or instrument is served at the /print path; the /html path returns only the arrangement of sections. The site also carries a legislation directory page per Act listing every instrument made under it, which is the only published index of the orders that make up a scheme.

Standing:

Cannot be cited for: This site publishes Acts **as enacted** and statutory instruments **as made**, and nothing else. It is not the law in force and does not claim to be: the Immigration Act 2004 (Visas) Order 2014 has been amended more than twenty times and the text served at its address is the 2014 original, with no marker to say so. Section 819(4) of the Taxes Consolidation Act 1997 is served in words replaced in 2008. For an Act the Law Reform Commission has revised, the revised text is the one to read; for the Taxes Consolidation Act and for every statutory instrument there is no revised text anywhere, and the current wording has to be assembled from the amending instruments by hand. The directory page for an Act is reachable; the equivalent page for a statutory instrument returned an error when tried.

We re-read it every 60 days. More about this source

Text layer - verbatim verifiedEuropean Union (Payment Accounts) Regulations 2016 (S.I. No. 482 of 2016) · Regulation 15(3)
«(3) Subject to Regulation 16(2) and (4), a consumer who is legally resident in the European Union (within the meaning of Article 2(2) of the Directive) shall have the right to open and use a payment account with basic features without undue difficulty regardless of— ( a ) his or her place of residence, or ( b ) whether he or she— (i) has a fixed address, (ii) is an asylum seeker, or (iii) is a consumer who has not been granted a residence permit but whose expulsion is not possible for legal or practical reasons.»

The right is bounded by legal residence in the Union and then declared indifferent to everything else inside it, including having no fixed address.

Read it at the source
About this source

The electronic Irish Statute Book: every Act of the Oireachtas since 1922 and every statutory instrument, each at a stable ELI address built from year, type and number. A full Act or instrument is served at the /print path; the /html path returns only the arrangement of sections. The site also carries a legislation directory page per Act listing every instrument made under it, which is the only published index of the orders that make up a scheme.

Standing:

Cannot be cited for: This site publishes Acts **as enacted** and statutory instruments **as made**, and nothing else. It is not the law in force and does not claim to be: the Immigration Act 2004 (Visas) Order 2014 has been amended more than twenty times and the text served at its address is the 2014 original, with no marker to say so. Section 819(4) of the Taxes Consolidation Act 1997 is served in words replaced in 2008. For an Act the Law Reform Commission has revised, the revised text is the one to read; for the Taxes Consolidation Act and for every statutory instrument there is no revised text anywhere, and the current wording has to be assembled from the amending instruments by hand. The directory page for an Act is reachable; the equivalent page for a statutory instrument returned an error when tried.

We re-read it every 60 days. More about this source

Text layer - verbatim verifiedCriminal Justice (Money Laundering and Terrorist Financing) Act 2010 (No. 6 of 2010) · Section 33(1) · consolidated to 2025-08-01
«33 .— (1) A designated person shall apply the measures specified in F54 [ subsection (2) ] , in relation to a customer of the designated person— ( a ) prior to establishing a business relationship with the customer, ( b ) prior to carrying out an occasional transaction with, for or on behalf of the customer or assisting the customer to carry out an occasional transaction,»
Read it at the source
About this source

Administrative consolidations of Irish Acts, prepared by the Law Reform Commission under the Law Reform Commission Act 1975. Each revised Act prints the date it is updated to, the latest Act and statutory instrument considered in its preparation, and annotations after every section recording which instrument inserted, substituted or deleted each passage, with the commencement date and the commencing order.

Standing: Maintains the text in force

Cannot be cited for: The Commission states on every page that it assumes no responsibility and gives no guarantees as to accuracy or completeness; a revised Act is an administrative consolidation, not an official text, and where it differs from the Acts it consolidates the Acts prevail. Its revision date is a cut-off: an amendment commenced after it is not in the text. The editorial apparatus is inside the sentences - F-markers, square brackets and ellipses sit between words - so a quotation cannot be taken across one, and the annotations and editorial notes are the Commission's own writing rather than anything enacted. Coverage is partial: there is no revised text of the Taxes Consolidation Act 1997 or of the Aliens Act 1935, and the Commission revises Acts only, never statutory instruments.

We re-read it every 90 days. More about this source

Text layer - verbatim verifiedCriminal Justice (Money Laundering and Terrorist Financing) Act 2010 (No. 6 of 2010) · Section 33(2)(a) · consolidated to 2025-08-01
«(2) The measures that shall be applied F56 [ , in accordance with section 30B , ] by a designated person under subsection (1) are as follows: ( a ) identifying the customer, and verifying the customer’s identity on the basis of documents (whether or not in electronic form), or information, that the designated person has reasonable grounds to believe can be relied upon to confirm the identity of the customer, including— (i) documents from a government source (whether or not a State government source), F59 [ … ] F58 [ ( ia ) information from relevant trust services as specified in the Electronic Identification Regulation, or ] (ii) any prescribed class of documents, or any prescribed combination of classes of documents;»

Identity may be verified on documents the person has reasonable grounds to believe can be relied upon. The statute names a government source and prescribed classes as examples, not as an exhaustive list.

Read it at the source
About this source

Administrative consolidations of Irish Acts, prepared by the Law Reform Commission under the Law Reform Commission Act 1975. Each revised Act prints the date it is updated to, the latest Act and statutory instrument considered in its preparation, and annotations after every section recording which instrument inserted, substituted or deleted each passage, with the commencement date and the commencing order.

Standing: Maintains the text in force

Cannot be cited for: The Commission states on every page that it assumes no responsibility and gives no guarantees as to accuracy or completeness; a revised Act is an administrative consolidation, not an official text, and where it differs from the Acts it consolidates the Acts prevail. Its revision date is a cut-off: an amendment commenced after it is not in the text. The editorial apparatus is inside the sentences - F-markers, square brackets and ellipses sit between words - so a quotation cannot be taken across one, and the annotations and editorial notes are the Commission's own writing rather than anything enacted. Coverage is partial: there is no revised text of the Taxes Consolidation Act 1997 or of the Aliens Act 1935, and the Commission revises Acts only, never statutory instruments.

We re-read it every 90 days. More about this source

Text layer - verbatim verifiedCriminal Justice (Money Laundering and Terrorist Financing) Act 2010 (No. 6 of 2010) · Section 38A(1) · consolidated to 2025-08-01
«38A. — F86 [ (1) Subject to subsection (2) , a designated person shall apply the following measures to manage and mitigate the risk of money laundering and terrorist financing additional to those specified in this chapter, when dealing with a customer established or residing in a high-risk third country: ( a ) obtaining additional information on the customer and on the beneficial owner; ( b ) obtaining additional information on the intended nature of the business relationship;»
Read it at the source
About this source

Administrative consolidations of Irish Acts, prepared by the Law Reform Commission under the Law Reform Commission Act 1975. Each revised Act prints the date it is updated to, the latest Act and statutory instrument considered in its preparation, and annotations after every section recording which instrument inserted, substituted or deleted each passage, with the commencement date and the commencing order.

Standing: Maintains the text in force

Cannot be cited for: The Commission states on every page that it assumes no responsibility and gives no guarantees as to accuracy or completeness; a revised Act is an administrative consolidation, not an official text, and where it differs from the Acts it consolidates the Acts prevail. Its revision date is a cut-off: an amendment commenced after it is not in the text. The editorial apparatus is inside the sentences - F-markers, square brackets and ellipses sit between words - so a quotation cannot be taken across one, and the annotations and editorial notes are the Commission's own writing rather than anything enacted. Coverage is partial: there is no revised text of the Taxes Consolidation Act 1997 or of the Aliens Act 1935, and the Commission revises Acts only, never statutory instruments.

We re-read it every 90 days. More about this source

Text layer - verbatim verifiedCriminal Justice (Money Laundering and Terrorist Financing) Act 2010 (No. 6 of 2010) · Section 24(1) · consolidated to 2025-08-01
«"high-risk third country" means a jurisdiction identified by the European Commission in accordance with Article 9 of the Fourth Money Laundering Directive; ]»

The definition. Which states are in the category is not in Irish law at all, and moves when the Commission moves it.

Read it at the source
About this source

Administrative consolidations of Irish Acts, prepared by the Law Reform Commission under the Law Reform Commission Act 1975. Each revised Act prints the date it is updated to, the latest Act and statutory instrument considered in its preparation, and annotations after every section recording which instrument inserted, substituted or deleted each passage, with the commencement date and the commencing order.

Standing: Maintains the text in force

Cannot be cited for: The Commission states on every page that it assumes no responsibility and gives no guarantees as to accuracy or completeness; a revised Act is an administrative consolidation, not an official text, and where it differs from the Acts it consolidates the Acts prevail. Its revision date is a cut-off: an amendment commenced after it is not in the text. The editorial apparatus is inside the sentences - F-markers, square brackets and ellipses sit between words - so a quotation cannot be taken across one, and the annotations and editorial notes are the Commission's own writing rather than anything enacted. Coverage is partial: there is no revised text of the Taxes Consolidation Act 1997 or of the Aliens Act 1935, and the Commission revises Acts only, never statutory instruments.

We re-read it every 90 days. More about this source

Practical notes

No country is named on this record. The high-risk category is real and origin-dependent, but the Commission's list was not read: the consolidated text could not be retrieved from EUR-Lex on the day of writing, and an absence inferred from a failed request would be a fact about our access rather than about the law.

Section 33(8) is the sharp end: where a customer fails to provide what the section requires, the institution must not provide the service and must discontinue the relationship. That is a duty on the bank, not a discretion.

Sources2 · all accessed 2026-10-10
  • publishes
    European Union (Payment Accounts) Regulations 2016

    Irish Statute Book, Office of the Attorney General

    About this source

    The electronic Irish Statute Book: every Act of the Oireachtas since 1922 and every statutory instrument, each at a stable ELI address built from year, type and number. A full Act or instrument is served at the /print path; the /html path returns only the arrangement of sections. The site also carries a legislation directory page per Act listing every instrument made under it, which is the only published index of the orders that make up a scheme.

    Standing:

    Cannot be cited for: This site publishes Acts **as enacted** and statutory instruments **as made**, and nothing else. It is not the law in force and does not claim to be: the Immigration Act 2004 (Visas) Order 2014 has been amended more than twenty times and the text served at its address is the 2014 original, with no marker to say so. Section 819(4) of the Taxes Consolidation Act 1997 is served in words replaced in 2008. For an Act the Law Reform Commission has revised, the revised text is the one to read; for the Taxes Consolidation Act and for every statutory instrument there is no revised text anywhere, and the current wording has to be assembled from the amending instruments by hand. The directory page for an Act is reachable; the equivalent page for a statutory instrument returned an error when tried.

    We re-read it every 60 days. More about this source

  • consolidates
    Criminal Justice (Money Laundering and Terrorist Financing) Act 2010, revised

    Revised Acts, Law Reform Commission · consolidated to 2025-08-01

    About this source

    Administrative consolidations of Irish Acts, prepared by the Law Reform Commission under the Law Reform Commission Act 1975. Each revised Act prints the date it is updated to, the latest Act and statutory instrument considered in its preparation, and annotations after every section recording which instrument inserted, substituted or deleted each passage, with the commencement date and the commencing order.

    Standing: Maintains the text in force

    Cannot be cited for: The Commission states on every page that it assumes no responsibility and gives no guarantees as to accuracy or completeness; a revised Act is an administrative consolidation, not an official text, and where it differs from the Acts it consolidates the Acts prevail. Its revision date is a cut-off: an amendment commenced after it is not in the text. The editorial apparatus is inside the sentences - F-markers, square brackets and ellipses sit between words - so a quotation cannot be taken across one, and the annotations and editorial notes are the Commission's own writing rather than anything enacted. Coverage is partial: there is no revised text of the Taxes Consolidation Act 1997 or of the Aliens Act 1935, and the Commission revises Acts only, never statutory instruments.

    We re-read it every 90 days. More about this source