United States securities and exchange commission logo
August 28, 2023
Ram n Mart nez
Ambassador of Panama
PANAMA REPUBLIC OF
Embassy of Panama
2862 McGill Terrace, N.W.
Washington, D.C. 20008
Re: PANAMA REPUBLIC OF
Schedule B filed
July 31, 2023
File No. 333-273534
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Form 18-K filed on
September 30, 2022 and amended on November 21, 2022,
March 28, 2023,
July 17, 2023 and July 31, 2023
File No. 333-07558
Dear Ram n Mart nez:
We have reviewed your registration statement and have the
following comments. In
some of our comments, we may ask you to provide us with information so
we may better
understand your disclosure.
Please respond to this letter by amending your registration
statement and providing the
requested information. If you do not believe our comments apply to your
facts and
circumstances or do not believe an amendment is appropriate, please tell
us why in your
response.
After reviewing any amendment to your registration statement and
the information you
provide in response to these comments, we may have additional comments.
Schedule B
General
1. To the extent possible,
please update all statistics and information in the registration
statement and the Form
18-K to provide the most recent data. We note, for example, that
Tables 12, 13, 14 and
15 in Exhibit 99.0 to your most recent Form 18-K reference your
2021 data as
preliminary.
2. We note recent news
reports of protests for various reasons, including water and
electricity issues,
racial and economic inequities, and immigration policies. These matters
Ram n Mart nez
PANAMA REPUBLIC OF
August 28, 2023
Page 2
appear to supplement the information disclosed in the "Recent
Developments" sections of
your recent Form 18-K amendments. Please either include a recent
developments section
in your Schedule B or revise your Form 18-K, as necessary, to reflect
the material nature
of these matters and those referenced in our below comments.
3. We note news reports of increasing issues with migration and crime. We
also note news
reports of Guyana possibly pursuing arbitration in connection with
rice exports. Please
revise your disclosure to include discussion of these issues, to the
extent they are material.
4. Please provide any material updates to the disclosure in your Form
18-K/a regarding
the impact that the recent drought has had on transport and the Panama
Canal, including
any shipping restrictions. To the extent material, please include
discussion of any risks to
Panama's economy and the governmental response.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.
Please contact Corey Jennings, Special Counsel, at (202) 551-3258 or
Michael Coco,
Chief, at (202) 551-3253 with any other questions.
Sincerely,
FirstName LastNameRam n Mart nez
Division of
Corporation Finance
Comapany NamePANAMA REPUBLIC OF
Office of
International Corporate
August 28, 2023 Page 2 Finance
FirstName LastName