Operation Pandora: $36 Million in Illegitimate Tax Credits Were Located at BAC International Bank (Panamá) 

DGI identified via an internal audit that $36.01 million of the $42.4 million in tax credits used by BAC International Bank (Panamá) between 2022 and 2025 were illegitimate.  These credits were allegedly created and sold to the bank by an organized criminal network that manipulated the DGI’s E-Tax platform, leading to criminal charges under Operation Pandora. 

BAC successfully completed its acquisition of a majority stake in Multi Financial Group (MFG)—the parent company of Multibank—and fully integrated the two entities into a single institution in Panama.  Following the regulatory approval from the Superintendency of Banks of Panama, the operational, technological, and commercial merger was officially completed. This consolidation positioned BAC Panama as the second-largest bank in the country’s market, boasting combined assets exceeding US$45 billion and a loan portfolio over US$32 billion. 

An internal audit by the General Directorate of Revenue (DGI) concludes that $36.01 million of the $42.4 million in tax credits used by BAC International Bank (Panama) to offset tax obligations between 2022 and 2025 correspond to operations that it considers improper and illegitimate.  The investigation specifically analyzed the adjustments identified with the number 394 (Compensation-Assignment) applied in favor of BAC during a period of three years.

‘Final Validation was Solely the Responsibility of the DGI’: BAC Gives its Version of the Tax Credit Case

The investigation by the Public Prosecutor’s Office and an internal audit by the General Directorate of Revenue (DGI) maintain that the network allegedly manipulated the e-Tax 2.0 system to generate non-existent tax credits, which were subsequently transferred and used by different legal entities to offset tax obligations.  What is the bank’s position regarding this finding, and how does it explain that such a significant volume of loans subsequently questioned by the DGI passed its due diligence and control processes?

BAC International Bank (Panamá) maintains that it acted strictly as a “good faith purchaser” (adquirente de buena fe) regarding the fraudulent tax credits uncovered in the “Operation Pandora” investigation. A technical audit by Panama’s General Directorate of Revenue (DGI) revealed that $36.01 million of the $42.4 million in tax credits used by BAC to offset its obligations between 2022 and 2025 were illegitimate.  The bank’s official position and its explanation for how these transactions cleared internal controls center on several key arguments:

Official Position of BAC Panama

• Good Faith Acquisition: BAC strongly asserts that it never received state money. Instead, it purchased existing tax credits from third parties on the open market—a standard commercial practice—intending to use them to settle its own tax liabilities.

• Systemic Reliance & Trust: The bank emphasizes a “breach of legitimate trust” (afectación a la legítima confianza). It states that the credits were already officially registered and visible as valid, certified assets within the DGI’s own e-Tax 2.0 digital platform.

• Proactive Collaboration: BAC explicitly rejects allegations of wrongdoing, stating it did not create the credits or manipulate government platforms. The bank maintains it is fully cooperating with the Public Ministry’s investigation.

How the Bank Explains the Due Diligence Loophole

BAC explains that the fraudulent credits passed its internal due diligence processes due to the unique nature of the institutional fraud:

• Internal DGI Manipulation: The bank points out that the fraud originated inside the government. Current and former DGI officials allegedly manipulated the e-Tax system internally to generate and validate entirely fabricated tax credits.

• Limitations of Bank Controls: BAC ran standard legal, fiscal, accounting, compliance, and contractual reviews before purchasing the credits. However, because the ultimate authority to validate and issue these credits rested solely with the DGI, the bank’s due diligence showed the assets as officially verified and clean.

Triggering of Internal Alerts: BAC contends that its internal control mechanisms were not a total failure. The bank asserts that its own internal compliance audits eventually detected anomalies in the transactions, which prompted them to proactively alert Panama’s regulatory authorities.