RAISE COUNTRY RISK ON THE REPUBLIC OF PANAMA ( AND KEEP IT THERE)

If you follow litigation in Latin America, you know that the trial judge dismissed all the charges against twenty eight defendant in the PANAMA PAPERS case, including those pending against the surviving owner of MOSSACK & FONSECA, the infamous corporate service firm responsible for facilitating many of the world's most corrupt PEPs seeking to conceal bribes and kickbacks from the citizens of their countries.

The laughable grounds cited by the Court in Panama, that the Chain of Custody in the evidence seized at the M & F offices by the authorities had been broken, and therefore, it was not admissible, are a cruel legal joke being played on the compliance world. Panama's utterly corrupt judicial system has failed in its most significant case of the decade. Compliance officers now have no choice but to raise Country Risk on that nation to the highest level, which means no wire transfers to or from its banks over $2000, or any new clients onboarded during Customer identification Procedure, if you are truly operating a risk-based compliance program at an American financial institution or broker-dealer.

Anyone who declines to red-line Panama, for their clients and customers seeking to place investments could themselves end up in litigation, when the client suffers a loss, and finds out that Panama is just too high risk to do business in. This is definitely willful blindness territory. Govern yourselves accordingly.