Fraud and Economic Crimes

Criminal Complaint No. 202200053278 concerns allegations by Lisa, S.A. that Juan Luis Bosch Gutiérrez, acting personally and as general agent of Villamorey, S.A., diverted multimillion-dollar dividends belonging to Lisa and concealed the company’s financial records to avoid accountability. Filed on July 27, 2022, the complaint asserts that Bosch unlawfully retained Lisa’s 33.3% share of Villamorey’s dividends, failed to comply with judicial deposit obligations established by the Eleventh Civil Court—including orders such as Auto No. 1624-08 and the enforceable Auto No. 2277-2018—and ultimately misappropriated sums that exceed $40 million. Lisa alleges that these acts formed part of a long-standing and deliberate scheme of corporate opacity in which Villamorey suppressed accounting books, falsified or destroyed records, and denied Lisa access to the financial information to which it is legally entitled as a shareholder.

The complaint maintains that Bosch’s and Villamorey’s conduct constitutes the crimes of fraud (Articles 220–221 of the Criminal Code), financial crimes (Articles 244–246), money-laundering predicate behavior (Article 254), and falsification or destruction of accounting documents (Articles 370–371). On September 9, 2022, the Public Ministry issued Resolution No. 2186-22, formally admitting the complaint and recognizing Lisa as the legitimate victim, thereby triggering a criminal investigation. As part of the prosecutorial actions that followed, the authorities issued a sequence of measures to obtain evidence: Resolution No. 2119-22 ordering banks to disclose financial products held by Bosch and Villamorey; multiple December 2022 directives to G&T Continental requiring production of accounts, transfers, and due-diligence files; and Official Notice No. 2463-2023, requesting judicial confirmation of Bosch’s compliance in a related civil accounting case. Together, these steps open a full investigation into whether Bosch and Villamorey committed economic crimes by diverting Lisa’s assets, concealing financial information, and violating obligations imposed by Panamanian law.