National Advisors Corporation — Investigation Profile
National Advisors Corporation (NAC) is a licensed securities house in Panama, regulated by the Superintendence of the Stock Market (SMV). NAC acted as the principal intermediary between Atlas Bank and its clients — facilitating client onboarding, coordinating fund transfers, and serving as the primary communication channel. When the SMV intervened in September 2023, audits revealed a catastrophic shortfall: $43.3 million belonging to Atlas Bank depositors was missing from NAC's custody.
Corporate Information
- Business Name
- National Advisors Corporation
- Resolution Number (CNV)
- CNV-084-01
- Start of Operations
- May 19, 1998
- Regulated By
- Superintendence of the Stock Market (SMV) — Panama
- Economic Group
- Platinum Overseas Holding
- Phone / Fax
- 398-9001 / Fax: 398-9008
- Website
- www.nationaladvisors.com.pa
- Physical Address
- Ave. Isaac Hanono Missri, PH Oceania Business Plaza, Tower 1000, 33rd Floor, Suite 33D
Leadership & Organization
| Role | Name |
|---|---|
| President | Guy De Puy Morales |
| CEO | Emiro Efrain Rodriguez Quentero |
| Treasurer | David Alexander Montenegro De Gracia |
| Legal Representative & Director | Eduardo Jaramillo Saraceni |
| Independent Director | Jacqueline Palmer Sousa De Wood |
| Independent Director | Magdalena Ortega De Gracia |
| Director | Kathia Vanessa Velasquez Cortes |
Auditor Firm
YAJAIRA MORALES DE MESA
Resident Agent
Aleman, Herrera & Moreno
Former Directors
Rosa Rodriguez
12.03.2020 – 13.05.2022
Roberto Caceres
05.05.2017 – 12.03.2020
Roberto Silva
05.05.2017 – 12.03.2020
Marco Rosalli
05.05.2017 – 12.03.2020
Role in the Atlas Bank Collapse
Client Introduction & Onboarding
NAC introduced clients to Atlas Bank, facilitating account opening and establishing the banking relationships on which clients depended. Clients relied entirely on NAC's regulatory standing and stated expertise when entering into their relationship with Atlas Bank. This gatekeeping role placed NAC in a position of significant trust and fiduciary responsibility.
Transaction Facilitation
NAC's role extended well beyond advisory services. The firm actively coordinated transfers of client funds into Atlas Bank, assisted with deposits, investments, and account movements. NAC was not a passive broker — it was operationally involved in the handling and placement of client assets, making it directly implicated in the chain of custody failures that led to the $43.3M loss.
Controlled Communication
Communication between clients and Atlas Bank was routinely channelled through NAC, deliberately limiting direct client oversight and creating an opaque intermediary layer. This architecture increased clients' dependence on NAC for information, reduced their ability to independently verify the status of their assets, and amplified the harm caused when NAC's representations ultimately proved false.
The $43.3 Million Loss
When the SMV intervened on September 7, 2023 (Resolution SMV-354), regulatory audits revealed that NAC had falsely claimed 93% of its client assets were held at external custodians — specifically RBC Direct Investing. In reality, insufficient assets were found. The $19M capital injection made by Atlas Financial Technology Corp in 2022 — routed via US accounts through NAC into Atlas Bank — could not be recovered. When Atlas Financial Technology demanded the return of $19M in July 2023, NAC was unable to produce the funds, triggering the fatal undercapitalisation of the bank.
$27.4M
Cash frozen at NAC
$15.9M
Securities at NAC
$43.3M
Total client loss
$19M
Unrecoverable injection
Key Events Timeline
- Jul 2023Atlas Financial Technology demands return of $19M from NAC — funds cannot be produced
- Sep 7, 2023SMV intervenes National Advisors Corporation via Resolution SMV-354
- Sep 15, 2023SBP seizes administrative control of Atlas Bank (Resolution SBP-BAN-R-2023-01296)
- Feb 29, 2024Compulsory liquidation of Atlas Bank ordered (Resolution SBP-BAN-R-2024-00093)
Legal & Regulatory Implications
Duty of Due Diligence
As a licensed intermediary, NAC had an affirmative regulatory duty to conduct thorough due diligence on Atlas Bank's financial soundness and governance before introducing clients. Evidence suggests this duty was not discharged, exposing clients to risks that a reasonably diligent regulated firm should have identified and disclosed.
Duty to Act in the Client's Best Interest
NAC's mandate required it to place client interests above its own commercial relationships. By channelling client funds into an undercapitalised institution without adequate disclosure of the risks — or without independently verifying the safety of those assets — NAC appears to have subordinated client welfare to its institutional relationship with Atlas Bank.
Potential Misrepresentation
NAC presented Atlas Bank as a secure and legitimate banking partner to its clients without apparent independent verification of the bank's asset quality or governance integrity. Representations made to clients about the safety of their deposits may constitute actionable misrepresentation if those representations were made without a reasonable basis.
Potential Joint Liability
Given NAC's active operational role in onboarding clients, facilitating fund transfers, and serving as the communication conduit, it may bear joint and several liability alongside Atlas Bank's shareholders and directors for losses suffered by clients. Legal proceedings may pursue NAC's institutional liability and the personal liability of its senior officers.
Critical Records Held by NAC
NAC is likely in possession of essential documentary evidence: client communications, transfer instructions, internal compliance records, and correspondence with Atlas Bank. These records are critical to tracing fund movements, establishing the chain of responsibility, and supporting both criminal investigations and civil recovery actions. Affected clients and their counsel should formally request preservation and disclosure of these records.
Do You Have Additional Information?
If you have direct knowledge, documents, or communications involving National Advisors Corporation, Guy De Puy Morales, Emiro Efrain Rodriguez Quentero, or any connected entities, please share that information with us securely. Every piece of evidence strengthens the case for recovery.
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