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Paraguay: Promissory Note Scheme Continues Despite Prior Crackdowns

January 28, 2026·Isaac

On January 25, 2026, Paraguayan lawyer Diana Vargas warned that the so called “mafia de los pagarés” remains active across the country, despite earlier efforts to dismantle it. Her comments were reported by ADN Digital and refer back to previous Senate involvement and the dismissal of judges and judicial officials linked to similar cases.

Vargas said the scheme continues to exploit vulnerable individuals, including public officials, through usurious lending disguised as ordinary commercial transactions. According to her account, the persistence of these practices reflects fragmented institutional responsibilities and weak oversight and notification mechanisms, rather than isolated judicial failures.

Some elements of the situation are clear. Vargas has publicly stated that the scheme is still operating. ADN Digital has reported her warnings. There have also been prior legislative and judicial actions related to earlier phases of the issue.

Other aspects remain reported rather than confirmed. Vargas stated that the scheme continues to function nationwide, systematically exploiting institutional gaps. She also asserted that the mechanism is used for money laundering purposes, though no enforcement findings were cited in the material provided.

Vargas described how the scheme allegedly works. Simulated sales, often presented as appliance purchases, are used to conceal high interest loans. Victims are reportedly persuaded to sign incomplete promissory notes that lack dates or fixed amounts, along with authorizations allowing direct salary deductions. These promissory notes then circulate and are enforced later, with repayment demands that can far exceed the original loan values. In reported examples, debts rose from 5 million to 70 million guaraníes. Victims are said to receive no formal notification, limiting their ability to challenge the authenticity of signatures or the validity of the claims.

From an AML and CTF perspective, the alleged use of negotiable instruments to obscure the origin and value of loans raises concerns. The structure also shows indicators associated with trade based money laundering and payroll linked financial abuse.

Vargas linked the longevity of the scheme to broader institutional exposure. She pointed to a lack of coordinated controls across public bodies, beyond the judiciary alone. She also stated that meetings were held with the Dirección Nacional de Ingresos Tributarios to inform tax authorities about the described operations. No public enforcement response from DNIT is reflected in the provided material.

These dynamics matter for AML risk. Public sector exposure can increase corruption and laundering vulnerabilities, while weak inter agency coordination allows financial crime schemes to persist over time.

Vargas also alleged the involvement of intermediaries, associations, guilds, and large formally constituted companies. She said the participation of such entities contributes to the scheme’s resilience and its distance from eradication. No companies were named in the reporting, and these claims remain unverified in this chat.

If substantiated, this would point to potential misuse of corporate structures for laundering and debt enforcement, and elevated customer and counterparty risk for financial institutions operating in the country.

Looking ahead, attention will be on whether DNIT, prosecutors, or judicial authorities issue public statements or take visible action following these warnings. Further reporting may also clarify whether specific companies or intermediaries are identified, whether legislative proposals addressing promissory note enforcement emerge, and whether financial sector guidance is issued on payroll linked debt schemes.

Sources

ADN Digital reporting.

Public statements by Abogada Diana Vargas, as reported.