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Banking Law Keyed to Malloy, 4th Ed.
Republic of Panama v. Republic National Bank of New York
Citation:
681 F. Supp. 1066 (1988)Facts
In February 1988, Panama experienced political upheaval when President Eric Arturo Delvalle attempted to dismiss General Manuel Noriega as Commander of the Panamanian Defense Forces. Noriega refused to step down and allegedly orchestrated Delvalle’s removal from office by vote of the National Assembly. The Cabinet Council then named Manuel Solis Palma as “Minister in Charge of the Presidency.” The United States government recognized only Delvalle as the lawful president of Panama. On March 1, 1988, Delvalle issued a proclamation declaring the Noriega regime illegitimate, and Ambassador Sosa notified U.S. banks that no debits should be made against Panama’s accounts without his authorization. On March 2, the Acting Secretary of State officially certified that Ambassador Sosa was the sole person authorized to control property held for Panama in U.S. banks. Banco Nacional de Panama and representatives of the Palma government sought to intervene, claiming a property interest in the funds.
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