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The Panama Papers and “Data for Sale”:
Caveat Emptor

Anyone claiming to have access to the entire Panama Papers database and offering traces for payment should be viewed with skepticism.

By Michele M. Palmer and Richard L. Palmer

April 2016 | Updated October 12, 2020 | More Articles


Last month, shortly after the 2015 leak of the Panama Papers was made public, we began seeing offers to sell alleged traces of persons and companies mentioned in the 11.5 million confidential documents in the stolen database.

It is not surprising that shady operators would try to cash in on this sensational development, and our advice to anyone considering the purchase of alleged Panama Papers data is caveat emptor (“let the buyer beware”). We believe that, after you read this article, you will agree that caution is justified.


The Panama Papers data was passed by an unknown (or unidentified) source to the Munich-based Süddeutsche Zeitung (“South German Newspaper”). That company enlisted the help of the International Consortium of Investigative Journalists (ICIJ), which distributed the documents for investigation and analysis to some 400 journalists at 107 media organizations in 76 countries.

The Panama Papers reportedly contain information about more than 214,000 offshore companies – including the identities of company shareholders and directors – compiled by the Panamanian law firm and corporate service provider Mossack Fonseca. The first news reports based on the papers, and 149 of the documents themselves, were published on April 3, 2016.

The documents released thus far identified several current and former heads of state and government officials, from more than 40 countries, in addition to close relatives and associates of those officials, many of whom apparently used certain corporate investments to shield assets from public scrutiny.

More to Come

More than 100 media outlets have cooperated on this project, but only the ICIJ and Süddeutsche Zeitung have had access to the entire database, and neither has published or granted access to the complete database or the abridged version that will be published.

Shortly after the Panama Papers' existence was made public, the ICIJ asserted that it would not “disclose the whole database,” and the publication date was subject to speculation.

However, on April 26, 2016, the ICIJ announced:

“On May 9 ICIJ will publish what will likely be the largest-ever release of information about secret offshore companies and the people behind them, based on data from the Panama Papers investigation. The searchable database will include information about more than 200,000 companies, trusts, foundations and funds incorporated in 21 tax havens, from Hong Kong to Nevada in the United States.”

It is still unclear whether the “more than 200,000” entities in the database to be released on May 9 will include all 214,000 companies. We anticipate that an incomplete release would give rise to a cottage industry built around offers of vague traces of the “entire Panama Papers,” the provenance of which could not be confirmed.

The tight security with which the ICIJ has managed the database, combined with the ICIJ’s plans to make public the names of thousands of clients, shareholders and owners of offshore companies, suggests that (a) purported vendors of Panama Papers data don’t have what they claim to have, and (b) on May 9 much of what they purport to sell will likely be readily available, free of charge.

Questionable Claims

As for the legitimacy of would-be sellers of Panama Papers data, our review of websites that claim to provide links to Panama Papers archives strongly suggest that those sites do not deliver on what they promise.

For example, the Reporter Times purports to offer the “Panama Papers: ICIJ Offshore Leaks Database Documents Download (Complete).” The latest date on any of these files is March 23, 2014; unfortunately, the first of the leaked data was received in early 2015. Further, these listed files do not include Panama Papers material; rather, at the bottom of that webpage is a list of interesting links to articles and partial lists of persons and companies named in the Panama Papers, but we see nothing there that is not available elsewhere on the web.

Also, we have been approached by several investigators who claim to be able to offer traces of the Panama Papers for payment. Some attribute their success in uncovering their data to their uniquely superior search skills, while others claim that what they have to sell was found only on the “darknet.” (A darknet is an overlay network that can be accessed only with specific software, configurations or authorization, often using non-standard communications protocols and ports.)

Both claims have serious flaws.

According to the ICIJ, if the data is genuine, it was probably acquired via access to one of the partial or incomplete databases to be used only by authorized journalists or researchers – in other words, it was illegally obtained. Thus, the data would be difficult, if not impossible, to use in a legal setting, and the eventual client would need to know that the information had “weaknesses,” to put it mildly, in terms of sourcing.

Further, a senior ICIJ official stated to us very recently that the ICIJ staff is still going through Panama Papers files that have not yet been processed. As a result, the main database is not complete and will not be totally complete even when it is released May 9. Rather, the ICIJ staff will be updating the official ICIJ website for months to come.

Thus, anyone claiming to have access to the entire Panama Papers database and offering traces for payment should be viewed with healthy skepticism. By definition, their offered products would not be a complete trace, and the problems with provenance could be a legal issue.

Broad Availability

It should be emphasized that, when the database is released as expected on May 9, it will be available to everyone, but it will not be a complete list of the documents in the actual main database. It should be easily accessible, as was the case in previously published archives from the ICIJ, such as the Swiss Leaks data and the main primary archive.

Therefore, we suggest that you wait for the authentic information. Surely, it will be worth the wait; after all, these are documents and information that will be difficult, if not impossible, to refute, and provenance should not be an issue.

In the meantime, for a taste of what may be to come, there are interesting but partial lists of Panama Papers information at the following links. Happy reading!



To discuss a corporate intelligence or financial investigation matter, or to learn more about Cachet International’s investigative resources in your jurisdiction, contact Michele Palmer by email or at 602-899-3993.


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