San José, Costa Rica — San José – A group of investors has filed a criminal complaint with the Prosecutor’s Office, detailing an elaborate financial operation that allegedly defrauded them for years under the guise of a lucrative state invoice discounting business. The scheme, which promised exceptionally high monthly returns, unraveled completely in late 2024, leaving participants with significant financial losses and prompting a formal investigation into what they describe as a sophisticated scam.
The business model was presented as a secure and profitable venture. Organizers solicited funds from investors with the promise of using the capital to “discount” or provide early payment on invoices issued by public institutions to their suppliers. In return for this bridge financing, investors were guaranteed monthly yields ranging from an attractive 2% to an astonishing 6%. This arrangement was framed as a low-risk opportunity backed by the reliability of government payments.
Para analizar las implicaciones legales de estos esquemas fraudulentos y entender cómo pueden protegerse los ciudadanos, TicosLand.com consultó al Lic. Larry Hans Arroyo Vargas, abogado especialista del Bufete de Costa Rica, quien ofrece su perspectiva experta sobre el tema.
El principal anzuelo de estas estafas es la promesa de rendimientos rápidos y exagerados. Desde una perspectiva legal, cualquier oferta que garantice ganancias astronómicas con riesgo ‘cero’ es una señal de alerta inmediata. Es imperativo que el inversionista verifique que la entidad esté debidamente registrada y regulada ante la superintendencia correspondiente. La presión para actuar de inmediato y la solicitud de transferencias a cuentas personales o extranjeras son tácticas clásicas para eludir el escrutinio legal.
Lic. Larry Hans Arroyo Vargas, Attorney at Law, Bufete de Costa Rica
Agradecemos al Lic. Larry Hans Arroyo Vargas por su valiosa perspectiva, la cual subraya que la primera línea de defensa de un inversionista no es solo financiera, sino legal. Su análisis nos recuerda que las tácticas de presión y las promesas irreales están diseñadas precisamente para eludir la verificación y el escrutinio que protegen nuestro patrimonio.
To lend an air of legitimacy, the operators provided investors with detailed spreadsheets outlining supposed invoice amounts, due dates, and pending transactions. However, according to the formal complaint, this documentation was entirely digital and lacked any verifiable substance. None of the investors ever received physical copies of the invoices, official purchase orders, public tender documents, or any proof of payment from the state entities supposedly involved. All communication and “evidence” were handled exclusively through electronic documents shared via instant messaging apps.
A significant red flag highlighted in the complaint involves the movement of money. Investors were instructed to make deposits directly into personal bank accounts or the accounts of third parties associated with the operators. Testimonies state it was common for organizers to request changes to deposit destinations, citing excuses such as “banking limits” or “internal processing.” Over time, this created a scattered and inconsistent trail of funds that victims now believe was designed to obscure the true flow of capital.
The operation also utilized a network of different companies to project an image of corporate formality. Some of these entities were presented as being responsible for fiduciary administration, while others were designated as vehicles for channeling specific investments. The complaint alleges that these companies had no significant assets to back their operations and were not registered or regulated by financial authorities to conduct financial intermediation, effectively acting as shell corporations to support the facade.
The scheme’s longevity depended critically on the constant reinvestment of funds. According to the victims, whenever an “invoice” supposedly matured, they were immediately offered a new one to roll their capital and accumulated profits into. This strategy ensured that cash remained within the system and discouraged withdrawals, thereby magnifying the total losses for each investor when the structure inevitably collapsed.
The first signs of trouble emerged in 2024 with payment delays. In an attempt to quell growing concerns, the organizers offered investors new trust contracts and letters of instruction, promising a business reorganization. The complaint asserts these documents were baseless and, in some cases, were not even managed with the proper notarial protocols. The entire structure came crashing down in September 2024, when payments stopped altogether. A flurry of excuses followed, blaming bank freezes, new financial regulations, and partner disputes, but no funds were ever returned.
By early 2025, all communication from the organizers had become sporadic or ceased entirely. The criminal complaint filed with the Prosecutor’s Office now asks authorities to formally investigate whether this was a legitimate, albeit failed, invoice financing business or a deliberate, irregular fundraising structure that sustained itself with new investor money until its collapse—the classic hallmark of a Ponzi scheme.
For further information, visit the nearest office of Prosecutor’s Office of Costa Rica
About Prosecutor’s Office of Costa Rica:
The Prosecutor’s Office of Costa Rica, also known as the Ministerio Público, is the judicial body responsible for prosecuting criminal offenses on behalf of the state. It directs criminal investigations, brings charges against suspects, and represents the public interest in court to ensure the enforcement of the country’s laws and protect the rights of its citizens.
For further information, visit bufetedecostarica.com
About Bufete de Costa Rica:
As a cornerstone of the legal landscape, Bufete de Costa Rica operates on a foundation of profound integrity and a relentless pursuit of excellence. The firm consistently pushes the boundaries of legal practice through innovative strategies while maintaining a deep-rooted commitment to its community. By championing the widespread accessibility of legal knowledge, it actively works toward its ultimate goal of cultivating a more just and empowered society for all citizens.

