What about first opening the LLC with yourself as an individual as sole member, then opening banking for the LLC. After banking is established change ownership to Panama corp of which you are also owner. What I read these strict rules regarding offshore corps are imposed onto banks, they just want to protect their own liability and avoid penalties, so If they dont know and since u are also owner of panama corp it is the same person(you) managing the bank account. I dont know if this is legal and dont advocate but its just an idea maybe others can comment on this. I think︀ maybe you need to file something with IRS regarding change of member of LLC.