Not Justice, but federal persecution.
The question is: Did the company repatriate the money. It didn’t sound like it to me. Thus no taxes owed. I think that is why he was after a loan. Because the money wasn’t repatriated, but it could be used for a loan. I am sure he didn’t know about the partner embezzling from him or he would have done something about it. The accountant was cooking the books to hide the embezzling. So Manafort sought the loan with cooked books. He didn’t get the loan based on those books though. The bank was trying to ingratiate itself and the manager himself to Manafort for future possibilities.