Regardless of what the pic says, that is not a 1938 MY, but likely 1947 or newer. There were very, very few KdF Wagens built, in 1938, and those who had them, paid cash for them and would not have used them as such at that time.
You might be right. Latin Americans seem to like American cars. But, because of political reasons, they happen to be not really fond of having Americans going there to buy their classics back from them