Former Nodus International Bank CEO Tomás Niembro Concha pleaded guilty to a scheme that siphoned at least $24.9 million from the bank and involved efforts to evade U.S. sanctions tied to Venezuela, a case that contributed to the bank’s collapse and triggered regulatory liquidation in 2023.
The former Chief Executive Officer of Nodus International Bank admitted his role in a multi-year fraud that moved money through sham investments and opaque loans to benefit himself and associates. Court filings show the scheme stretched across several years and fed directly into decisions that weakened the institution’s financial footing.
According to the filings, Niembro conspired with others to hide the true beneficiaries of certain investments and loans from both Nodus Bank’s board and its regulator. Those transactions, the papers say, violated Puerto Rican law and masked conflicts of interest involving Board Chairman Juan Ramirez.
“The defendant abused his position as CEO, turning the bank he managed into his own personal ATM and unlawfully transacting with a sanctioned individual,” said Assistant Attorney General A. Tysen Duva of the Justice Department’s Criminal Division. “The defendant’s crimes undermine the integrity of our financial system, threaten economic prosperity, and harm national security. The Criminal Division will investigate and prosecute fraudsters to protect financial markets and promote safety and prosperity for all Americans.”
From 2017 to 2023, Niembro, Ramirez and others directed Nodus Bank to invest roughly $11 million in a Miami-based lender so those funds could be re-loaned to the two men for their private benefit. Prosecutors say the investments were a front, built specifically to disguise what were effectively insider loans and to mislead the board and regulators about the bank’s exposure.
“This defendant used his position as CEO to siphon more than $24 million, hide conflicts of interest, and help drive the bank’s collapse,” said U.S. Attorney Jason A. Reding Quiñones for the Southern District of Florida. “The scheme also involved efforts to evade U.S. sanctions tied to Venezuela’s state-owned oil company, PDVSA. As a career prosecutor and former state trial judge, I’ve learned that following the money reveals the truth. Here, it exposed both fraud and sanctions violations. We will hold accountable anyone who abuses our financial system for personal gain.”
Separate transactions between January 2018 and September 2021 involved the bank’s purchase of at least 47 promissory notes totaling about $25.3 million from Nodus Finance, a Miami company owned by Niembro and Ramirez. Prosecutors allege those note sales funneled proceeds back to the owners, again hiding the true purpose from the bank’s board and the comptroller.
“Corporate titles don’t place anyone above the law,” said Ron Loecker, Special Agent in Charge, IRS Criminal Investigation, Florida Field Office. “Executive level fraud has real victims, and yesterday’s outcome is a step toward restoring accountability and confidence in the banking system. IRS Special Agents, alongside our partners, will keep bringing transparency to complex financial crimes and delivering results.”
In early March 2023, the Office of the Commissioner of Financial Institutions of Puerto Rico notified Nodus Bank that it would be placed into liquidation, citing the bank’s deteriorated condition. Investigators say Niembro and Ramirez also tried to patch the books by causing the bank to accept a loan portfolio from Nodus Finance to cover debts tied to the promissory notes.
Prosecutors further allege Niembro conspired to conduct prohibited financial transactions with an individual designated as a Specially Designated National by Treasury’s Office of Foreign Assets Control for providing material support to Petróleos de Venezuela, S.A. To satisfy a roughly $2.5 million loan the SDN’s company owed to Nodus before sanctions, the scheme included an OFAC-authorized foreclosure followed by a clandestine plan to sell the property back to the SDN for $4 million through a front company.
Niembro pleaded guilty to a two-count Information charging conspiracy to commit wire fraud and conspiracy to violate the International Emergency Economic Powers Act, with each count carrying a maximum of 20 years in prison. His sentencing is scheduled for June 8, and under the plea agreement he agreed to forfeit at least $16.9 million as the value of proceeds from the wire fraud conspiracy.
IRS Criminal Investigation led the probe with support from OCIF and the Treasury Executive Office for Asset Forfeiture, while trial work on the case is being handled by the Criminal Division’s Money Laundering, Narcotics and Forfeiture Section and by prosecutors in the Southern District of Florida. Named trial attorneys include Javier Urbina and Samir Paul for the Department of Justice and Assistant U.S. Attorney Felipe Plechac-Diaz for the Southern District of Florida.
The prosecution also ties into larger task force efforts aimed at disrupting transnational criminal finance and protecting the U.S. financial system. Those initiatives concentrate on removing criminal profit from the system, targeting financial facilitators, and pursuing both criminal prosecutions and asset recovery when financial institutions and their officers undermine legal and regulatory safeguards.
