Summary
Tomás Niembro Concha, 64, the former chief executive officer of Nodus International Bank, has been sentenced to 112 months in prison for his role in a scheme to fraudulently obtain at least $24.9 million from the Puerto Rican bank and conspire to evade U.S. sanctions against Venezuela.
Niembro, a Spanish and Venezuelan national, was also sentenced to three years of supervised release and ordered to forfeit more than $16.9 million, representing the value of proceeds he derived from the wire fraud conspiracy.
According to the U.S. Department of Justice, Niembro abused his position at Nodus Bank by concealing transactions that benefited himself and the bank’s chairman, Juan Ramirez. The conduct ultimately contributed to the bank’s failure and liquidation in 2023.
Key details of the case
| Detail | Information |
|---|---|
| Defendant | Tomás Niembro Concha |
| Age | 64 |
| Nationality | Spanish and Venezuelan |
| Former position | CEO, Nodus International Bank |
| Prison sentence | 112 months |
| Supervised release | 3 years |
| Fraudulent proceeds | At least $24.9 million |
| Forfeiture | More than $16.9 million |
| Guilty plea | March 19, 2026 |
| Bank | Nodus International Bank |
| Bank location | Puerto Rico |
| Main charges | Wire fraud conspiracy and IEEPA conspiracy |
| Sanctions authority | OFAC |
| Investigating agency | IRS Criminal Investigation |
How the Nodus Bank fraud scheme worked
According to court filings, Niembro conspired with others to divert money from Nodus Bank while concealing the transactions from other board members, bank executives and the Office of the Commissioner of Financial Institutions of Puerto Rico (OCIF).
The transactions allegedly benefited Niembro and Nodus Bank Board Chairman Juan Ramirez.
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From 2017 through 2023, Niembro, Ramirez and others caused Nodus Bank to invest $11 million in a Miami-based lender. The money was then loaned to Niembro and Ramirez for their personal benefit, according to the DOJ.
The defendants allegedly concealed the purpose of the transactions through sham investments.
$25.3 million in promissory notes
Between January 2018 and September 2021, Niembro and Ramirez allegedly caused Nodus Bank’s board and comptroller to approve the purchase of at least 47 promissory notes from Nodus Finance.
The notes were worth approximately $25.3 million.
Nodus Finance was a Miami-based company jointly owned by Niembro and Ramirez.
According to the DOJ, the defendants fraudulently induced the bank to purchase the notes so they could use the transaction proceeds for themselves.
The scheme involved concealing the connection between the bank’s investments and the personal interests of the bank’s senior executives.
Nodus Bank entered liquidation in 2023
The alleged transactions contributed to the financial problems that eventually led to Nodus Bank’s failure.
In early March 2023, OCIF notified Nodus Bank that it would be placed into liquidation.
The DOJ said Niembro and Ramirez then fraudulently caused Nodus Bank to accept a loan portfolio from Nodus Finance to pay down the debt associated with the 47 promissory notes.
The transactions were part of the broader scheme through which the defendants allegedly diverted bank funds for their own benefit.
Niembro also conspired to evade Venezuela sanctions
The case also involved an alleged scheme to circumvent U.S. sanctions against a Specially Designated National (SDN).
Between 2021 and 2023, Niembro allegedly conspired with others to conduct prohibited financial transactions with an individual designated by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC).
The individual had been designated for providing material support to Venezuela’s state-owned oil company, Petróleos de Venezuela, S.A. (PDVSA).
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Southampton property transaction
The sanctions-evasion scheme involved an outstanding loan of approximately $2.5 million owed to Nodus Bank by a company belonging to the sanctioned individual.
According to the DOJ, Niembro and the SDN arranged for Nodus Bank to foreclose on the individual’s home in Southampton, New York.
Nodus Bank obtained OFAC authorization for the foreclosure.
However, prosecutors said Niembro and the SDN separately reached a private agreement under which Nodus Bank would sell the property back to the SDN for $4 million through a front company.
The DOJ said the transaction was prohibited under U.S. sanctions and was not separately licensed by OFAC.
Niembro pleaded guilty to two federal charges
On March 19, 2026, Niembro pleaded guilty to a two-count information charging:
- Conspiracy to commit wire fraud
- Conspiracy to violate the International Emergency Economic Powers Act (IEEPA)
The guilty plea covered the conduct underlying the multimillion-dollar bank fraud and Venezuela sanctions-evasion scheme.
He was subsequently sentenced to 112 months in federal prison and three years of supervised release.
The court also ordered him to forfeit more than $16.9 million.
Agencies investigated the financial crime
The investigation was conducted by IRS Criminal Investigation (IRS-CI) with support from OCIF and the Treasury Executive Office for Asset Forfeiture (TEOAF).
The case was prosecuted by attorneys from the DOJ Criminal Division’s Money Laundering, Narcotics and Forfeiture Section (MNF) and the U.S. Attorney’s Office for the Southern District of Florida.
The DOJ said the case demonstrates cooperation between financial-crime investigators, Puerto Rican regulators and federal prosecutors in investigating complex fraud and sanctions-evasion conduct.
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Officials highlight financial-system risks
Assistant Attorney General A. Tysen Duva of the DOJ Criminal Division said Niembro abused his position at Nodus Bank for personal enrichment and to evade sanctions against a designated individual.
IRS-CI Florida Acting Special Agent in Charge Charles Miller said the case involved both financial fraud and sanctions evasion.
The DOJ said the investigation demonstrates the role of interagency cooperation in identifying financial crimes that affect the integrity of the U.S. financial system.
Homeland Security Task Force involvement
The DOJ said the prosecution is part of the Homeland Security Task Force (HSTF) initiative established under Executive Order 14159.
The HSTF is described by the DOJ as a whole-of-government partnership focused on investigating and prosecuting criminal cartels, foreign gangs, transnational criminal organizations and human smuggling and trafficking networks.
HSTF Miami includes agents and officers from IRS Criminal Investigation, with the prosecution in this case led by the MNF Bank Integrity Unit and the U.S. Attorney’s Office for the Southern District of Florida.
Why the case matters for financial crime enforcement
The case combines several financial-crime risks involving a regulated financial institution:
- Bank insider abuse
- Wire fraud
- Related-party transactions
- Concealment of beneficial interests
- Sham investments
- Use of front companies
- Sanctions evasion
- Cross-border financial activity
- Asset forfeiture
The DOJ’s MNF Bank Integrity Unit investigates and prosecutes cases involving banks and other financial institutions, including officers, managers and employees whose conduct threatens the integrity of an institution or the wider financial system.
To read the original order please visit Department of Justice (DOJ) website