On March 20, 2026, the U.S. Department of Justice announced that Tomas Niembro Concha, the former Chief Executive Officer of Puerto Rico-based Nodus International Bank, pleaded guilty in connection with his role a scheme in which he fraudulently obtained at least $24.9 million from the bank and conspired to evade U.S. sanctions on Venezuela. According to the DOJ, Niembro pleaded guilty to a two-count information that charged him with conspiracy to commit wire fraud and conspiracy to violate the International Emergency Economic Powers Act (“IEEPA”). According to the plea agreement, Niembro also agreed to forfeit at least $16.9 million, which represents the value of proceeds derived from the fraudulent scheme. He is currently scheduled to be sentenced in the Southern District of Florida on June 8, 2026.
According to court documents, Niembro, a resident of Miami who has co-owned Nodus with Juan Ramirez since approximately May 2017, conspired with Ramirez and others to siphon money from the bank for their personal gain, which ultimately caused the bank to fail in 2023. According to the Factual Proffer offered in support of the guilty plea, between 2017 and 2023, Niembro worked with Ramirez, who served as Nodus’s Chairman of the Board, and others to purchase $11 million worth of “certificates of investment” from a Miami-based lender so that the funds could be loaned to Niembro and Ramirez for their personal use. According to federal prosecutors, they also caused Nodus to purchase at least 47 promissory notes worth approximately $25.3 million from a Miami-based company that Niembro and Ramiez jointly owned, so that they could use the proceeds for themselves. The co-conspirators allegedly took steps to conceal from Nodus’s other board members and executives that these investments were intended for Niembro’s and Ramirez’s personal use. As part of his plea, Niembro admitted that the scheme was devised to evade a Puerto Rican law that prohibits international banks from issuing loans to shareholders, executives, or employees without written approval from the Puerto Rican Office of the Commissioner of Financial Institutions (“OCFI”).
According to federal prosecutors, between 2021 and 2023, Niembro also conspired with others to provide material support to an unnamed individual (“designee”) who was subject to Venezuela sanctions in the United States, in violation of the IEEPA. Niembro allegedly caused Nodus to foreclose on a NY-based home that was owned by the designee to satisfy an outstanding loan worth approximately $2.5 million that he obtained prior to his designation – a transaction that, according to the DOJ, was authorized by Office of Foreign Assets Control. However, federal prosecutors allege that Niembro reached a “private” agreement with the designee that caused Nodus to sell the property back to him for $4 million using a front company – a transaction that was never approved by OFAC and was strictly prohibited by U.S. sanctions.
Niembro is not the first scheme participant to reach a settlement with federal prosecutors. On September 24, 2025, Ramirez pleaded guilty to conspiracy to commit wire fraud for his role in the scheme. As part of his settlement, he agreed to forfeit at least $13.6 million, which represents the value of the proceeds derived from the conspiracy. He currently awaits sentencing, which is scheduled for June 1, 2026 in the Southern District of Florida.
DOJ Press Release | Plea Agreement | Factual Proffer| IRS Press Release – September 24, 2025