A criminal complaint filed on February 12, 2020 and unsealed on March 30, 2020 alleged that Juan Ribas Domenech, Jose Vicente Gomez Aviles, and Felipe Moncaleano Botero engaged in a conspiracy to launder bribery proceeds in US currency. The complaint alleges that Gomez and Moncaleano paid bribes to Ribas, who served between 2014 and 2016 as both the chairman of Seguros Sucre S.A., the Ecuadorean state-owned insurance company, and as an advisor to the then-president of Ecuador. As described in the complaint, the bribery scheme involved intermediaries, including Gomez, who helped Moncaleano’s company retain reinsurance contracts with Seguros Sucre for the Ecuadorean Ministry of Defense (MoD). According to the allegations, $10.8 million was paid in purported commissions through intermediary companies for the benefit of Ribas in exchange for the award or renewal of the MoD reinsurance contract. Some of this $10.8 million was allegedly laundered through the US financial system. The complaint states that the money laundering was done with the intent of violating the anti-bribery provisions of the FCPA as well as Ecuadorean anti-bribery law. Another criminal complaint, filed on March 3, 2020, ties Roberto Heinert to the scheme as co-owner of Moncaleano’s company.