Tomás Niembro Concha, the former chief executive of Puerto Rico-based Nodus International Bank, has been sentenced to 112 months — nine years and four months — in federal prison after pleading guilty to a multimillion-dollar fraud conspiracy and a separate conspiracy to evade U.S. sanctions involving Venezuela.
The 64-year-old Spanish and Venezuelan national was also sentenced to three years of supervised release and ordered to forfeit more than $16.9 million, representing proceeds federal prosecutors said he derived from the fraud. The Justice Department said Niembro led a scheme that fraudulently obtained at least $24.9 million from Nodus, a Puerto Rico international banking entity, while also participating in prohibited financial transactions involving a person sanctioned by the U.S. government.
Niembro pleaded guilty March 19 to conspiracy to commit wire fraud and conspiracy to violate the International Emergency Economic Powers Act. The criminal case, United States v. Tomás Niembro Concha, No. 1:26-cr-20035, was prosecuted in the U.S. District Court for the Southern District of Florida. Each offense carried a maximum statutory penalty of 20 years before sentencing.
According to federal court filings summarized by prosecutors, Niembro and others siphoned money from Nodus through transactions that concealed the financial interests of Niembro and the bank's board chairman, Juan Ramirez, from other directors, executives and Puerto Rico's Office of the Commissioner of Financial Institutions, known as OCIF. Prosecutors said the conduct ultimately contributed to Nodus's failure in 2023.
From 2017 through 2023, Niembro, Ramirez and others caused Nodus to invest $11 million in a Miami-based lender, according to the Justice Department. The money was then loaned to Niembro and Ramirez for their own benefit, while prosecutors said the true nature of the transactions was concealed through what the government described as sham investments.
A second stream of transactions occurred between January 2018 and September 2021. Federal prosecutors said Niembro and Ramirez induced Nodus's board and comptroller to purchase at least 47 promissory notes worth approximately $25.3 million from Nodus Finance, a Miami company jointly owned by the two men. The government said the proceeds were then available for their personal benefit.
Ramirez separately pleaded guilty in September 2025 to conspiracy to commit wire fraud. In that case, prosecutors said he fraudulently obtained more than $13.6 million from Nodus and agreed to forfeit at least the same amount. The Justice Department said the scheme included using proceeds for personal investments, mortgages and credit-card expenses.
By early March 2023, Puerto Rico regulators had informed Nodus that the institution would be placed into liquidation. Prosecutors said Niembro and Ramirez then caused Nodus to accept a loan portfolio from Nodus Finance as payment toward debt associated with the 47 promissory notes. In the case against Ramirez, DOJ said most of the approximately $26 million loan portfolio transferred shortly before liquidation was delinquent, nonperforming or otherwise uncollateralized.
Puerto Rico's regulator has separately described increasingly severe action against Nodus. OCIF said a voluntary liquidation and dissolution plan was signed in May 2023, the bank's operating license was revoked in October 2023 and Nodus was placed under permanent receivership until completion of the liquidation. In April 2024, the regulator issued an order seeking to make Niembro and Ramirez personally liable for the institution's debts and requiring them to put up approximately $26.83 million in personal assets for depositors and creditors. It also barred both men from conducting business in Puerto Rico for 10 years.
The federal criminal case against Niembro also extended beyond the fraud that depleted Nodus. Prosecutors said that between 2021 and 2023 he conspired with others to conduct transactions involving an individual designated by the Treasury Department's Office of Foreign Assets Control as a Specially Designated National, or SDN, for providing material support to Venezuela's state-owned oil company, Petróleos de Venezuela, S.A., or PDVSA. DOJ did not identify the sanctioned individual in Monday's announcement.
According to prosecutors, a company associated with that individual owed Nodus approximately $2.5 million from a loan predating the sanctions. Niembro and the sanctioned individual arranged for Nodus to foreclose on the person's home in Southampton, New York, a step for which the bank obtained authorization from OFAC. But prosecutors said the two separately entered into an undisclosed agreement for Nodus to sell the home back to the sanctioned person for $4 million through a front company, a transaction that was prohibited under U.S. sanctions and had not been licensed by OFAC.
Nodus had previously attracted Treasury scrutiny over Venezuela sanctions compliance. In October 2022, OFAC issued a Finding of Violation against the bank over three unlicensed transactions involving property in which a sanctioned individual had an interest. Treasury also cited failures to maintain complete records and inaccuracies in Nodus's reporting of blocked property. OFAC chose to issue a finding rather than impose a civil monetary penalty in that administrative matter.
At sentencing, Assistant Attorney General A. Tysen Duva said Niembro “abused his position with Nodus Bank to commit fraud for his own enrichment and to willfully evade sanctions on a designated individual.” Federal investigators said the case involved cooperation among IRS Criminal Investigation, Puerto Rico's financial regulator and the Treasury Executive Office for Asset Forfeiture.
OCIF's current licensing records continue to list Nodus International Bank as pending liquidation.
