MIAMI, FLORIDA – In a significant development for financial crime investigators, Tomás Niembro Concha, the 64-year-old former CEO of Nodus International Bank, pleaded guilty on Tuesday, March 31, 2026, to orchestrating a multi-million dollar wire fraud conspiracy and a scheme to evade U.S. sanctions against Venezuela. The plea marks a critical turning point in a case that saw the collapse of a Puerto Rico-based international banking entity and the loss of millions for hundreds of depositors.
The Charges Against Tomás Niembro Concha
Tomás Niembro Concha, originally from Venezuela and residing in Miami, faced a two-count information. He pleaded guilty to conspiracy to commit wire fraud and conspiracy to violate the International Emergency Economic Powers Act (IEEPA). Each charge carries a maximum penalty of 20 years in prison, potentially leading to a 40-year sentence. As part of his plea agreement, Niembro Concha has agreed to forfeit at least $16.9 million, representing the proceeds he derived directly from the wire fraud conspiracy.
The core of the fraud scheme, active from 2017 to 2023, involved Niembro Concha and Board Chairman Juan Francisco Ramirez siphoning funds from Nodus International Bank. They achieved this through a series of illicit financial maneuvers designed to conceal conflicts of interest from other board members, executives, and financial regulators.
Scale of the Crime
Niembro Concha’s intricate scheme fraudulently obtained at least $24.9 million from Nodus International Bank. The direct consequence of these actions was the bank’s catastrophic collapse in 2023. This led to the loss of approximately $92 million in deposits, impacting hundreds of clients across the U.S., Venezuela, and other Latin American countries. Investigations revealed that more than 95% of the bank’s loan portfolio was uncollateralized, a glaring red flag of the institution’s perilous state.
The fraudulent activities included:
- Sham Investments: Niembro Concha and Ramirez directed Nodus Bank to invest $11 million in a Miami-based lender, only for these funds to be secretly loaned back to them for personal use. These transactions were meticulously disguised as legitimate investments.
- Promissory Notes: Between January 2018 and September 2021, the duo fraudulently induced Nodus Bank’s board and comptroller to purchase at least 47 promissory notes, totaling approximately $25.3 million, from Nodus Finance—a Miami-based company they jointly owned. The proceeds were used for their personal enrichment.
- Loan Portfolio Transfer: In March 2023, facing impending liquidation by Puerto Rico’s Office of the Commissioner of Financial Institutions (OCIF), Niembro Concha and Ramirez fraudulently caused Nodus Bank to accept a loan portfolio from Nodus Finance. This move was designed to pay down their personal debt from the 47 promissory notes, effectively relieving Nodus Finance and its owners of their obligations to the bank.
- Sanctions Evasion: From 2021 to 2023, Niembro Concha engaged in prohibited financial transactions with an individual designated as a Specially Designated National (SDN) by OFAC, sanctioned for supporting Venezuela’s state-owned oil company, PDVSA. To settle a $2.5 million loan, Niembro Concha and the SDN obtained OFAC authorization to foreclose on the SDN’s Southampton, NY home. However, they then entered a separate, illicit agreement to sell the property back to the SDN for $4 million through a front company—a transaction explicitly prohibited by U.S. sanctions and unlicensed by OFAC.
“This case highlights the pervasive threat of corporate insiders exploiting their positions for personal gain, even at the cost of their institution and its depositors. The elaborate web of sham investments and sanctions evasion demonstrates a deliberate disregard for financial integrity and U.S. law.”
Who Is Tomás Niembro Concha?
Tomás Niembro Concha, a 64-year-old Venezuelan economist of Spanish origin, was a prominent figure in the Latin American financial sector. He served as the former CEO and majority owner (60%) of Nodus International Bank. His extensive career also included executive positions at Cartera de Inversiones Venezolana C.A. and Grupo B.O.D., both owned by Venezuelan banker Víctor Vargas. Niembro Concha also held directorships at Desarrollos Inmobiliarios y Valores BAN C.A., Banco del Orinoco in Curacao N.V., All Bank in Panama (where he was also treasurer), and Empire Banco de Ahorro y Crédito in the Dominican Republic, indicating a deep and widespread network within the regional banking landscape.
Investigation Details
The meticulous investigation was led by IRS Criminal Investigation (IRS-CI), with crucial support from the Office of the Commissioner of Financial Institutions of Puerto Rico (OCIF) and the Treasury Executive Office for Asset Forfeiture (TEOAF). The Department of Justice’s Criminal Division, specifically the Money Laundering, Narcotics and Forfeiture Section (MNF), and the U.S. Attorney’s Office for the Southern District of Florida are prosecuting the case. The fraud began to unravel through OCIF’s investigations, which identified severe financial and managerial deficiencies at Nodus Bank as early as 2017 and received numerous complaints from depositors unable to transfer funds. The FBI also launched an investigation into Niembro Concha and Ramirez regarding the disappearance of nearly $10 million that was subject to an OFAC block.
What Happens Next
Following his guilty plea, Tomás Niembro Concha’s sentencing is scheduled for June 8, 2026. Given the severity of the charges—conspiracy to commit wire fraud and conspiracy to violate the International Emergency Economic Powers Act (IEEPA)—he faces a substantial prison sentence. His co-conspirator, Juan Francisco Ramirez, pleaded guilty in September 2025 and agreed to forfeit at least $13.6 million, underscoring the coordinated nature of the illicit activities. The ongoing legal proceedings will determine the full extent of the penalties and the recovery of assets for the victims.
Protecting Yourself
This case serves as a stark reminder of the importance of vigilance in financial dealings. Several red flags were evident at Nodus International Bank. Early regulatory scrutiny, including violations of anti-money laundering regulations in 2012 and identified “serious financial and managerial deficiencies” by 2017, should have raised alarms. The consistent concealment of conflicts of interest and self-dealing transactions by executives, a lack of collateral for over 95% of the loan portfolio, and the bank’s refusal to complete fund transfers for depositors were all critical warning signs. Individuals and institutions should prioritize transparency, scrutinize related-party transactions, and heed regulatory warnings to safeguard against corporate fraud and financial mismanagement. Always be wary of institutions with a history of non-compliance with sanctions or a high percentage of uncollateralized assets, and promptly report any suspicious activity to the relevant authorities.
