Executive Summary
Laws and Precedent
Juan Francisco Ramirez, the former chairman of the board of Nodus International Bank, a Puerto Rican international banking entity, pleaded guilty on September 22 to leading a multimillion-dollar wire fraud conspiracy that siphoned over $13.6 million from the bank, ultimately causing its collapse in 2023.
Fraudulent Schemes Unveiled
According to court documents, Ramirez, 60, of Miami, conspired with others from 2017 to 2023 to illegally divert funds. He and a co-conspirator concealed from other Nodus board members, executives, and the Office of the Commissioner of Financial Institutions of Puerto Rico (OCIF) that certain investments and loans were for their personal benefit, violating Puerto Rican law and Nodus policy on insider transactions.
The scheme involved investing more than $11 million of Nodus’s funds in a Miami-based lender. This lender then funneled those funds back to Ramirez and his co-conspirator as loans for their own use. To hide the illicit nature of these transactions, Ramirez and his co-conspirators orchestrated sham investments in the lending entity.
Misuse of Promissory Notes and Loan Portfolios
Between January 2018 and September 2021, Ramirez and a co-conspirator fraudulently induced the bank’s board and comptroller to approve the purchase of at least 47 promissory notes, totaling approximately $25.3 million. These notes were acquired from a Miami-based finance company jointly owned by Ramirez and his co-conspirator.
Although these promissory notes purported to fund legitimate loans, the proceeds were instead used by Ramirez and his co-conspirator for personal investments in third-party companies, mortgage payments, and credit card expenses. This direct self-enrichment was hidden from Nodus and its regulators.
In early March 2023, OCIF informed Nodus of its intent to liquidate the bank. Later that month, Nodus agreed to voluntary liquidation. On April 28, 2023, without authorization from OCIF and knowing liquidation was imminent, Ramirez and a co-conspirator caused Nodus to purchase a loan portfolio worth approximately $26 million from their Miami-based finance company. Most of these loans were delinquent, nonperforming, and uncollateralized. This transaction allowed the finance company to settle its debt to Nodus, directly benefiting Ramirez and his co-conspirator.
Statements from Justice Officials
Acting Assistant Attorney General Matthew R. Galeotti emphasized the Justice Department’s commitment to prosecuting white-collar fraudsters. “The defendant abused his position as Chairman of the board of directors to fraudulently divert funds from the bank that he had been entrusted to run, resulting in the bank’s collapse,” Galeotti stated.
U.S. Attorney Jason A. Reding Quiñones for the Southern District of Florida reiterated the importance of protecting the banking system. “Ramirez abused that trust, siphoning millions for personal gain and leaving behind collapse and loss,” Quiñones said. “The Southern District of Florida will hold corporate leaders accountable when they turn financial institutions into vehicles of fraud.”
Special Agent in Charge Emmanuel Gomez of IRS Criminal Investigation (IRS-CI) Miami underscored the impact of such crimes beyond financial loss. “The Chairman’s fraud brought down more than a bank — it undermined public trust,” Gomez noted, affirming IRS-CI’s dedication to protecting the integrity of the U.S. financial system.
Legal Proceedings
As part of his plea agreement, Ramirez consented to forfeiture of at least $13.6 million, representing the proceeds derived from the conspiracy. He pleaded guilty to conspiracy to commit wire fraud and faces a maximum sentence of 20 years in prison. His sentencing date will be determined by a federal district court judge, who will consider U.S. Sentencing Guidelines and other statutory factors.
The case was investigated by IRS Criminal Investigation. Trial Attorneys Javier Urbina and Samir Paul of the Criminal Division’s Money Laundering and Asset Recovery Section (MLARS), Bank Integrity Unit, along with Assistant U.S. Attorney Felipe Plechac-Diaz for the Southern District of Florida, are prosecuting the case.
