The former chief executive of Nodus International Bank has been sentenced to 112 months in prison following his role in a fraud that stripped the failed Puerto Rican institution of at least $24.9 million, alongside a separate conspiracy to circumvent United States sanctions targeting Venezuela. The US Department of Justice confirmed the sentence, handed down on 22 September 2026 against 64-year-old Tomás Niembro Concha, who had entered his plea earlier in the year in March 2026. Niembro will also serve three years of supervised release once his custodial term ends.

The scheme at the heart of the bank's collapse

According to the case set out by prosecutors, Niembro and the bank's board chairman, Juan Ramirez, orchestrated a course of conduct between 2017 and 2023 in which loans and investments made by Nodus were quietly steered to benefit the pair themselves. The bank channelled roughly $11 million into a Miami-based lender, a manoeuvre said to have facilitated loans back to the conspirators. The board was also induced to approve 47 promissory notes issued by Nodus Finance, an entity jointly owned by Niembro and Ramirez, generating a further $25.3 million in fraudulent instruments.

Niembro admitted a count of conspiracy to commit wire fraud. The court ordered forfeiture of $16.9 million, while the fraudulent proceeds extracted from the bank were assessed at a minimum of $24.9 million. Nodus International Bank itself did not survive the fallout: it failed during 2023 and was placed into liquidation in March of that year.

Evading sanctions on Venezuela

The second strand of the prosecution concerned Niembro's conviction for conspiracy to violate the International Emergency Economic Powers Act. Between January 2018 and September 2021, he worked with an individual who had been designated by the US Treasury to sidestep restrictions administered by the Office of Foreign Assets Control (OFAC). After lawfully foreclosing on a Southampton property, the parties arranged an unauthorised onward sale of the asset for $4 million through a front company, concealing the involvement of the sanctioned party.

Board chairman named as co-defendant

Board chairman Juan Ramirez was identified as a co-defendant in connection with the fraud, though the outcome of any proceedings against him was not detailed. The combined charges illustrate how a single executive was able to exploit governance weaknesses at the top of a licensed financial institution, using the bank's own approval processes to lend an appearance of legitimacy to transactions that served private interests.

What it means for compliance and in-house counsel

The case is a pointed reminder that sanctions and anti-fraud exposure frequently travel together, and that both can originate from the most senior levels of an organisation. For compliance teams and in-house counsel, the facts underline the importance of robust related-party controls, independent scrutiny of board-approved lending, and diligence on the ultimate beneficiaries behind property and asset transactions. The Venezuela element is particularly instructive: dealings routed through front companies and foreclosed assets can quietly draw an institution into breach of OFAC restrictions, making enhanced screening of counterparties and end-buyers essential. As enforcement authorities continue to pursue individuals rather than institutions alone, directors and officers should expect personal accountability where oversight fails and self-dealing goes unchecked.