FILED BY D.C.

FE8 1 2 2222

ANGELA E. NOBLQ

UNITED STATES DISTRICT COURT CLERK u S DISI Cm s. o, o: iuk. - MIAMI

SO UTH ER N DISTR IC T O F FLO RIDA

No. $D - C 7R E X *

UN ITED STATES O F AM ERICA

VS.

JUAN RIBA S DO M ENECH ,

JO SE VICENTE G O M EZ A VILES, and

FELIPE M ON CALEAN O BO TER O ,

Defendants.

/

CRIM INAL COVER SHEET

Did this m atter originate from a m atter pending in the N orthenz Region of the United States

A ttorney's Office prior to October l4, 2003? Yes x N o

Did this m atter originate from a m atter pending in the Central Region of the United States

Attorney's Office prior to Septem ber 1, 2007? Yes x N o

Respectfully subm itted,

ARIAN A FA JA RDO O RSHAN

UN ITED STA TES A TTORN EY

BY :

A LEX AN DER KRAM ER

TRIAL ATTORN EY , CRIM IN A L DIVISION

DEPARTM EN T OF JU STICE

Court ID N o. A 5502240

99 N E 4th street

M iam i, Florida 33132-21 l 1

Tel: (202) 768-1919

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 1 of 13
AO 91 (Rev. 08/09) Criminal Complaint

U NITED STATES D ISTRICT C OURT

for the

Southern District of Florida

United States of America

V.

JUAN RIBAS DOMENEC ,H

JosE VICENTE GOMEZ AVILE ,S and

FELIPE MONCALEANO BOTERO

)

)

) Case No. q o . V. .z.c . % D X

)

)

)

CRIM INAL COM PLAINT

1, the com plainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the datets) of 2014 - 2016 in the county of Miami-Dade in the

Southern District of Florida , the defendantts) violated:

Code Section

18 U.S.C. j 1956(h)

Offense Description

Conspiracy to Iaunder bribery proceeds in U.S. currency through bank

accounts in order to conceal the nature, Iocation, source, ownership, and

control of the proceeds

This crim inal complaint is based on these facts:

(see attached affidavit)

W Continued on the attached sheet.

omp ainant 's signature

Jeff LaMirand I -CI S ecial A ent

Printe name a ti Ie

,. . C.

' Jud e 's 'gnature g

Hon. John J. 'Sullivan, U.S. Ma istrate Jud e

Printed name and title

Sworn to before m e and signed in my presence.

Date. 

. l1k q>

City and state'.

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 2 of 13
T, JEFFREY LAMIRAND, being duly sworn,

follows:

depose and state

1. I am a Special Agent with the Internal Revenue

Service, Criminal Investigation C'IRS-CI''). I have been an IRSCI Special Agent since on or about July 9, 2010. My

responsibilities include the investigation of possible criminal

violations of the Internal Revenue Laws (Title 26, United States

Code), the Bank Secrecy Act (Title 31, United States Code), the

Money Laundering Control Act (Title 18, United States Code), and

other related offenses . I hold a bachelor's degree in

accounting and finance from Michigan State University . I also

hold a Juris Doctor degree from Chicago-Kent College of Law . I

am a certified public accountant (CPA) licensed to practice in

the State of Virginia and an attorney licensed to practice in

the State of Illinois . On or about February 8, 2014, I became a

full-time member of the Global Illicit Financial Team (nGIFT''),

a multi-agency task force within IRS-CI whose mission is to

investigate large, international third-party money laundering

cases . I am fluent in Spanish . As part of my work at the IRS,

I have received training regarding fraud and white collar

crimes, including the Foreign Corrupt Practices Act (AAFCPA/') and

money laundering .

2. I am familiar with the facts and circum stances

set forth below from my personal participation in the

investigation, including my examination of reports and records,

witness interview notes, my participation in witness interviews,

and conversations with other law enforcement officers and other

individuals. Because this affidavit is being submitted for the

limited purpose of establishing probable cause, it does not

include a11 the facts that I have learned during the course of

my investigation . Where the contents of documents and the

actions, statements and conversations of others are reported

herein, they are reported in substance and in unless noted

otherwise.

3. Your affiant has participated in a criminal

investigation into JUAN RIBAS DOMENECH, an Ecuadorian citizen

who currently resides in Miami-Dade County, Florida; FELIPE

MONCALEAHO BOTERO , a Colombian citizen; and JOSE VICENTE GOMEZ

AVILES, an Ecuadorian citizen who currently resides MiamiDade County, Florida . Based on the evidence gathered through

this investigation, there is probable cause to believe that from

in or around 2014 through at least in around 2016, in the

Southern District of Florida and elsewhere, JUAN RIBAS DOMENECH ,

FELIPE MONCARRANO BOTERO , and JOSE VICENTE GOMEZ AVILES,

together with others, engaged in a bribery scheme that violated

1

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 3 of 13
United States 1aw and Ecuadorian bribery law, and from in or

around 2014 through in or around 2016, JUAN RIBAS DOMENECH ,

FELIPE MONRAT.RANO BOTERO , and JOSE V ICENTE GOMEZ AVILES,

together with others, conspired to launder monetary instruments,

in violation of Title 18, United States Code, Section 1956(h),

that is: knowing that the property involved in a financial

transaction represented the proceeds of the unlawful bribery

scheme, conducted and attempted to conduct such a financial

transaction which in fact represented the proceeds of specified

unlawful activity, knowing that the transaction was designed in

whole or in part to conceal and disguise the nature, the

location, the source, the ownership , and the control of the

proceeds of specified unlawful activity, in violation of Title

18, United States Code, Section 1956(a)(1)(B) (i).

4 . Bribery of a foreign official, a felony violation

of the FCPA, Title 15, United States Code, Section 78dd-2 and

bribery of a public official of Ecuador, a felony violation of

the penal code of the Republic of Ecuador, are specified

unlawful activities, pursuant to Title l8, United States Code,

Sections 1956(c)(7)(B)(iv) and (D).

THE U .S. FOREIGN CORRUPT PRACTICES ACT (FCPA)

5. Your affiant is aware that the FCPA was enacted

by Congress for the purpose of, among other things, making it

unlawful to act corruptly in furtherance of an offer, promise,

authorization, or payment of money or anything of value,

directly or indirectly, to a foreign official for the purpose of

obtaining or retaining business for or with, or directing

business to any, person . 15 U .S .C . 55 78dd-1, et seq.

6. The FCPA prohibits udomestic concernsz' which

include residents of the United States, from making use of the

mails or any means or instrumentality of interstate commerce

corruptly in furtherance of an offer, payment, promise to pay,

or authorization of the payment of any money, or offer, gift:

promise to give, or authorization of the giving of anything of

value, to a foreign official or to a person, while knowing that

a11 or part of such money or thing of value would be and had

been offered, given, or promised to a foreign official, for

purposes of (i) influencing acts or decisions of such foreign

official in his official capacity; (ii) inducing such foreign

official to do or omit to do acts in violation of the lawful

duty of such official; (iii) securing any improper advantage; or

(iv) inducing such foreign official to use his influence with a

foreign government or agencies or instrumentalities thereof to

affect or influence acts decisions of such government or

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 4 of 13
agencies or instrumentalities, in order assist the domestic

concern to obtain or retain business for or with, or directing

business to, any person . 15 U .S .C . 5 78dd-2 (a) and (h)(1)(A).

THE ECUADORIAN PENAL CODE

RELATING TO BRIBERY OF A PUBLIC OFFICIAL

7 . From my review

Penal Code of the Republic

Code/') in effect from at

through the present, the

relevant provision relating

translated from Spanish :

a. Article 280 (Briberyj: Any public servant

and any person that acts on behalf of a state power within any

of the State's institutions, listed in the Constitution of the

Republic, that receives or accepts, directly or through a third

party, an improper econom ic benefit, or any other type of

benefit for himself or for a third party, either to carry out,

omit, expedite, delay or condition matters related to his or her

functions, shall be punished with a term of imprisonment of one

to three years . If the public servant executes an act or fails

to carry out the proper act, he or she shall be punished with a

term of imprisonment of three to five years. If the conduct

described is carried out in order to commit another crime, the

public servant shall be punished with a term of imprisonment of

five to seven years. Any person who in any way offers, gives or

promises any public servant a donation, gift, promise,

advantage, or improper economic benefit in order for such

servant to carry out, omit, expedite, delay, or condition

matters related to his or her functions, or in order to comm it a

crime, shall be punished with the same penalties issued against

public servants.

of an English translation of the

of Ecuador (the nEcuadorian Penal

least in or around February 2014

penal code contains the following

to bribery of a public official, as

RELEVAN T ENT IT IE S A ND IND IV IDUA LS

8. Seguros S .A . (Mseguros Sucre'') was

state-owned insurance company of Ecuador . Seguros Sucre was

controlled by the government of Ecuador and performed a function

that Ecuador treated as its own, and thus was an

ninstrumentality'' of the Ecuadorian government as that term is

defined in the FCPA, Title 15, United States Code, Section 78dd2 ( h ) ( 2 ) ( A ) .

9. JUAN

citizen of Ecuador

and advisor to

RIBAS DOMENECH : one of defendants, was

who served as the Chairman of Seguros Sucre

the President of Ecuador from at least in

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 5 of 13
about 2013 through at least in or about 2017 . JUAN RIBAS

DOMENECH was a nforeign official'' as that term is defined in the

FCPA, Title 15, United States Code, Section 78dd-2 (h)(2)(A).

JUAN RIBAS DOMENECH maintains residence in Miami-Dade County,

Florida.

10. FELIPE MON/ALEAHO BOTERO , one of the defendants,

was a Colombian citizen who was an executive and shareholder of

Insurance Broker's Colombian-based subsidiaries from in or

around at least 2013 through in or around 2019.

11. nInsurance Brokerr'' a company whose identity is

known to your affiant, was a reinsurance broker and risk adviser

based in the United Kingdom . Insurance Broker wholly- or

majority-owned subsidiaries based in Colombia through which it

acted as a broker for insurance companies in Colombia and Latin

America, assisting them to reinsure their risks in the local and

international (relinsurance markets. Seguros Sucre was a client

of Insurance Broker. Insurance Broker conducted its business

with Seguros Sucre through its Colombian based subsidiaries and

other wholly- or majority-owned entities.

12 . JOSE VICENTE GOMEZ AV ILES, one of the defendants,

was an Ecuadorian citizen, a U .S. lawful permanent resident, and

one of the owners of Introducer Company . JOSE V ICENTE GOMEZ

AVILES maintained residence in Miami-Dade County, Florida . JOSE

VICENTE GOMEZ AVILES was a ''domestic concern'' as that term is

defined in the FCPA, Title 15, United States Code, Section 78dd2 ( h ) ( 1 ) ( A ) .

13 . nIntroducer Companyz'' a company whose identity

is known to your affiant, was a Panama registered company that

operated as a reinsurance introducer. In that capacity,

Introducer Company helped companies obtain and retain contracts

with Seguros Sucre in exchange for receiving a commission .

14 . uIntermediary Company company whose

identity is known to your affiant, was a company formed and

registered in Panama . Tntermediary Company 1 held a brokerage

account with a bank in Switzerland (the uIntermediary Company 1

brokerage account''). JOSE VICENTE GOMEZ AVILES controlled

Intermediary Company 1 and could direct payments into and out of

the Intermediary Company 1 brokerage account .

15 . A' Intermediary Company 2 '' a company whose identity

is known to your af f iant , was a company f ormed and registered in

the Cayman Islands . Intermediary Company 2 held multiple

accounts with a bank in the United States , at least three of

which were used to f acilitate transf ers of cash and securities

4

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 6 of 13
between accounts identified herein (the nIntermediary Company

accounts'/).

16. uIntermediary Company 3,// a company whose

identity is known to your affiant, was company formed and

registered in Panama . Intermediary Company 3 held a brokerage

account with a bank in Switzerland (the A'Intermediary Company 3

brokerage account//), which was held for the benefit of JUAN

RIBAS DOMENECH and received and held a portion of the bribe

payments from JOSE VICENTE GOMEZ AVILES and FELIPE MONCALEANO

BOTERO to JUAN RIBAS DOMENECH . The Intermediary Company 3

brokerage account was largely funded by Intermediary Company 1.

17. nFinancial Advisor,'' an individual whose identity

is known to your affiant, was a dual United States and

Ecuadorian citizen, a relative of JOSE VICENTE GOMEZ AVILES, and

a financial advisor at a financial services firm who had

authority to cause transfers into and from the Intermediary

Company 1 brokerage account, Intermediary Company 2 accounts,

and Intermediary Company 3 brokerage account . Financial Advisor

was a udomestic concern'' as that term is defined in the FCPA ,

Title 15, United States Code, Section 78dd-2 (h)(1)(A), and a

nUnited States person'' as that term is defined in the FCPA,

Title 15, United States Code, Section 78dd-2 (i).

OVERV IEW OF THE SCHRM R TO LAUNDER BR IBERY PROCEED S

18. As described in greater detail below , JUAN RIBAS

DOMENECH , while acting as Chairman of Seguros Sucre, received

bribes from JOSE VICENTE GOMEZ AV ILES and FELIPE MONrAT.RAHO

BOTERO , in exchange for using his position to assist JOSE

VICENTE GOMEZ AVILES and others to obtain and retain business

for Insurance Broker with Seguros Sucre, in violation of the

FCPA and Ecuador's 1aw against bribery of a public official.

l9. In order to conceal and disguise the bribe

payments, JUAN RIBAS DOMENECH , JOSE VICENTE GOMEZ AVILES, and

FELIPE MONCALRAHO BOTERO , together with others, caused bribery

proceeds of at least approximately $1,004,000 to be laundered

through bank accounts in the United States for the benefit of

JUAN RIBAS DOMENECH and others, in violation of U .S. money

laundering laws.

THE BRIBER Y AND MONEY LAUNDER IN G SCHRMR

2O . From my

bank records, witness

this investigation, I

following :

review emails, contracts, documents,

interviews and from my participation in

have learned, among other things,

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 7 of 13
21. From at least in or around 2013 through at least

in around 2017, JUAN RIBAS DOMENECH, as Chairman of Seguros

Sucre, had influence relating to the award of Seguros Su c r e

contracts .

22 . In or around

reinsurance business from

broker for the Ecuadorian

period 2013 through 2014.

In

June 2013, Insurance Broker obtained

Seguros Sucre to be the reinsurance

Ministry of Defense (UMOD'') for the

24. around early 2014, FELIPE MONrAT.MANO BOTERO

approached the owners of Introducer Company, including JOSE

VICENTE GOMEZ AVILES, about helping Tnsurance Broker retain the

contract to provide reinsurance for MOD. FELIPE MONCALEANO

BOTERO and the other owner of Introducer Company arranged

meetings with Seguros Sucre officials, including JUAN RIBAS

DOMENECH . Following these meetings, Seguros Sucre agreed

retain Insurance Broker's MOD policy .

25 . In or around May 2014, after Seguros Sucre agreed

to maintain Insurance Broker's MOD policy, Insurance Broker

approved Introducer Company as an introducer. Insurance Broker

approved the payment of any future commissions to Introducer

Company's Panama bank account given that Introducer Company was

a Panama-based company .

26. around September 2014, Insurance Broker and

Introducer Company reached an agreement whereby Insurance Broker

agreed to pay Introducer Company $1.8 million commission for the

MOD 2013 through 2014 contract and an 8% commission on the MOD

2014 through 2015 contract .

27 . The commission payments to Introducer Company

however , , were not made to its approved Panama bank account .

Rather, at JOSE VICENTE GOMEZ AVILES'S request and with FELIPE

MONCALEAHO BOTERO'S approval, payments totaling approximately

$10.8 million in commissions to Introducer Company were made to

accounts in the United States, Panama, and Switzerland that were

not held in the Introducer Company's name but rather in the name

of Intermediary Company 1 and other entities .

28 . Specif ically, f rom on or about October 2 , 2014 to

on or about October 28 , 2016 , a U . S . bank account held by

Insurance Broker' s Colombian subsidiary made at least eleven

wire transf ers totaling at least approximately $ 6, 510 , 735 to

6

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 8 of 13
Intermediary Company 1's brokerage account in Switzerland .

These payments were Introducer Company's commissions from the

reinsurance policies with Seguros Sucre to insure MOD and other

state-owned entities of Ecuador .

29. In or around February 2015, JOSE VICENTE GOMEZ

AVILES and FELIPE MONCALEANO BOTERO caused to be created a

false, backdated contract between Insurance Broker's Colombianbased subsidiary and Intermediary Company 1, signed by FELIPE

MONCALEAHO BOTERO , which was sent to Intermediary Company 1's

Swiss bank to justify the payments sent by Insurance Broker to

Intermediary Company 1 .

30. A portion of commission payments from the

Insurance Broker to Introducer Company for the Seguros Sucre

contracts were funneled to JUAN RIBAS DOMENECH and others close

to him through transactions involving multiple intermediary

companies and securities transfers. Specifically: Intermediary

Company 1 brokerage account, which was funded almost exclusively

with Insurance Broker commission payments to Introducer Company

,

transferred at least approximately $682,000 in cash and

$1,975,000 worth of securities ($2,657, 000 total value) to

Intermediary Company 3 brokerage account, which was held for the

benefit of JUAN RIBAS DOMENECH . A11 but one of these transferb

occurred though U .S .- based accounts held by Intermediary

Company 2 . Furthermore, Intermediary Company 1 and Intermediary

Company 3 Swiss-based brokerage accounts funneled through

Intermediary Company 2 U . s .-based accounts at least

approximately $750,000 into U.s.-based accounts held by JUAN

RIBAS DOMENECH and at least approximately $254,000 into U. S .-

based accounts held by JUAN RIBAS DOMENECH'S relatives .

On or about March 23, 2016, Financial Advisor

exchanged emails with his assistant regarding Tntermediary

Company 1 payments made to JUAN RIBAS DOMENECH between in or

around November 2014 and January 2016 and those still pending.

The correspondence references JUAN RIBAS DOMENECH by initials

and by name and also references JUAN RIBAS DOMENECH as linked to

Intermediary Company 3.

A . NovomHer 2014 Transfer of $400,000 for Benefit of JUAN

RIBA S DOM EN ECH

32. On or about November 3, 2014, JOSE VICENTE GOMEZ

AVILES caused the Intermediary Company 1 brokerage account to

transfer approximately $400,000 to the Intermediary Company 3

brokerage account, which was an account used to receive and hold

funds for the benefit of JUAN RIBAS DOMENECH .

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 9 of 13
B . Decomner 2014 Payment of $300,000 to JUAN RIBAS

DOMENECH

33. On or about December 8, 2014, Intermediary

Company 1's brokerage account transferred approximately $319

, 777 of Introducer Company's commissions on the MOD contracts t

o on e of the Intermediary Company 2 accounts through the purchase o f a

security .

34. On or about December 18, 2014, the same

Intermediary Company 2 account wired $300, 000 of the $319,777 to

a U.S. based bank account in the name of JUAN RIBAS DOMENECH .

C. January 2015 Payment of $282,000 to Intermediary

Company 3

35 . On or about December 9, 2014, while in

Southern District of Florida, JOSE VICENTE GOMEZ AVILES sent an

email to Financial Advisor, directing him to transfer $282, 000

to nel amigo.''

On or about December 12, 2014, Financial Advisor

caused the Intermediary Company l brokerage account to transfer

approximately $310,158 to one of the Intermediary Company 2 .

accounts through the purported purchase of a security .

37. On or about January 15, 2015, Financial Advisor

caused the Intermediary Company 2 account to wire approximatel

$282 y

, 000 of the $310,158 to the Intermediary Company 3 brokerage

account .

June 2015 Payment of $100,000 to JUAN RIBAS DOMENECH

38. or about June 8, 2015, Financial Advisor

caused the Intermediary Company 3 brokerage account to transfer

approximately $106,706 back to one of the Intermediary Company 2

accounts through the purchase of a security .

about June 8, 2015, Financial Advisor

caused the same Intermediary Company 2 account to wire $100, 000

of the $106,706 to a U.s.-based bank account in the name of JUAN

R IBA S DOM ENECH .

E. March and Aprii 2016 Payment of $104,000 to JUAN RIBAS

DOMENECH'S Reiatives

40 . From on or about March 31, 2016 to on about

April 11, 2016, Financial Advisor caused one of the Intermedi

C ary ompany 2 accounts to make three wire transfers to the U . S .

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 10 of 13
based accounts in the names of relatives of JUAN RIBAS DOMEN

th ECH

at totaled approximately $104,000.

First, on or about March 2016 Ad , Financial

visor caused the Intermediary Company account to wire approximately $29,000 to a U.s.

- based bank account in the name

of a relative of JUAN RIBAS DOMENECH .

42. Second, on or about April 2016

, Financial

Advisor caused the Intermediary Company account wire approximately $65,000 to a U .sv based bank account in nam

e

of a second relative of JUAN RIBAS DOMENECH .

43. Third, on or about April 1l, 2016, Financial

Advisor caused the Intermediary Company 2 account to wire

approximately $10,000 to a U.s.-based bank account in the name

of a third relative of JUAN RIBAS DOMENECH .

44. On or about May 12, 2016, Financial Advisor

caused the Intermediary Company 3 brokerage account to t $104 ransfer

, 000 in securities to the Tntermediary Company 2 account in order to reimburse Intermediary Company 2 for making approximately $104,000 in transfers to JUAN RIBAS DOMENECH'

S

relatives .

E . May-August 2016 Rmnils

MONCALRAHO BOTERO to JUAN

Seguros Sucre Official

Regarding ''Loans''

RIBAS DOMENECH

from FELIPE

and Another

45. Between in or around May 5, 2016 and June 6, 2016

FELIPE MONrAT.EAHO BOTERO sent em ails to JOSE VICENTE GOM EZ

AVILES and the other owner of Tntroducer Company discussing

repayment owed to FELIPE MONOAT.RAHO BOTERO for $200, 000 nloaned''

to Efirst name of a second Seguros Sucre executiveq with the

agreement to be repaid from the MOD commission. FEL IPE

MONCALEAHO BOTERO also referenced the ''1%/' for (first name of a

second Seguros Sucre executiveq.

46. On

BOTERO emailed JOSE AVILES

2016,

and

FEL IPE

the other owner of

MONCALKANO

Company referencing $80,000 that he had transferred

from his personal funds for uTermopinchincha

, '' which your

affiant believes to be a reference to CELEC EP Termopinchincha,

a business unit of the Ecuadorian public electric company and

one of the entities in connection with which Insurance Broke r received reinsurance business with Seguros Sucre . FEL IPE

MONCALRRHO BOTERO further stated (translated from Spanish)

, ''We

need to find way for me to get back this 80

, 000 plus the

200,000 that transferred last year to transfer an

9

Introducer

about August 8,

VICENTE GOMEZ

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 11 of 13
adjustment to Juan.''

reference to JUAN RIBAS

Your affiant believes

DOMENECH .

specifically the

transfers made Intermediary Company 1 to Intermediary

Company and Intermediary Company 3 knowing that a portion of

such money would be offered, given, or promised, directly or

indirectly, to JUAN RIBAS DOMENECH, there is probable cause to

believe that, from in or around 2014 through at least in o r

around 2016, JOSE VICENTE GOMEZ AVILES, a 'Adomestic concern''

under the FCPA, willfully and corruptly made use of the mails

and means and instrumentalities of interstate commerce in

furtherance of an offer and promise to make payments for the

benefit of Ecuadorian officials, including JUAN RIBAS DOMENECH

for the purpose of corruptly influe ,

ncing those officials in

order to assist JOSE VICENTE GOMEZ AVILES in obtaining and

retaining business for, and directing business to

, himself,

Introducer Company, FELIPE MONCALEANO BOTERO, and Insurance

Broker, violation of Title 15, United States Code, Section

78dd-2 .

47. Based On the foregoing,

from

48. Based on the foregoing, and based on my review of

the Ecuadorian Penal Code , there is also probable cause to

believe that the bribery scheme conducted by JUAN RIBAS

DOMENECH , JOSE VICENTE GOMEZ AVILES , and FELIPE MONCALEANO

BOTERO, and others as described above, in which JUAN RIBAS

DOMENECH received bribes from JOSE VICENTE GOMEZ AVILES and

FELIPE MONCALEANO BOTERO in exchange for, among other things,

obtaining and retaining contracts from Seguros Sucre, w a s a n

offense under, ânter alia, Ecuadorian 1aw prohibiting bribery of

public officials.

49. Based on foregoing the , specifically the

subsequent movement of a portion of the payments received by

Intermediary Company 2 and Intermediary Company 3, directly or

through securities transactions, from Intermediary Company 1, to

accounts held in the name of or for the benefit of JUAN RIBAS

DOMENECH or his relatives, there is also probable cause to

believe that, in or around 2014, through at least in or around

2016, JUAN RIBAS DOMENECH , JOSE VICENTE GOMEZ AVILES, and FELIPE

MONCALRAHO BOTERO conspired with others to commit money

laundering . Specifically, there is probable cause to believe

that JUAN RIBAS DOMENECH conspired with JOSE VICENTE GOMEZ

AVILES and FELIPE MONCALRAHO BOTERO , and others, to launder

bribery proceeds in U . S. currency through bank accounts

including bank accounts in the U , nited States, in order to

conceal the nature, location, source, ownership , and control

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 12 of 13
the proceeds, violation

Section l956(h).

CONCLUSION

Based on the foregoing, I believe probable cause exists to

issue a criminal complaint and arrest 

RIB warrant charging JUAN

AS DOMENECH , JOSE VICENTE GOMEZ AVILES

, and FELIPE MONrALEAHO

BOTERO with violating Title 18, United States Code 1956(h) , Section .

United States Code ,

Your affiant therefore

enter a complaint for

warrant for the arrest

GOMEZ AV ILES , and FELIPE

respectfully requests that the Court

the foregoing violations and issue a

of JUAN RIBAS DOMENECH , JOSE VICENTE

MONCAT.RANO BOTERO .

<

JE LAM IRAN D

S CIAL AGENT

INTERNAL REVENUE SERV ICE

,

:

sworn to fo me h 's

lz-th day of brua y 2 2

UNITED ISTRATE JUDGE

SOUTHER DT RICT OF FLORIDA

Case 1:20-cr-20169-KMW Document 3 Entered on FLSD Docket 02/13/2020 Page 13 of 13