UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:20-CV-22427-MGC

UNITED STATES OF AMERICA,

Plaintiff,

vs. 

REAL PROPERTY LOCATED AT

900 BISCAYNE BLVD UNIT #6107, 

MIAMI, FLORIDA 33132, 

Defendant In Rem.

/ 

UNITED STATES’ MOTION FOR ENTRY OF JUDGMENT OF FORFEITURE

CONSISTENT WITH THE STIPULATION AND SETTLEMENT AGREEMENT

BETWEEN THE UNITED STATES AND CLAIAMANT

Plaintiff, the United States of America, pursuant to Rules 54 and 58 of the Federal Rules 

of Civil Procedure, files this Motion for Entry of Judgment of Forfeiture Consistent with the 

Stipulation and Settlement Agreement between the United States and Nathalie Bumba-Pembe 

(“Claimant”) (collectively, the “Parties”). 

1. On June 12, 2020, the United States filed a Verified Complaint for Forfeiture in

Rem (the “Complaint”) against Real Property Located at 900 Biscayne Blvd Unit #6107, Miami, 

Florida 33132 (“Defendant Property”). ECF No. 1. 

2. The Complaint alleged, among other things, that “between 2011 and 2014, Minister

[Denis-Christel Sassou] Nguesso embezzled millions of dollars from” “Société Nationale des 

Pétroles du Congo, the state-owned oil company of the Republic of the Congo,” and that he “used 

the stolen funds to acquire real estate and luxury goods . . . including the [Defendant] Property.” 

ECF No. 1 at 1, 4. 

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3. On June 23, 2020, the Complaint was posted on the door of the Defendant Property. 

ECF No. 4. Notice of Civil Forfeiture was posted on an official government internet site 

(www.forfeiture.gov) for at least 30 consecutive days as required by Rule G(4)(a)(iv)(C) of the 

Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions. ECF No. 27.

4. On August 28, 2020, Claimant filed a Verified Claim and Statement of Interest as 

the sole titleholder of the Defendant Property, ECF No. 9, and on September 18, 2020, filed an 

Answer and Affirmative Defenses, ECF No. 12.

5. On October 22, 2020, the Parties filed an Agreed Motion to Authorize Interlocutory 

Sale of the Defendant Property, ECF No. 13, in which the Parties agreed that the net proceeds of 

the sale of the Defendant Property (“Net Proceeds”), to include any refund of taxes paid in 

connection with the sale, would be substituted as the res in this civil forfeiture action. The Court 

entered an order granting the motion on the same day, ECF No. 14. 

6. Per the Court’s order, the Defendant Property was sold, and, on November 2, 2020, 

the Net Proceeds were transferred to HSI and the IRS.1

7. The time for filing other claims has expired, and no other claims have been filed.

8. The United States and Claimant entered into a Stipulation and Settlement 

Agreement (the “Agreement”), in which they agreed to a settlement in which the United States 

will return $250,000.00 of the Net Proceeds to Claimant, while the remainder of the Net Proceeds, 

approximately $1,888,081.81, will be forfeited to the United States. ECF No. 28-1.

9. On August 5, 2021, this Court approved the Agreement. ECF No. 29.

1 The funds transferred to the IRS represent “those withheld under the Foreign Investment 

in Real Property Tax Act (‘FIRPTA’),” which Claimant agreed, if they were “later released or 

refunded . . . shall be remitted to the United States and shall become a part of the net proceeds and 

the substitute res.” Aff. of Nathalie Bumba-Pembe, ECF No. 13-1.

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10. The United States now respectfully requests that the Court, in accordance with the 

Agreement, order that $250,000 of the Net Proceeds be returned to Claimant

11. The United States further requests that the Court enter a Judgment of Forfeiture, 

ordering that the remainder of the Net Proceeds, as well as any refund of the FIRPTA tax withheld 

as part of the sale of the Defendant Property, and currently held by the IRS, that would otherwise 

be due to Claimant, be forfeited to the United States.

12. The United States respectfully requests that the Court retain jurisdiction to enter 

any further orders necessary to effectuate this Judgment, particularly as may be required to 

facilitate the transfer of funds currently held by IRS under FIRPTA.

WHEREFORE, the United States requests that this Court enter a Judgment of Forfeiture 

pursuant to Rules 54 and 58 of the Federal Rules of Civil Procedure, and for such other relief as 

the Court deems just and proper.

Dated: August 5, 2021 Respectfully submitted,

DEBORAH CONNOR, CHIEF

MONEY LAUNDERING & 

ASSET RECOVERY SECTION

By: /s/ Shai. D. Bronshtein

Shai D. Bronshtein, Trial Attorney (No. A5502665)

Criminal Division

United States Department of Justice 

1400 New York Avenue NW

Washington, DC 20005

Telephone: (202) 616-5950

Shai.Bronshtein@usdoj.gov

JUAN ANTONIO GONZALEZ

ACTING UNITED STATES ATTORNEY

SOUTHERN DISTRICT OF FLORIDA

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/s/ Adrienne E. Rosen

Adrienne E. Rosen, AUSA (No. A5502297)

U.S. Attorney’s Office 

99 NE 4th Street, 7th Floor

Miami, Florida 33132

Telephone: (305) 961-9338

Facsimile: (305) 536-4089

Adrienne.Rosen@usdoj.gov

Attorneys for Plaintiff

UNITED STATES OF AMERICA

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