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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. _________________________

 18 U.S.C. § 1956(h)

 18 U.S.C. § 982

UNITED STATES OF AMERICA

 

vs. 

 

JUAN RIBAS DOMENECH, 

 Defendant.

__________________________________/

FACTUAL PROFFER IN SUPPORT OF GUILTY PLEA

The United States Department of Justice, Criminal Division, Fraud Section (the 

“government”), and the Defendant, Juan Ribas Domenech (the “defendant”), stipulate and agree

that the information stated herein is true and accurate and a sufficient basis for the defendant’s plea 

of guilty to the money laundering conspiracy in violation of Title 18, United States Code, Section 

1956(h) charged in the instant case. Had this matter proceeded to trial, the defendant stipulates 

and agrees that the government would have proven the facts alleged below beyond a reasonable 

doubt and the forfeiture allegations set forth in the criminal Information by a preponderance of the 

evidence. 

Seguros Sucre S.A. (“Seguros Sucre”) was the state-owned and state-controlled insurance

company in Ecuador. Seguros Sucre performed government functions for and on behalf of 

Ecuador. The defendant was an Ecuadorian citizen who served as a public servant as the Chairman 

of the Board of Seguros Sucre and an advisor to the then-President of Ecuador. In those official 

capacities, the defendant had authority over the awarding of Seguros Sucre business. During the 

relevant time period, the defendant obtained more than two million dollars in bribes in exchange 

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for using his official positions to allow three U.K.-based reinsurance brokers (“Insurance Broker

1”, “Reinsurance Broker 1”, and “Reinsurance Broker 2”) to obtain and retain contracts with 

Seguros Sucre. The defendant was introduced to Insurance Broker 1 by a Panama-registered 

company that operated from Miami, Florida as a reinsurance introducer (“Introducer Company

1”). Separately, he was introduced to Reinsurance Brokers 1 and 2 by an Ecuador-based 

reinsurance introducer (“Introducer Company 2”). Introducer Companies 1 and 2 helped 

companies obtain and retain contracts with Seguros Sucre in exchange for receiving a commission.

Overview of Criminal Schemes Involving Insurance Broker 1 (Scheme 1)

Between in or around 2013 and in or around 2017, the defendant and others—including

Roberto Heinert (“Heinert”) and Jose Vicente Gomez Aviles (“Gomez”), co-owners of Introducer 

Company 1, and Felipe Moncaleano Botero (“Moncaleano”), the CEO of the Colombian-based 

subsidiary of Insurance Broker 1 during the relevant time period—knowingly and willfully agreed 

to offer, give, and promise an improper economic benefit of at least approximately $2,957,000 in

bribes to the defendant and other Ecuadorian public servants in order to carry out, omit, expedite, 

delay or condition matters related to their functions, that isto assist Insurance Broker 1 in obtaining 

and retaining business with Seguros Sucre (“illegal bribery scheme 1”). 

Further, from in or around 2013 and continuing until at least 2017, the defendant knowingly 

and willfully conspired with others, including Heinert, Gomez, and Moncaleano , to conceal and 

disguise the nature, location, source, ownership, and control of the proceeds of illegal bribery 

scheme 1 and the corruptly obtained contracts. The defendant knew that this conduct was 

unlawful.

Specifically, between in or around 2014 and in or around 2017, Introducer Company 1 

received approximately $10.8 million in commission payments from Insurance Broker 1 on 

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Insurance Broker 1’s corruptly obtained business with Seguros Sucre. The defendant’s coconspirators then laundered a portion of the commissions to the defendant and other Ecuadorian 

government officials, including to accounts held in the defendant’s name, the names of the 

defendant’s relatives, and the name of a nominee account holder for the defendant’s benefit. The 

defendant and his co-conspirators laundered at least approximately $1,004,000 of the commissions

through bank accounts in the United States for the benefit of the defendant. In furtherance of the 

conspiracy, and with the intent to conceal and disguise the nature, location, source, ownership, and 

control of the proceeds of illegal bribery scheme 1, the defendant and his co-conspirators, among 

other things, transferred the corrupt proceeds to and through multiple intermediary companies,

including shell company bank accounts in Switzerland; disguised bribe payments through private 

securities purchases; and provided false justifications for transactions to banks, Insurance Broker

1’s compliance personnel, and others. 

Illegal Bribery Scheme 1

In or around June 2013, Insurance Broker 1 obtained reinsurance business from Seguros 

Sucre to be the reinsurance broker for the Ecuadorian Ministry of Defense (“MOD”) for the period 

2013 through 2014. In or around late 2013, Seguros Sucre informed Insurance Broker 1 that 

Seguros Sucre might not renew Insurance Broker 1’s MOD reinsurance policy. In or around early 

2014, Moncaleano approached Introducer Company 1 about helping Insurance Broker 1 retain the 

Seguros Sucre MOD business. Gomez and Heinert arranged meetings between Insurance Broker 

1 and the defendant, following which Seguros Sucre agreed to retain Insurance Broker 1’s MOD 

policy. The defendant and his co-conspirators agreed that the defendant would receive bribes in 

exchange for allowing Insurance Broker 1 to obtain and retain business from Seguros Sucre.

In or around May 2014, after Seguros Sucre agreed to maintain Insurance Broker 1’s MOD 

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policy, Insurance Broker 1 approved Introducer Company 1 as an introducer. Insurance Broker 1

approved the payment of any commissions to Introducer Company 1’s Panama bank account given 

that Introducer Company 1 was a Panama-registered company. In or around September 2014, 

Insurance Broker 1 and Introducer Company 1 reached an agreement whereby Insurance Broker 1 

agreed to pay Introducer Company 1 $1.8 million commission for the MOD 2013 through 2014 

contract and an 8% commission on the MOD 2014 through 2015 contract. The commission 

payments to Introducer Company 1, however, were not made to its approved Panama bank 

account. Rather, at Gomez and Heinert’s request and with Moncaleano’s approval, the $10.8 

million in commissions from Insurance Broker 1 to Introducer Company 1 were paid to accounts 

in the United States, Panama, and Switzerland that were not held in Introducer Company 1’s name.

For example, on or about June 4, 2014, with the help of a financial advisor who was also a 

co-conspirator in the illegal bribery scheme and money laundering scheme (“Financial Advisor”), 

Gomez opened a bank account in Switzerland (“Intermediary Company 1 brokerage account”), 

which he used to receive Introducer Company 1’s commissions from Insurance Broker 1 as 

approved by Moncaleano. Specifically, from on or about October 2, 2014 to on or about October 

28, 2016, a U.S. bank account held by Insurance Broker 1’s Colombian-based subsidiary made at 

least eleven wire transfers totaling at least approximately $6,510,735 to the Intermediary Company 

1 brokerage account. These payments were Introducer Company 1’s commissions from the 

corruptly obtained reinsurance policies with Seguros Sucre to insure MOD and other state-owned 

entities of Ecuador. Based on their prior agreement, the defendant received a portion of these

commissions in exchange for having used his official positions to assist Insurance Broker 1 obtain 

and retain the reinsurance policies from Seguros Sucre. 

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The Money Laundering Related to Scheme 1

Between in or around June 2014 and in or around June 2016, the defendant and his coconspirators engaged in the following money laundering scheme. Gomez and Heinert, with the aid 

of Financial Advisor, caused the Intermediary Company 1 brokerage account, which was funded 

almost exclusively with Insurance Broker 1 commission payments to Introducer Company 1, to

transfer at least approximately $682,000 in cash and $1,975,000 worth of securities ($2,657,000 

total value) to a bank account in Switzerland held by a nominee company for the benefit of the 

defendant (“Intermediary Company 2 brokerage account”). All but one of these transfers were 

made though U.S.-based accounts held by a Cayman Islands company (“Intermediary Company 

3”).

Through its Swiss-based brokerage account, Intermediary Company 2 laundered a portion 

of the approximately $2,657,000 it received through Intermediary Company 3 to U.S.-based 

accounts controlled by the defendant, including at least approximately $450,000 into U.S.-based 

accounts held by the defendant and at least approximately $254,000 into U.S.-based accounts held 

jointly by the defendant and his relatives. 

Separately, on or about December 18, 2014, the defendant and his co-conspirators also 

laundered approximately $300,000 of Insurance Broker 1 commission payments received by the 

Intermediary Company 1 brokerage account through Intermediary Company 3 to a U.S.-based 

bank account held in the defendant’s name.

The defendant had at least one meeting with Moncaleano, Gomez, Heinert and other coconspirators in Miami, Florida to discuss illegal bribery scheme 1 and the related money 

laundering scheme. 

Overview of Criminal Schemes Involving Reinsurance Brokers 1 and 2 (Scheme 2)

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Between in or around 2014 and in or around 2016, certain individuals associated with 

Introducer Company 2 and others knowingly and willfully agreed to offer, give, and promise an 

improper economic benefit of at least approximately $2,079,465 in bribes to the defendant, an 

Ecuadorian public servant, in order to carry out, omit, expedite, delay or condition matters related 

to his functions, that is to assist Reinsurance Broker 1 and Reinsurance Broker 2 in obtaining and 

retaining business with Seguros Sucre (“illegal bribery scheme 2”). 

Further, from in or around 2014 and continuing until at least 2016, the defendant knowingly 

and willfully conspired with others, including an agent of Introducer Company 2, to conceal and 

disguise the nature, location, source, ownership, and control of the proceeds of illegal bribery 

scheme 2 and the corruptly obtained contracts. The defendant knew that this conduct was 

unlawful.

Specifically, between in or around 2014 and in or around 2016, Introducer Company 2 

received commission payments from Reinsurance Broker 1 and Reinsurance Broker 2 on corruptly 

obtained business with Seguros Sucre. The defendant’s co-conspirators then laundered a portion 

of the commissions to the defendant, including to accounts held in the defendant’s name, the names 

of the defendant’s relatives, and the name of a nominee account holder for the defendant’s benefit. 

The defendant and his co-conspirators laundered at least approximately $2,079,465 of the 

commissions through bank accounts in the United States for the benefit of the defendant. In 

furtherance of the conspiracy, and with the intent to conceal and disguise the nature, location, 

source, ownership, and control of the proceeds of illegal bribery scheme 2, the defendant and his 

co-conspirators, among other things, transferred the corrupt proceeds to and through multiple 

intermediary companies, including shell company bank accounts in Switzerland; disguised bribe 

payments through private securities purchases; and provided false justifications for transactions to 

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banks, and others. 

Illegal Bribery Scheme 2

Between in or around 2014 and in or around 2016, Reinsurance Broker 1 and Reinsurance 

Broker 2 obtained business from Seguros Sucre. The defendant approved the award of this 

business in return for bribe payments which were made by Introducer Company 2. Reinsurance 

Broker 1 and Reinsurance Broker 2 paid commissions on this business to Introducer Company 2. 

The defendant and his co-conspirators agreed that a portion of the commissions Introducer 

Company 2 received would be passed to the defendant, in exchange for the defendant using his 

official position to secure an improper advantage in order to assist the Introducer Company 2 in 

obtaining and retaining business for Reinsurance Broker 1 and Reinsurance Broker 2 from Seguros 

Sucre. 

The Money Laundering Scheme 2

Between in or around July 2014 and in or around January 2016, the defendant and his coconspirators engaged in the following money laundering scheme. The defendant and his coconspirators, with the aid of Financial Advisor, caused Introducer Company 2 to transfer at least 

approximately $2,079,465 to accounts held by or for the benefit of the defendant. The accounts 

included Intermediary Company 2, and two additional U.S.-based accounts held by or for the 

benefit of the defendant (“Intermediary Company 4” and “Intermediary Company 5”). 

Specifically, between in or around October 2015 and in or around January 2016, the 

defendant and his co-conspirators caused Introducer Company 2 to transfer at least approximately 

$905,627 to Intermediary Company 2 brokerage account for the benefit of the defendant. From 

between in or around July 2014 and in or around August 2015, the defendant and his coconspirators caused Introducer Company 2 to transfer at least approximately $1,038,897 to 

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