United States v. Jose Vicente Gomez Aviles (S.D. Fla. 2020)
United States v. Felipe Moncaleano Botero (S.D. Fla. 2020)
United States v. Juan Ribas Domenech (S.D. Fla. 2020)
United States v. Roberto Heinert (S.D. Fla. 2020)

• Case Name
• United States v. Jose Vicente Gomez Aviles (S.D. Fla. 2020)
  United States v. Felipe Moncaleano Botero (S.D. Fla. 2020)
  United States v. Juan Ribas Domenech (S.D. Fla. 2020)
  United States v. Roberto Heinert (S.D. Fla. 2020)

• Date Filed
• 04/23/2020

• Enforcement Agency
• DOJ

• Foreign Official
• Chairman of Seguros Sucre, a state-owned insurance company, and an advisor to the then-President of Ecuador (Ribas).

• Date of Conduct
• 2013 to 2017

• Nature of Business
• Jose Vicente Gomez Aviles is an Ecuador citizen and U.S. permanent resident. He owned a reinsurance company based in Miami, Florida.
  
  Seguros Sucre S.A. is a state-owned insurance company in Ecuador.
  
  Juan Ribas Domenech, a citizen of Ecuador, served as the chairman of Seguros Sucre and advisor to the President of Ecuador from 2013 to 2017.
  
  Felipe Moncaleano Botero, a Colombian citizen, was an executive of a reinsurance broker and risk adviser.
  
  Robeto Heinert, a dual U.S. and Ecuador citizen, owned a reinsurance introducer company based in Panama together with Gomez.

• Influence to be Obtained
• According to the DOJ, between 2013 and 2017, Gomez participated in a conspiracy to pay at least $3.1 million to officials at Seguros Sucre to obtain and retain business for his and Heinert’s insurance company and Moncaleano’s reinsurance brokerage. Gomez allegedly laundered payments from the reinsurance broker to Ribas, who oversaw the awarding of contracts with the SOE. Gomez allegedly agreed to use shell company bank accounts, multiple intermediary companies, and private securities purchases to send the bribe money to the government officials in exchange for insurance contracts with Seguros Sucre.

• Enforcement
• On February 12, 2020, the DOJ filed a criminal complaint against Gomez, Ribas, and Moncaleano for one count each of conspiracy to commit money laundering, On March 4, 2020, the DOJ filed a similar criminal complaint against Heinert for one count of conspiracy to commit money laundering.
  
  On June 11,2020, the DOJ announced it had entered into a plea agreement in which Gomez agreed to plead guilty to the conspiracy count. Ribas also pleaded guilty on September 16, 2020 and was ordered to forfeit $5,036,465. Gomez was sentenced to forty-six months in prison and three years of supervised release and Ribas was sentenced to fifty-one months in prison and three years of supervised release.
  
  Moncaleano pleaded guilty to one count of conspiracy to commit money laundering on August 4, 2020 and was sentenced to six years in prison and three years of supervised release. He was also ordered to pay a criminal fine of $50,000.
  
  Heinert pleaded guilty on October 2, 2020 and was sentenced to three years in prison and three years of supervised release.
  
  The defendants were also ordered to jointly and severally forfeit $3.157 million.

• Amount of the Value
• $3,157,000

• Amount of Business Related to Payment
• Not stated.

• Intermediary
• Multiple Intermediary Companies.

• Compliance Monitor
• No

• Reporting Requirements
• No

• Case is Pending?
• Yes

Jose Vicente Gomez Aviles

• Citation
• United States v. Gomez Aviles, No. 1:20-CR-20169 (S.D. Fl. 2020)

• Date Filed
• 04/23/2020

• Filed Under Seal
• No

• FCPA Statutory Provision

• Other Statutory Provision
• Conspiracy (Money-Laundering).

• Disposition
• Guilty Plea, Guilty Plea

• Defendant Jurisdictional Basis
• Domestic Concern

• Defendant's Citizenship
• Ecuador

• Individual Sanction
• Pending. 

Felipe Moncaleano Botero

• Citation
• United States v. Gomez Aviles, et al., No. 1:20-CR-20169 (S.D. Fl. 2020).

• Date Filed
• 02/12/2020

• Filed Under Seal
• No

• FCPA Statutory Provision

• Other Statutory Provision
• Conspiracy (Money-Laundering). 

• Disposition
• Guilty Plea, Guilty Plea

• Defendant Jurisdictional Basis
• Conspiracy

• Defendant's Citizenship
• Colombia

• Individual Sanction
• 6 years imprisonment; 3 years of supervised release; $50,000 fine; $3.157 million in forfeiture (jointly and severally with the co-defendants).

Juan Ribas Domenech

• Citation
• United States v. Gomez Aviles, et al., No. 1:20-CR-20169 (S.D. Fl. 2020).

• Date Filed
• 02/12/2020

• Filed Under Seal
• No

• FCPA Statutory Provision

• Other Statutory Provision
• Conspiracy (Money-Laundering)

• Disposition
• Guilty Plea, Guilty Plea

• Defendant Jurisdictional Basis
• Conspiracy

• Defendant's Citizenship
• Ecuador

• Individual Sanction
• 51 months imprisonment; 3 years of supervised release; $5.035 million in forfeiture. 

Roberto Heinert

• Citation
• United States v. Roberto Heinert, No. 1:20-CR-20187 (S.D. Fl. 2020).

• Date Filed
• 03/04/2020

• Filed Under Seal
• No

• FCPA Statutory Provision

• Other Statutory Provision
• Conspiracy (Money-Laundering).

• Disposition
• Guilty Plea, Guilty Plea

• Defendant Jurisdictional Basis
• Conspiracy

• Defendant's Citizenship
• United States

• Individual Sanction
• 3 years imprisonment; 3 years of supervised release; $3.157 million in forfeiture (jointly and severally with the co-defendants).