Seguros Sucre S. A. was the state-owned insurance company of Ecuador.
Jose Vicente Gomez Aviles, a citizen of Ecuador and a U.S. lawful permanent resident residing in Miami, was one of the owners of a Panama-registered company that operated as a reinsurance introducer ("Introducer Company"), which helped companies obtain and retain contracts with Seguros Sucre in exchange for receiving a commission. Roberto Heinert was another owner of the company.
Juan Ribas Domenech, a citizen of Ecuador, served as the Chairman of Seguros Sucre and an advisor to the President of Ecuador from at least 2013 through at least 2017.
Felipe Moncaleano Botero, a citizen of Colombia, was an executive and shareholder from 2013 to 2019 of the Colombian-based subsidiaries of an unidentified reinsurance broker and risk adviser based in the United Kingdom ("Insurance Broker").
According to the documents in this case, between 2013 and 2017, Botero approached the owners of Introducer Company about helping Insurance Broker retain the contract to provide reinsurance for Ecuador's Ministry of Defense ("MOD"), which was provided through Seguros Sucre. Following meetings, Seguros Sucre agreed to retain Insurance Broker's MOD policy. Insurance Broker and Introducer Company reached an agreement whereby Insurance Broker agreed to pay Introducer Company commissions for the won or retained contracts. A portion of the commission payments were then funneled to Domenech and his relatives through transactions involving multiple intermediary companies and securities transfers. In all, one intermediary company transferred approximately $1,432,000 in cash and $1,975,000 worth of securities to another intermediary company's brokerage account, which was held for the benefit of Domenech. Additionally, approximately $254,000 was transferred into U.S.-based accounts held by Domenech's relatives.
On February 13, 2020, the DOJ filed a criminal complaint in the Southern District of Florida against Domenech, Botero, and Aviles alleging a conspiracy to commit money laundering. The case was later severed into individual actions against the three defendants.
On April 23, 2020, the DOJ filed a single count Information against Aviles alleging the same charge. Aviles entered a plea agreement on June 11, 2020, and on October 15, 2020, the court ordered Aviles to forfeit $3,157,000, a sum for which he was jointly and severally liable with Heinert, Domenech, and Botero. On March 30, 2021, the court sentenced Aviles to 46 months in prison to be followed by 3 years of supervised release and ordered him to pay a mandatory assessment of $100.
