A Florida resident and dual U.S.-Colombian citizen, Gilda Rosenberg, has been sentenced to 30 months in prison for her role in a conspiracy to defraud the United States by hiding more than $90 million from the Internal Revenue Service (IRS). According to court documents, Rosenberg and two family members concealed assets and income in undeclared bank accounts across Andorra, Israel, Panama, and Switzerland between 2010 and 2022.
Rosenberg’s family began maintaining offshore accounts in the 1970s. By the late 1990s, Rosenberg was listed as an owner and authorized signer on some of these accounts. She was aware that neither she nor her relatives had disclosed their ownership of these foreign financial accounts to U.S. authorities or paid taxes on related income as required by law.
In the early 2000s, the family consolidated their assets at Credit Suisse accounts in Switzerland and the United Kingdom. Family members informed Credit Suisse employees that they were U.S. persons attempting to hide their assets from American authorities. The assets remained there until 2013 when Credit Suisse closed the accounts due to their U.S. citizenship status.
Following this closure, the family transferred their assets—often held under nominee entities—to new accounts at Bank Leumi in Israel, Union Bancaire Privée (UBP) and PKB Privat Bank SA in Switzerland, as well as a bank in Andorra. Documentation identified Rosenberg as the beneficial owner of certain accounts at UBP and the Andorran bank. She also signed false account opening documents claiming Colombian citizenship only.
Neither Rosenberg nor her relatives filed Reports of Foreign Bank and Financial Accounts (FBARS), which are mandatory for such holdings. They continued filing false tax returns omitting offshore asset income.
In or around 2017, seeking to evade further tax reporting obligations, Rosenberg and her family divided their assets and created documentation suggesting that offshore holdings had been gifted to another relative who had renounced his U.S. citizenship. They attempted covert transfers back into the United States using fake loan and investment records to disguise these movements.
From 2010 through 2017, Rosenberg filed false tax returns excluding income earned from concealed foreign assets at UBP. For tax years spanning from 2009 through 2017, unreported income attributed to Rosenberg and two co-conspirators totaled over $5.5 million with an estimated tax loss exceeding $1.9 million.
Before sentencing, Rosenberg agreed to pay restitution totaling $1,927,342 plus interest to the IRS for unpaid taxes on undisclosed foreign earnings; she also accepted a civil penalty of nearly $5.86 million for failing to file FBARs as required by law.
Rosenberg previously pleaded guilty in Texas federal court for conspiracy related to wire fraud involving false reports intended to avoid paying commissions owed under contract with military retail services.
“Acting Deputy Assistant Attorney General Karen E. Kelly of the Justice Department’s Tax Division and U.S. Attorney Hayden P. O’Byrne for the Southern District of Florida made the announcement.”
“IRS Criminal Investigation’s International Tax & Financial Crimes Unit investigated the case. The Justice Department’s Office of International Affairs provided critical assistance in obtaining important evidence.”
“Senior Litigation Counsel Mark Daly and Trial Attorney Marissa Brodney of the Tax Division, as well as Assistant U.S. Attorney Ana Maria Martinez for the Southern District of Florida, prosecuted the case.”
