In the high drama of a federal property court in Miami, Gilda Rosenberg, a dual U.S.-Colombian citizen from Golden Beach, Florida, was sentenced to 30 months for masterminding a decades-long scheme to conceal from the Internal Revenue Service (IRS) over $90 million in foreign bank accounts.
Scheme overview
Between 2010 and 2022, Rosenberg and two family members maintained undisclosed financial accounts in Andorra, Israel, Panama, and Switzerland. Having used the offshore accounts since the 1970s, Rosenberg-an owner and authorized signatory on some accounts-knew by the late 1990s that neither she nor her relatives had reported these holdings or paid U.S. taxes on income derived from them.
In furtherance of their efforts to avoid detection, the co-conspirators:
- Filed false U.S. tax Returns through which income from these accounts was not reported.
- Did not file Reports of Foreign Bank and Financial Accounts (FBAR) as required.
- Created sham documents for “loans” and “investments” in order to disguise the transfers into accounts in the United States.
By 2017, when Credit Suisse was obliged to terminate the family’s account because it knew they were U.S. persons, Rosenberg and her co-conspirators juggled assets among private banks under nominee vehicles to continue hiding their riches.
Legal charges and guilty plea
Rosenberg pleaded guilty in March 2025 to one count of conspiracy to defraud the United States. Per allegations by the Department of Justice (DOJ), the scheme caused tax losses of $1,927,342 from 2009 to 2017. Rosenberg agreed to pay that amount in restitution with interest, together with a civil penalty of $5,857,045.50 for failing to report her foreign accounts.
Sentencing details
On July 28, 2025, District Judge K. Michael Moore sentenced Rosenberg to 30 months in prison, followed by a term of supervised release. Judge Moore ordered full restitution to the United States and payment of the previously agreed civil penalties. Acting Deputy Assistant Attorney General Karen E. Kelly noted that this sentencing “reflects the seriousness of concealing such vast assets from the IRS.”
The International Tax and Financial Crimes Unit investigated this case, with critical evidence obtained through the Justice Department’s Office of International Affairs. The prosecution was led by U.S. Attorney for Southern District of Florida Hayden O’Byrne and Assistant U.S. Attorneys from the Tax Division for the Department of Justice.
Financial and legal implications
Rosenberg’s sentence demonstrates the increased focus of the U.S. government toward international tax enforcement. Under the Foreign Account Tax Compliance Act (FATCA) expected and the FBAR requirements, U.S. persons are to report their foreign financial assets and pay taxes on their worldwide income irrespective of the place they hold it. Such compliance failure can embolden a range of major criminal and civil penalties.
Worldwide financial institutions now face tough U.S. reporting obligations. Rosenberg’s multiple-jurisdictional activities serve as an example of how non-U.S. banks have tightened their compliance protocols to avoid facilitating tax evasion. Her Credit Suisse account closures in 2013 side-highlighted banks’ unwillingness to accommodate undeclared U.S. clients.
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