A dual citizen of the United States and Colombia residing in Florida has pleaded guilty to charges related to a conspiracy aimed at defrauding the United States. This conspiracy involved the concealment of substantial undeclared foreign financial accounts, the submission of fraudulent tax returns, and the evasion of tax obligations.
Court documents reveal that between 2010 and 2022, Gilda Rosenberg, a resident of Golden Beach, Florida, collaborated with two family members to hide assets exceeding $90 million from the IRS. These assets were held in undisclosed bank accounts located in Andorra, Israel, Panama, and Switzerland.
The Rosenberg family had been managing offshore accounts since the 1970s. By the late 1990s, it became apparent that Rosenberg, identified as an owner and authorized signer on certain accounts, was aware that neither she nor her family members had reported their ownership of these foreign accounts to the U.S. government or paid taxes on the income derived from these assets as mandated by law.
In the early 2000s, the family centralized their holdings within accounts at Credit Suisse in Switzerland and the United Kingdom. They informed Credit Suisse employees of their status as U.S. persons while attempting to obscure their assets from U.S. authorities. These accounts were ultimately closed in 2013 due to their status as U.S. persons.
Following the closure of their accounts at Credit Suisse, the family transferred their assets—often registered under nominee entities—to new accounts at Bank Leumi in Israel, Union Bancaire Privée (UBP), PKB Privat Bank SA in Switzerland, and an Andorran bank. Rosenberg was listed as the beneficial owner of accounts at UBP and the Andorran institution. She also signed misleading documents claiming Colombian residency to disguise her U.S. citizenship.
Rosenberg and her relatives failed to submit Reports of Foreign Bank and Financial Accounts (FBARS) to disclose their offshore financial holdings, as legally required. Furthermore, they continued to file inaccurate tax returns that omitted income generated from these concealed offshore assets.
Around 2017, as part of their ongoing efforts to evade U.S. tax and reporting responsibilities, Rosenberg and her family members executed a division of their assets and crafted documents to suggest that offshore assets had been gifted to another relative who had renounced his U.S. citizenship. They then attempted to secretly transfer assets back to Rosenberg in the United States while obscuring their persistent tax evasion history. To facilitate this, they created fictitious loan and investment documents to misrepresent these transfers as legitimate transactions.
Between 2010 and 2017, Rosenberg submitted false tax returns that did not report income accrued from her concealed accounts at UBP. The unreported income for Rosenberg and two accomplices amounted to over $5.5 million for the tax years 2009 through 2017, resulting in a tax loss of $1,927,342.
Rosenberg is set to receive her sentence on May 30. She faces a potential maximum sentence of five years imprisonment along with supervised release, restitution, and monetary penalties. The final sentencing will be determined by a federal district court judge, taking into account the U.S. Sentencing Guidelines and other relevant statutory considerations.
Previously, Rosenberg entered a guilty plea in the Eastern District of Texas concerning a conspiracy to commit wire fraud linked to deceptive practices against the Army and Air Force Exchange Service (AAFES), involving false reports to evade full payment of owed commissions (United States v. Rosenberg, 4:24-cr-00062-ALM-AGD).
This announcement was made by 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.
The investigation is being conducted by IRS Criminal Investigation’s International Tax & Financial Crimes Unit, with significant assistance provided by the Justice Department’s Office of International Affairs in gathering crucial evidence.
The prosecution is led by Senior Litigation Counsel Mark Daly, Stan Okula, Trial Attorney Marissa Brodney from the Tax Division, and Assistant U.S. Attorney Ana Maria Martinez for the Southern District of Florida.
