Case 3:25-cr-00284-RAM Document 6 Filed 07/02/25 Page 1 of 23

UNITED STATES DISTRICT COURT

DISTRICT OF PUERTO RICO

UNITED STATES OF AMERICA

v. Crim. No. 25-284-RAM

[2] JUAN CARLOS REYNOSO

UNITED STATES’ MOTION FOR DETENTION PENDING TRIAL

For years, Juan Carlos Reynoso was the general manager for Latin American of OmegaPro,

a global Ponzi scheme that raised over $650 million in virtual currency from thousands of victims.

Mr. Reynoso and his co-conspirators offered investors the opportunity to purchase, via

cryptocurrency, packages that would allegedly earn returns up to 300% in 16 months through

foreign-exchange trading. Investors were also told that they could earn commissions for recruiting

new investors. The promised returns, however, were based upon an illusory trading scheme.

Around the fall of 2022, OmegaPro allegedly suffered a cyber hack, preventing investors from

withdrawing their funds and resulting in millions of dollars in losses to victims—many of whom

live in Puerto Rico and elsewhere in the United States. Mr. Reynoso and his OmegaPro co-

conspirators, however, profited richly from their fraud. The Government’s cryptocurrency tracing

has indicated that, between May 2021 and December 2022, over $11 million USD was transferred

from accounts associated with OmegaPro victim funds to a Binance account associated with Mr.

Reynoso. His co-conspirators likewise transferred tens of millions of dollars in OmegaPro

investors funds to their personal accounts.

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The United States respectfully moves for pretrial detention of Juan Carlos Reynoso

pursuant to 18 U.S.C. § 3142(e) because there is no combination of conditions that will reasonably

assure Mr. Reynoso’s appearance, based on a preponderance of the evidence. A detention hearing

is warranted because Mr. Reynoso presents a serious risk of flight. See 18 U.S.C. § 3142(f)(2)(A).

Given his history of violating a court order, the substantial time he spends abroad, and his ability

to access sizable funds overseas, Mr. Reynoso can readily choose a life overseas rather than facing

the consequences of his conduct here in the United States. In particular:

- Mr. Reynoso has already demonstrated contempt for a judicial order related to the
OmegaPro scam. To date, he has incurred over $1,110,000 in fines pursuant to a civil
contempt order in the District of Puerto Rico in 3:25-mc-00068. The funds that the
Government sought to seize (and that Mr. Reynoso diverted and concealed) were
OmegaPro victim funds.

- Mr. Reynoso is a dual Peruvian-U.S. citizen with an extensive history of travel. This
includes 68 trips to 21 different, foreign destinations between 2020 and June of 2025.
He spends extensive periods outside of the United States. The address of his U.S.
residence provided to U.S. Probation is listed online for sale.

- Mr. Reynoso has extensive assets readily transferable across borders. Between
February 2021, and December 2023, more than $21,400,000 USD equivalent of
various kinds of cryptocurrency were deposited into Mr. Reynoso’s Binance account.
He has ties to over-the-counter brokers in Latin America to convert cryptocurrency
into fiat of his choice.

- Mr. Reynoso has ties to human traffickers. In 2024, he paid thousands of dollars for
his Colombian girlfriend and Peruvian cousin to be smuggled via boat into Florida.

- If convicted at trial of the charges against him, Mr. Reynoso faces a maximum penalty
of 20 years in prison on each of the two counts in the indictment. This creates an
incentive to flee.

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Legal Background

Under the Bail Reform Act, 18 U.S.C. §§ 3141 et seq., federal courts can order a

defendant’s detention pending trial upon a determination that the defendant is either a danger to

the community or a risk of flight. 18 U.S.C. § 3142(e). A court’s finding that a defendant poses a

risk of flight must be supported by a preponderance of the evidence. See, e.g., United States v.

Iglesias-Benitez, 974 F.2d 1329, at *3 (1st Cir. 1992) (unpublished); United States v. Valentin-

Rosa, 740 F. Supp. 2d 289, 291 (D.P.R. 2010).

In evaluating whether there are conditions of release that will reasonably assure the

appearance of the defendant, the Court must take into account the following: (1) the nature and

circumstances of the crimes charged; (2) the weight of the evidence against the person; (3) the

history and characteristics of the defendant, including the person’s “character . . . [and] financial

resources”; and (4) the seriousness of the danger posed by the defendant’s release. 18 U.S.C.

§ 3142(g).

Evidentiary rules do not apply at detention hearings, and the Government is entitled to

present evidence by way of proffer. See 18 U.S.C. § 3142(f)(2) (“The rules concerning

admissibility of evidence in criminal trials do not apply to the presentation and consideration of

information at the hearing.”); United States v. Femia, 983 F.2d 1046 (1st Cir. 1993) (“[Defendant’s]

objection that a judicial officer may not order detention on the basis of a mere proffer of evidence

by the government is simply not correct.”); United States v. LaFontaine, 210 F.3d 125, 130-31 (2d

Cir. 2000) (“proffers are permissible both in the bail determination and bail revocation contexts”).

Where a judicial officer concludes after a hearing that “no condition or combination of

conditions will reasonably assure the appearance of the person as required and the safety of any

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other person and the community, such judicial officer shall order the detention of the person before

trial.” 18 U.S.C. § 3142(e)(1).

Discussion

I. The Nature/Circumstances of the Offense, as Well as the Weight of the Evidence

Favor Detention.

The United States has charged Mr. Reynoso with wire-fraud and money-laundering

conspiracies in violation of 18 U.S.C. §§ 1343, 1349 and 1956(h). According to the Indictment,

from 2018 through 2025, Mr. Reynoso and others operated a massive, global Ponzi scheme that

promised investors a 300% return after 16 months. The investments were made via cryptocurrency

and allegedly handled by foreign-exchange traders. Known as “OmegaPro,” the scheme raised

over $650 million from thousands of investors between July 2019 and November 2022. Many of

these were in Latin America, including several in Puerto Rico. OmegaPro collapsed in November

2022, when its leaders announced that the platform had been hacked, after which investors were

unable to withdraw funds. Victims lost millions of dollars.

Below are screenshots from OmegaPro’s promotional materials:

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Mr. Reynoso was the general manager for Latin America (including Puerto Rico) of

OmegaPro.

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In a draft manuscript for an autobiography entitled “El Reyno del Éxito,” Mr. Reynoso

detailed his involvement in OmegaPro and acknowledged that he spends much of his time outside

of the United States. He explained reviewing one and two-year plans for OmegaPro with other

leaders in Miami; his role as the General Manager for Latin America; and his promotional work

for the company. These included drafting marketing language for OmegaPro, as evidenced in the

below chat messages in which Mr. Reynoso discussed the translation into Spanish of OmegaPro’s

promised “300% return”:

[5/14/19 2:59:46 PM] Dilawar: @[phone number redacted] can you check this pls

[5/14/19 3:04:11 PM] Carlos Reynoso Juan: Ok I will check sms get back

[5/14/19 4:59:20 PM] Carlos Reynoso Juan: I did change the wording to 300% de retorno

[5/14/19 5:00:07 PM] Carlos Reynoso Juan: Before it was saying up to 300% return

Mr. Reynoso specifically targeted investors in Puerto Rico, including in a video recorded

at an OmegaPro event in Dubai and via weekly Zoom calls made available to investors in the

United States. A screenshot of one call is below 1:

1
The English translation is “EXPERTS IN FIAT MONEY - LICENCE FOR 16 MONTHS”
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 Case 3:25-cr-00284-RAM Document 6 Filed 07/02/25 Page 7 of 23

Mr. Reynoso’s presentations, many of which were distributed online, 2 make numerous

false claims in Spanish, including the following:

- People entered into the “cloud” to work with OmegaPro, which operated in the a-
legal world of the Internet. In the metaverse, there were investment funds where laws
did not yet exist. There was no need for investors to be concerned when a
government agency stated that OmegaPro was not regulated. Governmental agencies
that criticized OmegaPro were misguided because OmegaPro existed in another
dimension beyond national regulation. Investors could not wait for a country to
conclude that OmegaPro was legal. Everyone else would be getting rich.

- No one had ever lost money in the history of OmegaPro. 100% of people who
invested in OmegaPro gained profits because it invested in the most stable market
that currently exists: foreign exchange. This is a regulated market that is safe. This
market is not affected by pandemics or wars.

- OmegaPro was operating pursuant to legitimate licenses. OmegaPro was supported

by a bank in England, which showed that OmegaPro was legal. It allegedly had to
submit to strict U.K. regulations that required due diligence.

- OmegaPro gained returns every day by maximizing small, daily profits and
minimizing risks. Its goal was to earn 1% a day, which resulted in 16-17% monthly
gains that could be shared with investors. According to Mr. Reynoso, that has been
the return every month, without fail, for 3.5 years.

- The governmental warnings about OmegaPro were perfectly normal and did not mean
that OmegaPro was a fraud or was engaging in illegal activities

Mr. Reynoso promoted the scheme, despite red flags discussed in private, as reflected in

these messages with other leaders of the scheme:

[8/11/19, AM] Carlos Reynoso Juan: There is some doubts growing with some
groups because we didn'tt have the MT4 and we don't have any accounts to show for
over one month. We talk transparency but basically have nothing to show that is
current and some leaders are concern...l don't know why we are delaying so much

2
See, e.g., https://www.youtube.com/watch?v=5UViO90cOyE;
https://www.youtube.com/watch?v=6hkOi1Vyips

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 Case 3:25-cr-00284-RAM Document 6 Filed 07/02/25 Page 8 of 23

with these MT4

[8/11/19, 1 AM] Mike S.. They can't see the fxbook?

[8/11/19, 1:03:51 AM] Andreas: I talked to them and on Monday it should all be
settled, we have been putting a lot of pressure on the tram to deliver the MT4

[8,111/19, AM] Mike What groups are there doubts with? I haven't heard this and I
communicate with several leaders.

[8/11/19, AM] Mike S.: Trading is going really great.

[8/11/19, AM] Carlos Reynoso Juan: No there is no FXbook current

[8/11/19, 1:06.29 AM] Carlos Reynoso Juan: I have been in zooms and new people
want to see some accounts that are current but we can only show stuff that is 2
months old.

[8/11/19, 1 AM] Carlos Reynoso Juan: And the question always comes up. Why we
dont have anything to show for these last 2 months?

- ***
[6/27/19, 1 AM] Carlos Reynoso Juan: Guys I just found out that the address in our
website is not real…someone went to that address and they said it doesn't exist….is
that right?

[6/27/19, 1 AM] Dilawar: Thats a company registration adress. We don't Show the
adress from the trading office!

[6/27/19, 1:41:26 AM] Dilawar: Otherwise til now the Person could have planed
another mlm System with them

[6/27/19 3:13:34 AM] Andreas: This is the contact address, mail calls etc. They are
received and sent to our real address. Basically a virtual address/PO box

[6/27/19, 3:13:59 AM] Andreas The main reason is like Dilawar said, otherwise some
idiot win end up there and start asking questions etc

The Government’s cryptocurrency tracing has indicated that, between May 2021 and

December 2022, over $11 million USD was transferred from accounts associated with OmegaPro

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victim funds to a Binance account associated with Mr. Reynoso. He publicized his lavish lifestyle

online, including in the following images showing his use of luxury cars and a private plane:

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II. Mr. Reynoso’s Past and Recent Schemes

Mr. Reynoso’s involvement in OmegaPro forms part of a series of similar scams. He

previously promoted the following:

- Mr. Reynoso promoted AirBit Club. Founded in 2015, AirBit Club was a
“multimillion-dollar pyramid scheme that preyed on mostly unsophisticated investors
with false promises that their money was being invested in cryptocurrency trading
and mining. Instead of investing on behalf of investors, [AirBit Club] hid victims’
money in a complex laundering scheme using Bitcoin, an attorney trust account, and
international front and shell companies….” 3 Mr. Reynoso was not criminally charged
in connection with AirBit Club. In an interview with government agents, Mr.
Reynoso acknowledged that AirBit Club was a Ponzi scheme and that he never saw
evidence of the supposed cryptocurrency trading.

- In 2017, Mr. Reynoso co-founded (with other former AirBit Club promoters) another
scheme, Crypto World Evolution. It allegedly sold a license to a trading bot that was
linked to cryptocurrency exchanges. The company went out of business when the
cryptocurrency market declined.

- Around 2017, IcomTech launched and purported to be a cryptocurrency mining and

trading company. It promised profits in exchange for investors’ purchase of purported
cryptocurrency-related investment products. Mr. Reynoso served as the CEO for a
brief period. According to a DOJ press release, IcomTech “falsely promised their …
Victims, among other things, that profits from the companies’ cryptocurrency trading
and mining would result in guaranteed daily returns on Victims’ investments and
doubling their money within six months. In reality, IcomTech did not engage in
cryptocurrency trading or mining for its Investors, and [IcomTech]… used Victim funds
to pay other Victims, to further promote the schemes, and to enrich themselves.” 4 Mr.
Reynoso was not charged in connection with IcomTech. In an interview with
government agents, Mr. Reynoso acknowledged that IcomTech was a Ponzi scheme.

- Towards the end of OmegaPro, Reynoso began promoting a scheme called “TeaMiner.”
Mr. Reynoso told one colleague in November 2023 that TeaMiner would be “10x”

3
https://www.justice.gov/usao-sdny/pr/co-founder-global-multimillion-dollar-cryptocurrency-
ponzi-scheme-airbit-club
4
https://www.justice.gov/usao-sdny/pr/two-defendants-sentenced-10-years-and-eight-years-
prison-cryptocurrency-ponzi-scheme
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bigger than OmegaPro. TeaMiner promised unrealistic returns consistent with those
offered by OmegaPro.

III. Mr. Reynoso Presents a Risk of Flight Because He Has an Extensive History of
Travel and Dual Citizenship.

Mr. Reynoso is a Peruvian and American dual citizen who resides in New Jersey. His

international travel between 2020 and June of 2025 has included the following 68 trips to 21 unique

destinations:

Month/Year Airport (initial destination from U.S.)

June 2025 Panama
March 2025 Medellin
December 2024 Panama
October 2024 Bahamas
September 2024 Panama (two separate occasions in
September)
August 2024 Amsterdam
July 2024 Panama
June 2024 London
June 2024 Barranquilla
May 2024 Panama
April 2024 Panama
April 2024 Bahamas
February 2024 Costa Rica
January 2024 Barranquilla
December 2023 Panama
November 2023 Panama (two separate occasions in
November)
October 2023 Panama
September 2023 Panama
August 2023 Panama
August 2023 Dubai
July 2023 Lima
June 2023 Panama
March 2023 Mexico
February 2023 Mexico (two separate occasions in
February)
January 2023 Cancún
January 2023 Dubai
December 2022 Panama
December 2022 Costa Rica

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November 2022 Paris

November 2022 Mexico
November 2022 Dominican Republic
October 2022 Madrid
October 2022 Dominican Republic
September 2022 Bogotá
September 2022 Dominican Republic
August 2022 Bogotá
August 2022 Madrid
July 2022 Lima
June 2022 Iceland
June 2022 Panama
May 2022 Cancún
April 2022 Bogotá
March 2022 Cancún
March 2022 Punta Cana
February 2022 Bogotá
January 2022 Paris
November 2021 Bogotá
September 2021 Bogotá
September 2021 Dubai
August 2021 Lisbon
July 2021 Panama
July 2021 Cancún
June 2021 Amsterdam
May 2021 Costa Rica
May 2021 Cancún
March 2021 Lima
March 2021 Punta Cana
January 2021 Bogotá
December 2020 Lima
December 2020 Bogotá
December 2020 Cancún
November 2020 Cancún
October 2020 Frankfurt
August 2020 Lima
June 2020 Ecuador
March 2020 Nicaragua
February 2020 Lima
January 2020 Bogotá

The Pretrial Services Report from the Southern District of Florida (25-mj-3285) also

notes that Mr. Reynoso partially owns a “family home in Peru.” (p. 2)

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It is noteworthy that another OmegaPro executive assumed an alternative identity in a

foreign country less accessible to U.S. law enforcement. Mr. Reynoso’s former colleague,

Andreas Szakacs, who was the CEO of OmegaPro and a Swedish national, changed his name to

“Emre Avci” and obtained citizenship in Turkey, where he is believed to currently reside. Article

4 of the 1979 United States-Turkey Extradition Treaty provides that Turkey is not bound to

extradite its nationals to the United States. See Extradition Treaty Between the United States of

America and the Republic of Turkey, U.S.–Turk., signed June 7, 1979, entered into force Jan. 1,

1981, 32 U.S.T. 3111, T.I.A.S. No. 9856 Given this and Mr. Reynoso’s history, there is

heightened concern about his risk of flight.

IV. Mr. Reynoso Presents a Risk of Flight Because of His Contempt for Judicial
Orders: He Is Subject to a Contempt Order in This District in 3:25-mc-00068
and Has Incurred Over $1,110,000 in Fines.

In March 2025, a court in this district held Mr. Reynoso in civil contempt for a “flagrant

violation of [a seizure] warrant.” See 25-mc-68-FAB (Dkt. No. 20) at p. 22. The Court found

that Mr. Reynoso had deliberately placed the Bitcoin subject to the seizure warrant “beyond the

United States’ reach” and otherwise obstructed the seizure warrant. Id.

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That seizure warrant involved millions of dollars of OmegaPro victim funds. Instead of

complying, Mr. Reynoso was involved in moving the cryptocurrency funds through a variety of

addresses, as depicted below:

Mr. Reynoso was therefore non-compliant in a matter directly relevant to this case.

As a result of Mr. Reynoso’s conduct, the Court ordered Mr. Reynoso to transfer the assets

subject to the seizure warrant—199.65 BTC (approximately $21,475,155 USD)—to a

government-controlled wallet and imposed a fine of “$10,000.00 for every day that he violates the

seizure warrant from the date that this Opinion and Order is published. Failure to comply may

result in additional fines and/or incarceration.” Id. at p. 22. As of the filing of this motion, Mr.

Reynoso has failed to pay a penny of the fines that he has accrued since March 4, 2025. At $10,000

per day, Mr. Reynoso currently owes over $1 million.

Mr. Reynoso has appealed this decision to the United States Court of Appeals for the First

Circuit. See 25-1328. In May 2025, the Court of Appeals ordered Mr. Reynoso “to show cause

why this appeal should not be dismissed for lack of jurisdiction.” Mr. Reynoso filed a response

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and an appellate brief. The Court of Appeals has not ruled on the question of its jurisdiction or set

a briefing schedule.

This behavior demonstrates Mr. Reynoso’s unwillingness to comply with the justice system

in a matter related to OmegaPro: a key concern that underscores his serious flight risk.

V. Mr. Reynoso Presents a Risk of Flight Because of Extensive, Liquid Assets

Readily Transferable Across Borders.

The Government’s cryptocurrency tracing indicates that Mr. Reynoso moves significant

volumes of assets frequently through over-the-counter brokers in Latin America. Between

February 2021 and December 2023, more than $21,400,000 USD equivalent of various kinds of

cryptocurrency were deposited into Mr. Reynoso’s Binance account(s). In addition to custodial

accounts (i.e., assets stored in exchanges), Mr. Reynoso extensively uses non-custodial wallets, in

which the funds are globally accessible from any Internet connection, cannot readily be frozen or

seized, and can be used to self-fund any international flight by Mr. Reynoso. In addition, he uses

decentralized instant swap services, which do not conduct due diligence of their customers (i.e.,

KYC checks).

Below is one example of the multiple “hops” from an address beginning bc1qs6z,

representing OmegaPro victim funds, which flow through non-custodial wallets and an exchange

to addresses associated with Mr. Reynoso (after being converted from Bitcoin to Tether):

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In this chart, the center address bc1qa2 (which was directly tied to Mr. Reynoso via a seed

phrase 5 found on devices seized from him) contains OmegaPro victim funds. On March 18, 2025,

address bc1qa2 sent 0.31238226 BTC (~26,247.95688 USD) to Changelly—a non-custodial

cryptocurrency exchange service that allows users to swap cryptocurrencies with looser KYC

requirements. The corresponding outflow from Changelly (after Bitcoin had been converted to

Tether) was to address TLw9M, which received 24,895.215105 USDT on the Tron platform on

March 18, 2025. Several characteristics of this transaction indicate Mr. Reynoso’s serious flight

risk:

• The use of cryptocurrency swaps via Changelly assists in obfuscating asset origin using a

non-custodial, less heavily regulated exchange.

• The cross-chain conversion (moving Bitcoin to Tron) makes tracing more difficult.

• Quick movements of funds that incur transaction fees without seeming to achieve any

legitimate financial purpose suggest concealment and an attempt to distance assets from

victims.

5
A “seed phrase” (also called a “recovery phrase” or “mnemonic phrase”) is a sequence of 12 to
24 words used to back up and recover a cryptocurrency wallet. It represents the master key to
access all the private keys in the wallet.
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Upon Mr. Reynoso’s arrest on June 30, he possessed crypto currency cards, including

“Futcard” and “SDEFI” card. These cards are described online as allowing the user to “[g]o to

any ATM and convert your digital assets into cash in your local currency.” 6 These cards are

marketed to “[t]ravelers who need a flexible, global payment solution.”

Upon his arrest, Mr. Reynoso was also carrying the equivalent of more than $5,000 USD

in cash, consisting of $100 USD bills and Peruvian soles.

Overall, the cryptocurrency profile of Mr. Reynoso demonstrates access to substantial

financial resources, sophisticated knowledge of international financial systems, and the ability to

rapidly transfer wealth across borders. These factors indicate that Mr. Reynoso poses a serious risk

of flight under 18 U.S.C. § 3142, as he has both the means and opportunity to flee and sustain

himself abroad.

6
https://futswap.se/futcard/
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VI. Mr. Reynoso Presents a Risk of Flight Because of Contacts with Human
Smugglers.

Based upon the Government’s investigation, Mr. Reynoso paid traffickers thousands of

dollars in 2024 to smuggle his Colombian girlfriend, Mary Capacho Ulloa, and a Peruvian cousin,

Jorge Gonzalez Reynoso, into Florida via a boat. When arrested upon her illegal entry on October

15, 2024, by police in Ocean Ridge, Florida, Ms. Capacho Ulloa had a photo of Mr. Reynoso. She

identified Mr. Reynoso as the person who organized and paid for her illegal passage from the

Bahamas to Florida. She stated that one thousand dollars was paid via Western Union, and $8,000

was paid in cash. Consistent with these statements, the Government confirmed that Mr. Reynoso

traveled from Miami to Nassau, Bahamas on October 11, 2024, and returned to Miami on October

13. Mr. Reynoso has not yet been charged related to this incident.

This conduct demonstrates a willingness to engage in illegal cross-border activity and

disregard for immigration laws, indicating a heightened risk that Mr. Reynoso would flee to avoid

prosecution. While Mr. Reynoso’s conduct described above involves smuggling individuals into

this District, his connection to foreign nationals and willingness to circumvent legal processes

further suggest he has the means and motive to flee and evade court proceedings under 18 U.S.C.

§ 3142.

VII. Missing Peruvian Passport

Based on information provided by federal agents, Mr. Reynoso was arrested at the Miami

airport on June 30, 2025 with a U.S. passport. Records indicate that he left the United States

around June 13 on a Peruvian passport. Nonetheless, his Peruvian passport was not seized on

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 Case 3:25-cr-00284-RAM Document 6 Filed 07/02/25 Page 19 of 23

him. 7 As a result, Mr. Reynoso may have access to an active foreign passport that could be used

for international travel.

VIII. Red Flags in the Pretrial Services Report from the Southern District of Florida

The Pretrial Services Report (“PSR”) in 25-mj-3285 (S.D.Fl.) notes that Mr. Reynoso is a

risk of non-appearance for reasons that include “unexplained assets related to cryptocurrency” and

“strong family ties to Peru.” (p. 3) The PSR raises several more concerns, including the following:

• Evasiveness regarding crypto assets: Mr. Reynoso “[d]eclined to answer” U.S. Probation’s

questions related to his cryptocurrency assets. (PSR at p. 2)

• Home address provided by Mr. Reynoso Is Listed for Sale: The home address in Miami

provided by Mr. Reynoso to U.S. Probation in the PSR is listed for sale online for $2.19 million

and is described as “Seller motivated!!!!”. See https://www.zillow.com/homedetails/1556-

71st-St-Miami-Beach-FL-33141/43877722_zpid/

• Bank accounts not revealed to U.S. Probation: In the PSR, Mr. Reynoso only lists a single

bank account: Bank of America. (p. 2) That is misleading for the following reasons:

o He was arrested with a debit card in his name from the bank BBVA.

o He was also arrested with a debit card in the name of someone else from the

Panamanian bank Banesco.

7
The Pretrial Services Report (p. 1) states that both “Mr. Reynoso’s American and Peruvian
passports are with the arresting agents.” Based on conversations with law enforcement, that
appears to be inaccurate. In addition, the PSR states that Mr. Reynoso was born in 1987. (p. 1)
In fact, he was born in 1967.
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 Case 3:25-cr-00284-RAM Document 6 Filed 07/02/25 Page 20 of 23

o Mr. Reynoso stated that he is the owner of the “digital marketing consulting firm,”

Reyfer Digital Corp. (p. 2) In chats reviewed by the Government from September

2022, Mr. Reynoso referred to Reyfer Digital Corp. as “my business name”: 8

He is even sometimes addressed as “Mr. Reyfer,” as in this message from 2022 (Mr. Reynoso’s

message is in green):

Reyfer Digital has an account at a South Korean commercial bank, KEB Hana Bank.

• According to the PSR, Mr. Reynoso claims to earn $15,000 to $25,000 per month. That is his

only reported source of income. (p. 2) But, as noted above, between May 2021 and December

2022, over $11 million USD was transferred from accounts associated with OmegaPro victim

8
The mailing address for Reyfer Digital with Florida’s Division of Corporations is the same
address for Mr. Reynoso’s home listed in the PSR. Compare PSR at p. 1 with
https://search.sunbiz.org/Inquiry/corporationsearch/SearchResultDetail?inquirytype=EntityName
&directionType=ForwardList&searchNameOrder=REYFERDIGITAL%20F240000057410&agg
regateId=forp-f24000005741-d669b0b9-ca3f-4741-a522-
a81f347ea278&searchTerm=R.E.Y.%20FAMILY%20HOLDINGS%2C%20LLC&listNameOrde
r=REYFAITH%20L240002285350
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 Case 3:25-cr-00284-RAM Document 6 Filed 07/02/25 Page 21 of 23

funds to Mr. Reynoso’s Binance account(s). His wealth is not consistent with his reported

income.

Conclusion

Juan Carlos Reynoso presents an extreme risk of flight because of ample and highly mobile

financial resources, extensive international ties and relationships with human smugglers. He will

not comply with conditions imposed by the Court, as demonstrated by the contempt order against

him in this district, as well as unpaid fines in excess of one million dollars in a matter related to

the OmegaPro scheme. He has a motive to flee because he is facing a lengthy prison sentence in

a case where the weight of the evidence against him is strong.

There are no conditions of bail that would assure his presence in court proceedings in this

case. Accordingly, any application for bail should be denied.

In San Juan, Puerto Rico, this 2nd day of July 2025.

W. STEPHEN MULDROW
United States Attorney

LORINDA I. LARYEA
Acting Chief, Fraud Section
United States Department of Justice

By: /s/ Jonathan Gottfried_______________

Assistant United States Attorney
U.S. Attorney’s Office for the
District of Puerto Rico
Torre Chardón, Suite 1201
San Juan, PR 00918
(787) 282-1889
[email protected]

Ariel Glasner
Trial Attorney
U.S. Department of Justice
Criminal Division, Fraud Section
1400 N.Y. Ave. NW
Washington, DC 20530
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(202) 598-2522
[email protected]

Tamara Livshiz
Trial Attorney
U.S. Department of Justice
Criminal Division, Fraud Section
1400 N.Y. Ave. NW
Washington, DC 20530
(202) 674-5670
[email protected]

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CERTIFICATE OF SERVICE

I, Jonathan Gottfried, Assistant United States Attorney for the District of

Puerto Rico, hereby certify that this document has been filed on Pacer, which will

be available to all attorneys of record.

By: s/ Jonathan Gottfried

Jonathan Gottfried

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