Carlos Manuel da Silva Santos, the founder and chief executive officer of San Diego-based Ethos Asset Management, Inc., which offered financing to domestic and international businesses, was sentenced to 87 months in prison for tricking borrowers into paying him more than $17 million in up-front loan fees for nothing in return, conduct that U.S. District Judge Robert S. Huie described as “reprehensible”.
Santos pleaded guilty in January 2025 to wire fraud conspiracy and aggravated identity theft in connection with his advance-fee loan scam through his company, Ethos.
Santos, a Portuguese national, has been in custody since his arrest on November 13, 2023, in Newark, New Jersey, after arriving in the United States from abroad.
According to his plea agreement, Santos admitted he and co-conspirators held Ethos out to the public as a “full-service project financing” company that offered loans to prospective borrowers in exchange for an upfront fee as collateral for Ethos to use.
However, on many occasions when a borrower gave Ethos the upfront fee as collateral, Ethos’ funding never materialised.
To induce prospective borrowers to send Ethos an upfront fee as collateral and enter into loan agreements, Santos and his co-conspirators lied about Ethos’ history of funding projects, the source of Ethos’ money, the amount of capital available to disburse loans, and how Ethos used the collateral upfront fees.
For instance, Santos admitted that he used money from the upfront collateral fees to release collateral deposited by other borrowers and to disburse loans to other borrowers.
Santos also admitted that he and others altered otherwise legitimate financial account statements to inflate the amount of money Ethos appeared to have at its disposal to finance projects for the purpose of luring prospective borrowers to provide collateral and financial institutions to lend money.
For example, in August 2021, Santos successfully induced a borrower to wire money as a collateral upfront fee by sending a bank statement that falsely represented Ethos having $100,304,447.46 when, in fact, it did not.
In February and May 2023, Santos again induced borrowers to provide collateral upfront fees by emailing a copy of Ethos’ annual financial statements falsely reflecting that Ethos had over $2.2 billion in total assets and that an accounting firm had audited the statements.
Indeed, Santos admitted that he knowingly forged the signature of an employee at a bookkeeping firm on Ethos’s 2022 annual financial statement to indicate that the firm had audited the statement falsely.
In each noted example, Ethos fraudulently obtained upfront fees and failed to disburse loan payments as promised.
Santos further admitted Ethos’ project financing scheme was international in nature, with a presence in the United States, Brazil, Turkey, and elsewhere. Santos admitted his scheme resulted in $17,125,000 in losses to certain U.S.-based victims.
The plea agreement also explains that the parties will request a restitution hearing allowing the United States to offer evidence that Santos owes significantly more money to various other victims.
According to the plea agreement, Santos also forged the signature of an employee at an accounting firm to make it appear that the firm had audited Ethos’ annual financial reports.
A restitution hearing will be held at a later date.
