Bancor Group Inc v. Carlos Rodriguez

Court of Appeals for the Eleventh Circuit·Decided August 31, 2026·No. 24-13693·Unpublished

Opinion

USCA11 Case: 24-13693 Document: 69-1 Date Filed: 08/31/2026 Page: 1 of 20

NOT FOR PUBLICATION

In the

United States Court of Appeals For the Eleventh Circuit

No. 24-13693

Non-Argument Calendar

BANCOR GROUP INC, STITCHING PARTICULIER FONDS FRANEKER, derivatively on behalf of Eastern National Bank, N.A., Plaintiffs-Appellees,

versus

GABINA RODRIGUEZ, CARLOS RODRIGUEZ, Defendants-Appellants,

LOUIS FERREIRA, et al., Defendants.

Appeals from the United States District Court for the Southern District of Florida D.C. Docket No. 1:22-cv-20201-DPG

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Before ROSENBAUM, GRANT, and LUCK, Circuit Judges. PER CURIAM:

Bancor Group Inc. and Stitching Particulier Fonds Franeker filed a shareholder derivative lawsuit as minority shareholders of Eastern National Bank, N.A., against two former bank directors— Gabina and Carlos Rodriguez—for breach of their fiduciary duties of care and loyalty. After a jury found for the minority shareholders , the district court entered judgment against the directors. The directors appeal a number of the district court’s pretrial, trial, and posttrial rulings. After careful review, we affirm.

FACTUAL BACKGROUND

In 2016, Eastern National Bank began doing business with Banco de Venezuela, Venezuela’s largest state-owned financial institution . Against the advice of its chief compliance officer, the bank’s board approved opening an account for Banco. Two of the bank’s directors, Carlos and Gabina Rodriguez, also approved disabling the bank’s account monitoring system to avoid alerting the bank of money laundering risks from politically-exposed persons associated with the Venezuelan account.

2017 Office Examination

In 2017, the Department of the Treasury’s Office of the Comptroller of the Currency, a supervisory and regulatory authority for the bank, conducted an examination of the bank’s anti- money laundering programs. The Office found the bank’s board management and supervision deficient because the bank could not

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properly monitor transactions made through the Venezuelan account . Because it could not monitor the transactions, the bank closed the Venezuelan account, but it continued to process pending transactions.

2018 Consent Order

In 2018, the Office issued a consent order against the bank because the bank had opened and operated the Venezuelan account without a proper monitoring program in place. The consent order required the bank to review the Venezuelan transactions, overhaul its existing anti-money laundering program, ensure proper internal controls, strengthen board oversight, and develop a capital planning program that avoided payment of dividends without regulatory approval.

The bank did not comply with the consent order. Instead, at Gabina’s behest, the board fired the chief compliance officer who warned against opening the Venezuelan account.

2020 Consent Order

When the bank did not comply with the first consent order, the Office issued a second consent order, finding that the bank was still in violation of anti-money laundering controls; engaged in “numerous unsafe or unsound practices”; and lacked effective governance , including board oversight and capital planning. The Office concluded that these problems were “exacerbated by a dominant chairman,” namely, Gabina. To help fix the bank’s financial situation , the Office ordered it to reduce director compensation.

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The bank’s finances continued to deteriorate, however, and the bank lost money in 2018, 2019, 2020, and 2021.

PROCEDURAL HISTORY

After the bank failed to comply with the consent orders, two minority shareholders, Bancor and Franeker, brought a shareholder derivative lawsuit on the bank’s behalf alleging that the directors breached their fiduciary duties of care and loyalty. The minority shareholders alleged that Gabina acted as an “agent of the Venezuelan [g]overnment” to control the board, funnel Venezuelan funds into the bank, and help the Venezuelan government evade executive orders sanctioning it, while Carlos “[a]llow[ed]” the control to happen “to the [bank’s] detriment.”

We’ll focus on the parts of the proceedings relevant to this appeal.

Privilege Motion

In discovery, the directors produced thirty-one documents related to the Office’s examination. The examination documents contained the Office’s opinion that Gabina prioritized the Venezuelan government’s interests over the bank’s as well its findings on the bank’s overall management deficiencies. After discovery ended, the directors tried to claw back the documents, claiming that they were privileged.

The minority shareholders moved to adjudicate the privilege dispute, seeking an order “allowing [them] to use [the examination documents].” In response, the Office intervened to exclude

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the examination documents, asserting that they were protected by the “bank examination privilege.” The minority shareholders replied that the district court should overrule the privilege for “good cause.”

After reviewing the documents in camera, the district court overruled the Office’s privilege claim. Although it acknowledged that neither we nor the Supreme Court had ever recognized the privilege, the district court noted that neither the minority shareholders nor the Office “dispute[d]” that the privilege existed and “appear[ed] to agree” that a five-factor framework controlled the inquiry.

Applying the framework, the district court found that four factors strongly supported disclosure and only one weakly weighed against it. First, the district court found that the evidence contained in the documents was relevant since it “show[ed] how and why the [b]ank’s regulator was dissatisfied with the [b]ank’s leadership’s inability to achieve regulatory compliance.” Second, the district court ruled that other evidence was not available because the examination documents, as compared to its “raw data” in the form of “[bank] books and records,” uniquely “put the [b]ank’s leadership on notice” of their performance deficiencies.

As to the third and fourth factors, “[r]egarding the seriousness of the litigation and the role of government in the litigation,” the district court explained that the “allegation that the leadership of an American bank conspired with a foreign government to retain access to the American banking system despite an executive

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order to the contrary . . . call[ed] for some sunlight into the way our federal government regulates our national banks.” Finally, the district court found the risk of “chilling the speech of future government regulators . . . to be considerably low,” and that this was “one such case” in which the “the other factors discussed above outweigh[ed] the public interest in candor between banking regulators and banks.”

Motion in Limine

The directors also filed a motion in limine to exclude the examination documents under Federal Rule of Evidence 403 because their “probative value . . . [wa]s substantially outweighed by the likelihood of unfair prejudice.” The district court denied the motion because the documents were important to the “central issues” of the case, and the “solution [wa]s not to exclude [them, but] rather . . . to admit the evidence that directly contradicts [them].” And, the district court added, “if any undue prejudice c[ould] be imagined from the jury’s consideration of [the documents], a limiting instruction c[ould] be requested.”

At trial, the district court gave the jury a limiting instruction.

It told the jury that a “violation of the regulations of a governmental agency does not, in and of itself, make a director or officer liable for any losses sustained by the corporation,” and that although that “conduct . . . may be considered, [the jury’s] decision . . . must be based on all facts and the entire circumstances in the case.”

24-13693 Opinion of the Court 7

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