Internal audits and cross-checks of authorizations would reveal: billing in mismatched age ranges, inconsistencies between authorizations and target population, as well as the use of vaccines from the Ministry of Health in services billed as private.
SANTO DOMINGO. – The request for coercive measures in the “Operation Cobra” case details figures, limits, irregularities, and payment flows in two essential areas: vaccination and nutrition, aspects that have a direct impact on vulnerable populations.
The file also includes additional information on financial mechanisms and acquisition of goods that, in the opinion of the Specialized Prosecutor's Office for the Prosecution of Administrative Corruption (PEPCA), areindicators of fraud.
Unlike the initial public coverage, which was based on global figures and company names, the PEPCA dossier introduces specific data on goods that have a direct impact on the lives of children, chronically ill patients, the elderly, and people with nutritional vulnerabilities.
The figures relating to vaccines and supplements, both lines of public health action, show that, according to the document, the alleged misappropriations not only affected institutional and public finances, but also sensitive components of the social protection system.
According to the Attorney General's Office, the data contained in the file shows multimillion-dollar amounts, increasing limits, specific products, and accounting practices that indicate alleged irregularities in vaccination and nutrition programs for members of SeNaSa.
Vaccination: over RD$1.482 billion in payments
PEPCA documents that, between January 2021 and September 2025, SeNaSa paid RD$1,482,863,701.40 for vaccination services.
The document includes complete tables with the monthly distribution of expenses, indicating that, according to the Attorney General's Office, some of the invoices presented inconsistencies, including vaccines charged outside the corresponding age ranges; authorizations that did not match the target population and services billed with products that came from the Ministry of Health's own public dispensing, which, according to PEPCA, would imply that goods already distributed by the State were billed as private.
The presentation of these figures in the file suggests, according to the Public Prosecutor's Office, a direct impact on the provision of preventive services for children, the elderly and vulnerable groups, whose access to vaccines depends on the integrity of the public insurance payment scheme.
According to the coercion request, during that period internal audits and cross-checks of authorizations would reveal: billing in age ranges that do not match, inconsistencies between authorizations and target population, and use of vaccines from the Ministry of Health in services billed as private.
According to the Public Prosecutor's Office, these findings would compromise the proper provision of preventive services and could constitute violations of Article 33 of Law 87-01, which requires the proper management of services under the Basic Health Plan.
Nutrition: 30,000 monthly services
The file dedicates another central section to the contracts of the company Nutrimed / Nutri-med CAS, detailing the nutritional kits, quantities, and their prices. The first actual contractual scope, and therefore the basis for calculating initial amounts, included at least 15,233 services, the result of adding the explicitly defined limits.
| Kit | Unit cost | Frequency | Limit on members/services |
| Kit 1 | RD$ 3,275 | Quarterly | 1,932 services |
| Kit 2 (2a and 2b) | RD$ 1,585 | Monthly | (No quantitative limit is established in the document shown) |
| Kit 3 | RD$ 5,275 | Monthly | 13,301 monthly services |
The addenda cited in the file increased the limits to 30,727 monthly services after successive contractual modifications and according to the Attorney General's Office, the volume and modality of these payments constitute evidence of money laundering, typified in articles 2 and 3 of Law 155-17, due to the alleged channeling of funds through interposed companies.
The Attorney General's Office maintains that these kits became a channel through which payment flows were generated that are part of the alleged scheme.
The document emphasizes the effect on populations that depend on these supplements for metabolic treatments, immune support, and nutritional recovery.
The legal framework
The case file that supports the charges against ten people identifies the legal framework that, according to the prosecutors, was violated by the network, summarized as administrative corruption, money laundering, bribery, and public procurement.
The request for coercion indicates that the investigated actions violate several legal provisions:
Penal Code: criminal association, prevarication and embezzlement (arts. 265–266, 166, 172, 174).
Law 155-17 on Money Laundering: classification and aggravating factors (arts. 2, 3, 9).
Law 448-06 on Bribery in Commerce and Investment.
Law 41-08 on Public Service: duties, probity and conflicts of interest (art. 80 et seq.).
Law 340-06 on Purchases and Contracts: Prohibitions and Disqualifications (arts. 14, 15, 66).
Social Security Law 87-01: use of funds and services (arts. 31, 33, 46).
Vehicles, accounts and reservations
Although the evidentiary focus of the file is concentrated on the health programs, the Prosecutor's Office also describes other elements of the alleged scheme, such as the purchase of the Lincoln Navigator 2020 vehicle, on June 29, 2020, financed through account 803-978105 in the name of the wife of José Pablo Ortiz Giráldez, identified in the file as the financial operator of the network.
The structure of shell companies used, according to the file, for billing without support and immediate withdrawal of funds, in alleged violation of Law 155-17 and the principles of public procurement.
The impact on the Technical Reserves, estimated at RD$15,921,369,659.62, a figure recorded with cent precision within the file and which the prosecutors link to violations of the management of resources in Law 87-01.
Financial mechanisms and parallel flows
Although the focus of the case is on health programs, the document also incorporates additional elements that, according to PEPCA, describe the operation of the alleged scheme:
- The purchase of a 2020 Lincoln Navigator vehicle, acquired on June 29, 2020, before the official appointment, and financed through bank account number 803-978105, whose owner, according to the file, is the wife of José Pablo Ortiz Giráldez.
- Lists of shell companies linked to invoicing without operational support, allegedly used for immediate transfers and withdrawals of funds.
- Internal distribution flows, including percentages and roles within the structure, according to the Attorney General's Office.
- The cumulative impact on SeNaSa's Technical Reserves, which the file estimates at RD$15,921,369,659.62 until the end of 2024.
Regarding money laundering, the file provides an expanded list of shell companies, described by prosecutors as entities used to issue fictitious invoices, receive transfers and make immediate cash withdrawals, with the aim of channeling payments that, according to the Attorney General's Office, were distributed within the network.
The documentation mentions the existence of specific percentages that were applied to the amounts paid to contractors, as well as Ortiz Giráldez's involvement in the collection of funds, according to what PEPCA alleged.
Taken together, the PEPCA's request for coercive measures presents a detailed narrative about the operation of the alleged network, with figures, dates, amounts and names.
All the information described above comes exclusively from the file submitted to the court, which supports the accusations of the Public Prosecutor's Office in the "Operation Cobra" case.
