U.S.
PLURIBUS

UNUM

O
OF

REPRESWhite Housefor Sale:How Princes, Prime Ministers , and Premiers
Paid Off President Trump
Staff Report
Committee on Oversight and Accountability
Democratic Staff

Rep. Jamie Raskin, Ranking Member
U.S. House of Representatives
January 4 , 2024

https://oversightdemocrats.house.gov/

Dedicated to the late Congressman Elijah E.Cummings,
Chairman of the House Committee on Oversight and Reform
The memory of the righteous is a blessing.

2

FOREWORD

CongressmanJamieRaskin
RankingMember
HouseCommitteeon Oversightand Accountability

Many reports get published in Congress every year and sink into oblivion , but this one isunlikely to disappear . The findings and conclusions presented by the House Committee onOversight and Accountability's Democratic staff are astounding

and they demand urgent action

by the Congress and by the American people .

Drawing from actual receipts and records and using the most conservative possible
accounting methodologies , White House for Sale: How Princes, Prime Ministers , and Premiers
Paid OffPresident Trump documents how, as President , Donald Trump accepted more than $7.8
million in payments from foreign states and their leaders, including some of the world's mostunsavory regimes . By elevating his personal financial interests and the policy priorities ofcorrupt foreign powers over the American public interest , former President Trump violated boththe clear commands of the Constitution and the careful precedent set and observed by every
previous Commander- in- Chief

Article I Section 9 , Clause 8 ofthe Constitution forbids the President to accept money
payments or gifts of any kind whatever from foreign governments and monarchs unless heobtains the Consent ofthe Congress to do so . Yet Donald Trump, while holding the office ofpresident, used his business entities to pocket millions of dollars from foreign states and royalty
and never once went to Congress to seek its consent. This report sets forth the records showing
foreign government money and all the spoils from royals we can find pouring into hotels andbuildings that the President continued to own during his presidency, all in direct violation of theConstitutional prohibition.
To be sure, we know about only some ofthe payments that passed into former President
Trump's hands during just two years of his presidency from just 20 ofthe more than 190 nations
inthe world through just four of his more than 500 businesses . Despite the Constitution's
requirement that a president disclose foreign emoluments and seek Congress's consent to keep
them, it took Oversight Committee Democrats years of aggressive litigation against the former
President to obtain the subset of documents from Mazars, Donald Trump's accounting firm, thatform the factual basis of this report. And then, in January 2023, Oversight Committee Chairman
James Comer made the abrupt and outrageous decision to release Mazars from having tocontinue complying with the Committee's subpoena and court-supervised settlement agreement .
Despite Chairman Comer's decision to bury further evidence , however, even this small slice of apicture of unknown proportions allows America to glimpse the rampant illegality and corruption
ofthe Trump presidency. It is true that $ 7.8 million is almost certainly only a fraction of
Trump's harvest of unlawful foreign state money, but this figure in itself is a scandal and adecisive spur to action.

The report's detailed findings make clear that we don't have the laws in place to deal witha president who is willing to brazenly convert the presidency into a business for self-enrichment
3and wealth maximization with the collusive participation of foreign states . No other president
had ever come close before to trying a rip-off like this simply based on vacuuming up foreign
government money, which was the cardinal presidential offense and betrayal in the eyes of theFoundersoffense and betrayal made all the more striking here by the offender's repeatedlaughable proclamations of America First !

This report forces us to confront fundamental questions that the Founders faced indesigning American institutions : What kind of government will we have? Will it be devoted tothe common good of all the people and will it actually put the interests of the people first? Or
will itjust be a structured opportunity for private gain and self-enrichment for schemers who
excel at self-promotion and sneer at the rule of law? In answering these questions, we have one
decisive advantage over the Founders: we have the Founders own handiwork inthe
Constitution which gives us precisely the principles we need to fortify democratic self
government and reject the practice of political leaders selling America out to foreign powers .
In the face ofthese stunning findings and conclusions , Oversight Committee Democrats
are prepared to act in defense of the Constitution . We will develop a package of proposed
legislative reforms to ensure that all occupants of the Oval Office abide by the Constitution's
unequivocal language commanding loyalty to the interests of the American people not theinterests ofhomicidal Saudi monarchs , totalitarian Chinese bureaucratic state capitalists , or otherforeign actors looking to obtain policy favors and indulgences by paying off a president or hiswholly owned businesses .
Supportingand defendingour Constitutionagainst all enemies, foreignand domestic, is
our sworn commitmentin Congress. Butthe defense ofdemocracyis the work ofa nation, andwe hopethat all the Americanpeople will participatein it.

Jamie Raskin
Ranking Member
House Committee on Oversight and Accountability

4

TABLE OF

3

Executive Summary .

6

Background: The ForeignEmolumentsClause, Trump's Businessesand ForeignConflicts,
17
and the Committee's Investigation
ReportMethodologyand DocumentLimitations

39

People's Republicof China

45

Saudi Arabia

67

Qatar

.83

United Arab Emirates

93

Kuwait

101

India

104

Philippines

113

Malaysia

117

Turkey124

DemocraticRepublicofthe Congo

132

Albania

140

144

AdditionalEmolumentSpending.

148

Additional Countries with Accounts at Trump- Owned Businesses

155

Conclusion

156

..

5

EXECUTIVESUMMARY

No Title ofNobility shall be granted by the United States : And no Person
holding any Office ofProfit or Trust under them, shall, without the Consent ofthe
Congress , accept of any present, Emolument, Office, or Title, ofany kindwhatever , from any King, Prince, or foreign State.
Constitution of the United States , Art . I , 9 , cl. 8

This report sets forth the results of a multi-year investigation into former President
Donald Trump's receipt ofpayments from foreign governments and foreign state-owned or state
controlled entities while in office . This systematic collection of foreign money was in direct
violation of the explicit prohibition against such emoluments in the U.S. Constitution's Foreign
Emoluments Clause . The Committee's investigation began under the leadership of then-Ranking
Member Elijah E. Cummings in 2016 , the year when President-elect Trump was poised to bringwith him into the office of President of the United States a sprawling and debt-laden corporate
empire of more than 500 businesses operating in at least 25 different countries , and yet refused todivest himself of these corporate assets and properties . Instead, he declared himself still open forbusiness to allcomers , including princes , prime ministers , premiers , and foreign governments ,who became his active , albeit constitutionally forbidden , financial patrons.¹
In layman's terms , an emolument is broadly defined as an advantage , profit, or gain
received as a result of one's employment or one's holding ofoffice, financial or otherwise ,received either directly or indirectly.² Shrouded in complexity and secrecy, President Trump's
global corporate empire proved to be a magnet for emoluments from foreign governments andgovernment-sponsored sources across the globe. His businesses encompassed luxury hotels allover the world, high-end mixed-use buildings like Trump Tower in New York City, anddestination golf resorts. When he arrived in the White House, then-President Trump wasdetermined not only to keep this well-branded global corporate empire going but also to seize a
new and unprecedented opportunity to make it ever more lucrative for himself and his family . It
would soon become clear that he viewed the presidency as a once-in-a-lifetime opportunity for
self- enrichment and profit maximization, courtesy of some of the most corrupt governments inthe world . The presidency became the fulfillment of a get- rich-quick campaign hereportedly described as

the greatest infomercial in political history.

993

Letter From Ranking Member Elijah E. Cummings , Committee on Oversight and Government Reform, toChairman Jason Chaffetz, Committee on Oversight and Government Reform (Nov. 14, 2016) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/documents/2016-11
14.EEC % 20to % 20JC % 20% 28003 % 29.pdf) .
2

See Congressional Research Service , The Emoluments Clauses ofthe U.S. Constitution (Jan. 27, 2021)(online at https://crsreports.congress.gov/product/pdf/IF/IF11086 ) (quoting Black's Law Dictionary) .

Committee on Oversight and Reform, Hearing with Michael Cohen, Former Attorney to President
Donald Trump , 116th Cong, Transcript at 14, 21–22 (Feb. 27, 2019) (online at www.congress.gov/116/chrg/CHRG
116hhrg35230/CHRG- 116hhrg35230.pdf) ; Cohen : Trump Described His Campaign As The Greatest Infomercial
in Political History, The Hill (Feb. 27, 2019 ) (online at https://thehill.com/homenews/house/431802-cohen-trump
described-his-campaign-as-the-greatest -infomercial-in-political ).
6Immediately after the 2016 election , ethics experts from across the political spectrum
read the writing on the wall and urged the new President - elect to fully divest himself of his
business interests and place all their proceeds in a truly independent blind trust . These bipartisan
ethics experts warned that ifhe did not divest , the President would remain the ultimate financial
beneficiary of payments made to his businesses by foreign powers seeking favorable treatment
from the government ofthe United States

exactly the predicament feared by the Framers ofthe

Constitution and explicitly forbidden by the Constitution's Foreign Emoluments Clause.4

Throwing caution to the wind and the Constitution to the curb, former President Trump
bluntly and cavalierly rejected all such bipartisan advice. He instead chose to place the day-to
day management of his businesses in the hands of his two adult sons while retainingpersonal
ownership andcontrol of all his businesses, as well as the ability to draw funds from themwithout any outside disclosure.5 He also refused to divest from his business entities, including
those benefiting significantly from business with foreign governments. Instead, former President
Trump merely pledged that The Trump Organization would enter into no new foreign deals.6
This transparently improper arrangement reinforced ( rather than severed ) his ties to hisbusinesses and enabled him to prioritize his personal interests over those of the nation, as foreign
governments and those acting on their behalf quickly began spending money at Trump properties
in hopes of gaining the new President's favor . Thus , the central constitutional ban onpresidential acceptance of payments
in danger immediately .

of any kind whateverfrom foreign governments was put

By ignoring this fundamental constitutional command , former President Trump also
threatened to obliterate a critical and defining principle of American democracy

namely , thestrict separation of a president's personal financial interests from those of the nation. In
establishing the presidency , the Framers emphasized that the President was not a term- limited
king but a public servant whose duty was to serve the common good rather than personal
financial interests . The U.S. Constitution emphatically and unambiguously rejected themonarchical system , requiring our elected chief executive to use the office solely to advance theinterests ofthe American people, rather than their own personal financial and business interests.

Bipartisan Group Urges Trump, Family to Divestfrom Private Business, Washington Post (Dec. 9,2016)(online at www.washingtonpost.com/news/post-politics/wp/2016/12/09/bipartisan-group-urges-trump-family-to
divest-from-private -business /).
5

Trump Can Quietly Draw Money from Trust Whenever He Wants , New Documents Show , Washington

Post ( Apr. 3 , 2017) (online at www.washingtonpost.com/politics/trump-can-quietly-draw-money-from-trust
whenever- he-wants -new -documents - show/ 2017/ 04/ 03 / 7f4c0002-187c - 11e7-9887-1a5314b56a08_story.html ); Letterfrom Chairwoman Carolyn B. Maloney , Committee on Oversight and Reform , to Administrator Robin Carnahan ,General Services Administration (Oct. 8 , 2021) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight

08.CBM % 20GEC% 20to% 20Carnahan - GSA% 20re %house.gov/files/2021-10% 20Post

6

20Office% 20Building

20Lease.pdf ) .

Donald Trump's New York Times Interview: FullTranscript, New York Times (Nov. 23,2016) (online atwww.nytimes.com/2016/11/23/us/politics/trump-new-york-times-interview-transcript.html) ; Trump Drops NoNew
Deals Pledge,Politico ( Jan. 11, 2017) (online at www.politico.com/story/2017/01/trump-business-ties-conflicts
233468) .
7

Given President Trump's dramatic departures from the Constitution, the rule of law, andthe prior unbroken history of presidential refusals to take foreign state money, as well as therepeated opportunities his business entanglements with foreign states created to use his office toadvance his business dealings , Democrats on the Committee on Oversight and Accountability
began a nearly seven-year long investigation , initiated by the late Ranking Member Elijah E.
Cummings , advanced by Chairwoman Carolyn B. Maloney, and now completed, based on
available materials , by Ranking Member Jamie Raskin. As this report makes clear , it provides
a significant glimpse into former President Trump's foreign financial dealings but far
from a comprehensive account of his unprecedented efforts to use the presidency to enrichhimself and his family in direct violation of the U.S. Constitution .

After President Trump and the White House had refused multiple requests from theCommittee to provide documents voluntarily , and after Mr. Trump's longtime former attorney,
Michael Cohen, testified before the Committee that Mr. Trump routinely prepared false financial
statements , then-Chairman Cummings issued a subpoena to Mr. Trump's accounting firm at thetime, Mazars USA, LLP (Mazars) . This subpoena , issued in April 2019 , sought documents to
help Congress fulfill its constitutional responsibility to determine whether President Trump hadbusiness interests that could impair his ability to make policy decisions in the national interest,
whether he was complying with the Foreign and Domestic Emoluments Clauses ofthe
Constitution , and whether he made accurate financial disclosures to the Office of Government
Ethics as required by law. President Trump fought hard to keep relevant financial documents
secret , spending years litigating in an unsuccessful effort to block the Committee's subpoena . In
July 2020, the U.S. Supreme Court rendered its decision in Trump v . Mazars, holding thatPresident Trump was not above the law and had to comply with the Committee's subpoena undera new four-part test .

President Trump continued to fight the scope of the subpoena in lower

courts until September 2022 , when a federal district court approved a settlement between
President Trump , Mazars, and the Committee , pursuant to which the court supervised theagreement .
However , in January 2023, upon becoming the new Chairman of the re- named
Committee on Oversight and Accountability , Representative James Comer apparently decided toallow attorneys for President Trump to speak on behalf of the Committee and, acting in thatwholly improper capacity , to release Mazars from its legal obligation to produce relevant records
to the Committee under the court - supervised settlement . According to an email from former
President Trump's attorneys to Mazars , Chairman Comer authorized Mr. Trump's attorneys toinform Mazars that the Committee has no interest in forcing Mazars to complete [ its productionof documents] and is willing to release it from further obligations under the settlementagreement .
InJune 2023, Mr. Trump and the Committee under Chairman Comer's
direction
7
8

filed a joint motion for dismissal and termination of the case. The District Court

Trumpv . MazarsUSA, LLP, 140 S. Ct. 2019 ( 2020) .

Committee on Oversight and Reform, Press Release: Chairwoman Maloney's Statement on OversightCommittee Securing Agreement to Obtain Former President Trump's Financial Records (Sept. 1 , 2022) (online athttps://oversightdemocrats.house.gov/news/press-releases/chairwoman-maloney-s-statement-on-oversightcommittee-securing- agreement-to) .

9

Email from Patrick Strawbridge , Consovoy McCarthy PLLC, on behalf of Donald Trump , to Counsel for

Mazars USA, LLP (Jan. 19 , 2023 ) ( on file with Committee ).
8grantedthe motionon July 5, 2023, endingthe litigationand the court's supervisionofthe
10
parties agreement.

Despite these obstacles , Committee Democrats succeeded in obtaining a subset of
documents that shine a light on the finances of at least some of the former President's businesses,
despite being incomplete and lacking in significant respects because of the Chairman's actions
and significant gaps in the records possessed by Mazars. This report presents the analysis ofthese documents prepared by the Committee's Democratic staff. Critically , even this subset of
documents reveals a stunning web of millions of dollars in payments made by foreign
governments and their agents directly to Trump -owned businesses while President Trump
was in the White House. These payments were made while these governments were promoting
specific foreign policy goals with the Trump Administration and even, at times , with President
Trump himself, and as they were requesting specific actions from the United States to advancetheir own national policy objectives .
Based on the subset of documents the Committee received from Mazars , this reportconcludes:

Through entities he owned and controlled, President Trump accepted , at a minimum,
millions ofdollars inforeign emoluments in violation ofthe United States Constitution .
The documents obtained from former President Trump's accounting firm and from afederal agency demonstrate that four Trump- owned properties together collected, at theleast, millions of dollars in payments from foreign governments and officials that violated
the Constitution's prohibition on emoluments of any kind whatever from foreign
governments . These payments clearly fell within the definitions of emoluments set forthin Article I , Section 9 of the Constitution and applied by the U.S. Department of Justice( DOJ) and the federal judiciary , which include payments that flow from transactional
relationships with foreign governments or entities , including so- called market
transactions .
President Trump's businesses received , at a minimum , $ 7.8 million in foreign
payments from at least 20 countries during his presidency . These included paymentsfrom foreign governments and foreign government - owned or -controlled entities toproperties owned by Donald Trump , including Trump International Hotel in Washington ,D.C

Trump International Hotel in Las Vegas ; Trump Tower on Fifth Avenue in New

York; and Trump World Tower at 845 United Nations Plaza in New York.

President Trump never sought or received Congress's approval to keep these foreign
payments, as the Constitution requires . Instead of disclosing to Congress the foreign
payments his businesses received during his presidency and requesting its consent toretain them pursuant to the process compelled by Article I , § 9 , cl. 8 as multiple
presidents before him had done former President Trump actively concealed thesepayments and tried to prevent Congress from obtaining information about them . As a

See Order, Trump v . Committeeon Oversightand Accountabilityofthe U.S. HouseofRepresentatives, etal CivilActionNo. 1: 19-cv- 01136-APM(D.D.C.July 5, 2023) .
9

result, President Trump obstructed Congress's duty under the Constitution to consider
whether to permit the President to retain any of the foreign emoluments his businesses
received.

Theforeign nations makingpayments to PresidentTrump spanned the globe andincludedseveralofthe mostcorruptand authoritariangovernments on Earth. They
rangedfrom the People's Republic of China to Saudi Arabia to the Democratic Republic
ofthe Congo to Malaysia to Albania to Kosovo. These countries spent often lavishlyon apartments and hotel stays at Donald Trump's properties personally enriching
President Trump while he made foreign policy decisions connected to their policy
agendas with far-reachingramifications for the United States.
Information available to the Committee shows that among countries patronizing
Trump properties, China made the largest total payment to President Trump's private
business interests. According to the subset of documents obtained from Mazars and an
additional document from the U.S. Securities and Exchange Commission (SEC) , thesepayments collectively included millions of dollars from China's Embassy in the UnitedStates; the Industrial and Commercial Bank of China (ICBC), a Chinese state-owned
enterprise ; and Hainan Airlines Holding Company , a subsidiary of Chinese company
HNA Group, owned by the Hainan provincial government .
Bypocketing foreign states payments, President Trump repeatedly placed his personal
financial interest and the interests offoreign wealth andpower above the public
interest, resulting inprecisely the split loyalty between foreign power and the American
people that the Framers sought to avoid by writing the Foreign Emoluments Clauseinto the Constitution . Examples include the following :2017, PresidentTrump did not impose sanctions on ICBC
tenant inTrump Tower in New York

his well- paying

even though the DOJ in 2016 filed acomplaintalleging that the bank had been amongChinese financialinstitutions
that hadprovided accountsto a company that had allegedly conspired with aNorth Korean bank to evade U.S. sanctions.

He did not sanction ICBC even after former Republican Chairman Ed Royce ofthe House Foreign Affairs Committee called on President Trump to apply
maximum financial and diplomatic pressure by “ targeting more Chinese banks
that do business with North Korea.
President Trump expressed his own
personal sympathies and constitutional indifference on the matter in the 2016
campaign when he stated :love China ! The biggest bank in the world isfrom China You know where their United States headquarters is located?
12
Inthis building , in Trump Tower .
House Committee on Foreign Affairs , Press Release : Chairman Royce Statement on North Korea (Sept.
3 , 2017) ( online at https://foreignaffairs house.gov/press-release/chairman-royce-statement-north-korea/ ) .
12

Trump's Comments After Not Attacking Nike Raise Even More Questions , Washington Post (Sept. 5,2018) (online atwww.washingtonpost.com/news/politics/wp/2018/09/05/trumps-explanation-for-not-attacking-nikeraises-even-more-questions ) .
10

The documents provided to the Committee reveal that Saudi Arabia and its royalfamily spent at least $ 615,422 at Trump properties during the Trump

Administration, and the total amount of the country's expenditures is likely muchhigher than that . In May 2017, while Saudi Arabia was spending lavishly atproperties he owned, President Trump signed an arms deal with the Saudi
government worth more than $ 100 billion, despite reports that the country
repeatedly used weapons to cause mass civilian casualties during its ongoingmilitary intervention in

President Trump also cast doubt on U.S.

intelligence assessments concluding that Saudi Crown Prince Mohammed bin
Salman had ordered the murder and dismemberment of Washington Post
contributing journalist and Saudi regime critic Jamal Khashoggi . At a
campaign rally in 2015, then-candidate Trump articulated what would
matter most to him in any conflict between his personal financial incentives
related to the Saudis and American values and policy goals: Saudi Arabia ,get along great with all of them. They buy apartments from me. They
spend $40 million, $50 million.
them ? I like them very much

He continued ,Am I supposed to dislike

Over a seven- month period in 2017 and 2018 , while the United Arab Emirates(U.A.E.) lobbied Trump Administration officials to support a blockade of Qatar
that Saudi Arabia and the U.A.E. had imposed , the U.A.E. spent tens of thousandsof dollars at the Trump International Hotel in Washington , D.C., through four
different stays . For many years , President Trump had business interests in Dubai,
and he maintained those interests while he was in office .
In February 2017,16

just after Donald Trump took office , both Donald Trump Jr. and Eric
Trump attended the opening of a new Trump - branded golf course in the17

Importantly, the foreignpaymentsto PresidentTrump identifiedinthis reportare likely
only a small fractionofthe total amount of suchpaymentshe receivedduring his presidency.
This report is not able to provide a more comprehensiveaccountofall ofthe foreignemoluments
13

Trump Signs Kushner - Negotiated $100B Saudi Arms Deal, CNN (May 20, 2017) ( online atwww.cnn.com/2017/05/19/politics/jared-kushner-saudi-arms-deal-lockheed-martin/index html) ; What You Need toKnow About the Crisis in Yemen , TIME (Nov. 3 , 2016) ( online at https://time.com/4552712/yemen-war
humanitarian-crisis-famine ) .

FullText: PresidentDonald Trump's Statement on SaudiArabia, Khashoggi Killing, Politico (Nov. 20,2018) (online at www.politico.com/story/2018/11/20/donald-trump-statement-saudi-arabia-khashoggi-killing
1008219) .
15

Trump Claims He Has No Financial Interests in Saudi Arabia
He Makes Lots of Money from ,CNBC (Oct. 16,2018 ) (online at www.cnbc.com/2018/10/16/trump-says-no-financial-interests-in-saudi-arabia-but
makes-money.html).
16

Trump's Business Ties in the Gulf Raise Questions About His Allegiances , New York Times (June 17,2017) (online at www.nytimes.com/2017/06/17/world/middleeast/trumps-business-ties-in-persian-gulf-raisequestions-about-his-allegiances.html).
17

TrumpSons OpenDubaiGolfClubas NamesakeNowUSPresident, Seattle Times( Feb. 18, 2017)( onlineatwww.seattletimes.com/business/trumps-sons-eric-and-donald-jr-in-dubai-to-open-golf-club/).
11

former President Trump's businesses received during the time period covered by theCommittee's subpoena as a result of Chairman Comer's successful effort , in coordination with
Trump's attorneys , to block the production of the remaining documents in discovery as soon as
he became Chairman in 2023 , as well as the failure of President Trump to provide to Mazars or
Mazars's failure to retain
Committee's favor

many key documents . Although the Supreme Court ruled in theand despite the fact that a federal judge was monitoring Mazars's ongoingcompliance with the court-approved settlement18
agreement .

Chairman Comer deliberately scuttled thisAstonishingly , soon after becoming Chairman , Representative Comer claimed: I
honestly didn't even know who or what Mazars was. " For years , President Trump aggressively
litigated the case to thwart Mazars's compliance with the Committee , but Chairman Comer has
blamed Democrats for investigating Trump for six years . Instead of honoring the court
approved settlement , Chairman Comer made clear what he planned to do:know exactly what
investigating: money the Bidens received from China
As promised, Chairman Comer
halted any further document productions relating to President Trump's receipt of foreign
payments from China or any other country and launched an investigation of President Joseph
Biden's son, which to date has produced no evidence of any constitutional or criminal
wrongdoing by President Biden.
Inadditionto placinghis personalloyaltyto Donald Trump abovethe institutional
interestsofCongressand the integrity ofthe Constitution, ChairmanComerworkedwithDonald
Trump'sattorneysto bury further evidence offormer President Trump's misconductby
deprivingthe Committee'sDemocraticstaff of the abilityto work withMazarsto conductfurther
searchesfor responsiverecords, including for any documentsregardingpaymentspotentiallyfrom Russia, South Korea, SouthAfrica, and Brazil.
Notably, the set of documents Mazars did produce
decision to release the company from its obligations

before Chairman Comer's shocking

containedsome staggering omissions.

Underthe terms of the September 2022 settlement agreement, Mazarswas requiredto produce:
1.

documents from 2014 through 2018 related to any false or inaccurate information
on President Trump's public financial disclosures;

2. AlldocumentsfromNovember2016 through 2018 regardingthe TrumpInternational
Hotelin Washington, D.C.; and18 Email from Patrick Strawbridge, Consovoy McCarthyPLLC, on behalf of Donald Trump, to Counsel for
Mazars USA LLP ( Jan. 19, 2023 ) ; Letter from RankingMemberJamie Raskin to Chairman James Comer,
Committee on Oversight and Accountability (Mar. 12, 2023) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/FINAL%202023.03.12.%20JBR%2
20Comer 20re% 20Mazars 20BofA% 20Subpoena.pdf) ; Comer Stymies Probe into Trump Tax Records,
House Democrats Say, Washington Post (Mar. 13, 2023) (online atwww.washingtonpost.com/politics/2023/03/13/trump-tax-records-investigation/ ) ; Order , Trump v . Committee onOversight and Accountability ofthe U.S. House ofRepresentatives , et al ., Civil Action No. 1 : 19-cv -01136-APM(D.D.C.July 5 , 2023) .
19

HouseRepublicansQuietlyHaltInquiryinto Trump'sFinances, NewYork Times ( Mar.13, 2023)( onlineatwww.nytimes.com/2023/03/13/us/politics/house-trump-finances-investigation.html).
12

3. All documents from 2017 through 2018 regarding any financial transactions between
President Trump and any foreign or domestic state agency or government official.20
Foreachofthesecategories, however, key documentswere apparentlyneverprovidedto
or retainedby Mazars.

For example , with regard to the first category , the Committee's Democratic staff
specifically requested information regarding a $20 million loan made by Daewoo , a South
Korean commercial entity, that was not reported on President Trump's 2015, 2016 , or 2017
public financial

21

Mazars responded that it had no documents related to this loan.

With regard to the second category, the Committee's Democratic staff specifically requested
hotel guest ledgers covering the 2017 presidential inauguration . Although Mazars provided hotel
guest ledgers for various other time periods , itresponded that it did not have ledgers covering the2017 inauguration . And with regard to the third category , the Committee's Democratic staff
specifically requested information regarding ICBC's nearly two - million dollar a year lease in
Trump Tower. Once again, Mazars represented that it had no responsive documents .

The myriad payments by foreign governments , royalty, state- owned companies , andforeign agents revealed in the documents that Mazars did produce , as well as in public records,
raise two distinct yet intertwined constitutional concerns . First, President Trump's
unprecedented acceptance of these hidden foreign payments clearly violated theConstitution's prohibition against a president's acceptance of foreign state emoluments
without Congress's consent . Second, President Trump's failure to comply with the Foreign
Emoluments Clause and to uphold his oath of office produced the exact kinds ofpresidential corruption and conflicts between the President's personal financial interests
and the public interest that this constitutional provision was designed to prevent . As James
Madison wrote , the Foreign Emoluments Clause was adopted due tothe necessity of preservingAsforeign ministers and other officers of the U.S. independent of external influence.
demonstrated throughout this report, Donald Trump's business interests provided an irresistible
entry point for external influence in American foreign policy and a continuing source ofcorruption in Trump's conduct of U.S. foreign policy . It is these two linked concerns that thisreport seeks to bring to light and begin to remedy.
The Framersassumedthat futurepresidentswould complywith the Constitution's
specificrequirementto seek Congress'sconsent in order to retain any and allforeign
emolumentsbeingdangled beforethem. Beforethe TrumpAdministration, every presidenthad
donejust that. The Framersclearly never envisioneda presidentwho would simplydisregardthe20

See Stipulated Agreement, attached as Exhibit A to Order, DonaldJ. Trump, et al. v . Committeeon

OversightandReform ofthe U.S. House ofRepresentatives, et al., Civil Action No. 1 : 19-cv-01136-APM (D.D.C.
Sept. 11, 2022) .
21

Trump Owed Hidden Debt While in Office , Forbes (Dec. 4 , 2022 ) (online at

www forbes.com/sites/danalexander/2022/12/04/trump-owed-hidden-debt-while-in-office/).

The Records of the Federal Convention of 1787, at 389 (Max Farrand ed , 1911) (Madison's notes).

22(online at https://constitution.congress.gov/browse/essay/artI-S9-C8-2/ALDE_00013205/#ALDF_00020473
13).

constitutional wall of separation betweenthe president's personal finances and foreign
government money inducements.

funds

The unprecedentedscopeand scale ofMr.Trump'sreceiptofunconstitutionalforeign
andthe failure ofthe currentstatutoryregimeto ensurean effectiveandtimely response

to his violationsofthe Constitution demonstratethe pressingneed to overhaulethicsand
disclosurelawsto protectessentialanti- corruptionprinciplesin our law andConstitutionfrom
suchflagrantExecutiveBranchabuse.

Congressnow must decidehowto respond. This reporturges Congress to consider
adoptinga new legislativedisclosureregimeto help Congressobtainthe informationit needsto
performits assignedconstitutionalfunctionofevaluating and either approvingor rejecting
the acceptanceof foreigngovernmentemolumentsby the president andother federal officials.
This reportalso recommendsthat Congress consider instituting a moreformal procedureforpresidentsandother officialsto seek Congress'spermissionwhenthey receive and want to retain
such emoluments. Inthe meantime, this investigationwill continueto informCongress andthe
Americanpeople about how to prevent senior public officials fromtaking advantageoftheir
only duringbut
positionsto reapprivatefinancialwindfalls fromforeign statesimmediatelybeforeand after takingpublic office. Further, while this report focuses on former
PresidentTrump'sviolations ofthe Constitution'sForeignEmolumentsClause, the Mazars
documentsalsoreveala patternofpaymentsfrom domestic individuals, entities, and government
agenciesthatraise significantpotentialconflicts of interestandpotentialviolations ofthe
Constitution'sDomesticEmolumentsClausethrough expenditures at Trump-owned businesses.
Thesewillbe the focus of a subsequentreport.
The chart below identifies spending by foreign governments and entities at Trump-owned
properties, allin violation of the Constitution's Foreign Emoluments Clause, as reflected inthe
limited records produced to the Committee by Mazars and identified in publicly available
information :TotalSpending
Identified

Trump Businesses Patronized

Trump Tower
China$ 5,572,548

Trump International Hotel ( Washington, D.C.)

Trump International Hotel ( Las Vegas , NV)
SaudiArabia

Trump World Tower$ 615,422

TrumpInternationalHotel( Washington, D.C.)

This chartreflectschargesthatthe Mazarsrecordsand public recordsshow were incurredbyforeign
nationsat the TrumpInternationalHotelsin Washington, D.C., and in Las Vegas. For charges incurredby foreign
nationsat Trump WorldToweror TrumpTower(bothin NewYork) , whichall pertainto real estateownedor
rentedby foreigngovernmentsor entities, this reportuses commonchargesor rent paymentsreflectedinrecords
producedby Mazarsor in publicinformationto estimatetotal paymentsduringformerPresidentTrump's
presidency Forexample, for units in Trump WorldTowerownedby foreigngovernmentsor entities, the Mazars
recordscoveronlychargespaidin2018. However, whenpublicrecordsshow thatthe sameforeigngovernmentsor
entitiesownedthese unitsthroughoutthe Trumppresidency, this reportuses the common(base) chargespaidin
2018toestimatethe total ofsuchchargespaidby the specifiedforeignnationsduringthe entire Trumppresidency.
Similarly, a publicrecordreflectsthat theIndustrialand CommercialBankof Chinaleasedpropertyat Trump
14

Qatar

$ 465,744

Kuwait$ 303,372

Trump World Tower
Trump World Tower
TrumpInternationalHotel( Washington, D.C.
)

India

Trump World Tower$ 282,764

TrumpInternational
Hotel( Washington, D.C.)

Malaysia$ 248,962

Afghanistan$ 154,750

Philippines$ 74,810

Trump International Hotel ( Washington, D.C.)$ 65,225

Trump International Hotel ( Washington, D.C.

$ 25,171

TrumpInternationalHotel( Washington, D.C.)

Kazakhstan$ 23,772

TrumpInternationalHotel( Washington, D.C.)

Thailand$ 11,340

TrumpInternationalHotel( Washington, D.C.)$ 8,800

Trump International Hotel (Washington, D.C.)

Mongolia$ 8,486

Trump InternationalHotel( Washington, D.C.)

Lebanon$ 7,720

TrumpInternationalHotel( Washington, D.C.)

Albania$ 6,002

TrumpInternationalHotel( Washington, D.C.)

Kosovo$4,950

Trump International Hotel (Washington, D.C.)

Latvia$2,739TrumpInternationalHotel( Washington, D.C.)$1,894

Trump International Hotel (Washington , D.C.)

Hungary$ 1,011

Trump International Hotel (Washington , D.C.)

Cyprus$ 590

Trump International Hotel (Washington , D.C.)

TrumpInternationalHotel( Washington, D.C.)

Trump World Tower

Trump International Hotel (Washington, D.C.)

United ArabEmirates

Democratic

Republic of Congo

Self- Declared

Turkish Republic ofNorthern Cyprus

Inaddition, records provided to the Committee by Mazars indicate that Azerbaijan,
Georgia, Namibia, Romania, and Costa Rica had accounts at a Trump- owned property after

Tower, NewYork withan annualbase rent of $ 1.9 millionstartingin2008and continuingat least throughthe
expirationof the leaseinOctober2019. This reportestimatesthe totalrentpaymentsfrom February2017 throughOctober2019 basedon that annualbase rent.

15

Donald Trump was elected President, but Mazars did not provide any documents detailing the
purposes or amounts of these countries expenditures.

16

BACKGROUND: THE FOREIGNEMOLUMENTSCLAUSE, TRUMP'SBUSINESSESAND FOREIGNCONFLICTS, AND THE COMMITTEE'SINVESTIGATION

the time ofhis election, Mr. Trump ran numerous businesses centered in the real estateand hospitality industries alongside his three adult children
all played prominent roles in those businesses .

Donald Jr. , Ivanka, and Eric

who

Mr. Trump refused to divest from thesebusiness interests and claimed that the president can't have a conflict of interest, registering amodern echo of the royalist credo that the king can do no wrong. 25 This decision raised
immediate concern that he would be prejudiced by foreign influence and would not fulfill hisoath to preserve , protect and defend the Constitution of the United States, including thecategorical requirement in the Foreign Emoluments Clause that a president seek and obtain
Congress's permission before accepting any payment from a foreign state.26
The Foreign Emoluments Clause :Sweeping and Unqualified

Article I Section 9 of the Constitution provides :NoTitle ofNobilityshall be granted by the UnitedStates: And no Person
holdinganyOffice of Profit or Trust underthem, shall, withoutthe Consentof
the Congress, acceptofanypresent, Emolument, Office, or Title, ofany kindwhatever, from any King, Prince, or foreignState.

Fordecades, the DOJhas recognizedthat this prohibitionis sweepingand unqualified
and directedagainstevery kind of influenceby foreigngovernmentsuponofficersofthe UnitedStates, based on ourhistoricpolicies as a nation.

Ithas been well understoodin our history

that the ForeignEmolumentsClausepreventsthe presidentfrom acceptingany profit, advantage,

24 Growing Up Trump, TIME (Aug. 11, 2015 ) (online at https://time.com/3990496/donald-trump

children ).

25 DonaldTrump's New York Times Interview: FullTranscript, New York Times (Nov.23 , 2016) (onlineat www.nytimes.com/2016/11/23/us/politics/trump-new-york-times-interview-transcript.html) ; DonaldTrump's
ComplexBusinessesBringPotential Conflicts ofInterest, WallStreet Journal (Nov. 15, 2016) (online atwww.wsj.com/articles/donald-trumps-complex-businesses-bring-potential-conflicts-of-interest-1479221276) ; Trump
CouldRun Afoul ofThis Obscure ConstitutionalClause, CNBC (Nov.23, 2016) (online atwww.cnbc.com/2016/11/21/trump-could-run-afoul-of-this-obscure-constitutional-clausehtml) .
26

U.S. Constitution, ArticleII

1 , cl. 8 .

27 U.S.Constitution, Article I , § 9, cl. 8. The Constitutionalso containsa Domestic EmolumentsClause
whichmandatesthat the Presidentshall, at stated Times, receivefor his Services, a Compensationwhich shallneither be increasednor diminishedduringthe Periodfor which he shall have been elected, and he shallnot receive
withinthat period any other EmolumentfromtheUnitedStates, or any ofthem. U.S.Constitution, Article II, § 1,. 7. Inadditionto violationsofthe Foreign EmolumentsClause, the Mazars documentsreveala patternof
paymentsfrom domestic individuals, entities, and governmentagenciesthat raise significantpotentialconflictsof
interestandpotentialviolationsof theDomesticEmolumentsClausethroughexpendituresat Trump businesses,
whichwillbethe focus of a subsequentreport.
28

Applicability ofthe Emoluments Clause to Non- GovernmentMembers ofACUS, 17 Op. O.L.C. 114( 1993) ( online at www.justice.gov/file/20456/download) ; DepartmentofJustice, Office of Legal Counsel, Proposal
ThatthePresidentAccept HonoraryIrishCitizenship, 1 Op . O.L.C. Supp. 278 ( 1963) (online atwww.justice.gov/d9/olc/opinions/1963/05/31/op-olc-supp-v001-p0278_0.pdf).
17

gain, or benefit derived from private commercial transactions with a foreign government unless
29

Congress consents.2

The adoption ofthe Foreign Emoluments Clause reflected a defining and fundamental
break from monarchy. In royal society , a king's private hereditary and commercial interests were
coextensive with the wealth of his kingdom. But in American Constitutional democracy , theelected president's job is to take care that the laws be faithfully executed , and, accordingly , heor she is limited to a fixed presidential salary and may not collect any outside payments fromforeign states or royalty.30

Thus, Article IIof the Constitution, which defines the powers of the Executive Branch,gave the president significantly less authority to demand advice on personal matters than the
English king possessed. Whereas George IIIcould order his subjects on the Privy Councilto
assist in managing his personal landholdings based on their obligation to advise for the King's
honour and to serve their sovereign lord George Washington had no comparable authority,
but could only obtain cabinet opinions on public matters relating to the Duties of their
OfficesMoreover, the Framers emphasized that because the English king ruled for life, andbecause his wealth was closely bound up with that of his nation, he actually had a greater stake
inthe long-term interests of his kingdom , and hence , was less susceptible to foreign corruption
than American presidents , who held office for a limited term, did not enjoy the same access topublic wealth , and would be focused on their personal interests after their terms in office
endedThis difference , in the Framers view, underscored the critical need for constitutional
protection against foreign emoluments and the heightened risk that presidents ofthe new nation
would act in their own financial interests rather than those of the American people .
Viewedinthis historicalcontext, DonaldTrump's shockingtreatmentthroughouthispresidencyofthe ForeignEmolumentsClause as a risiblesuggestion, ratherthan a foundational
requirementofour democracy, threatenedto underminethe rigorousseparationofpersonal
financialinterestsand officialduties that the Framersdeliberatelycrafted. Throughhis pervasive

See, e.g., Briefof Amici Curiae by Certain Legal Historians on Behalfof Appellants, Citizens for
Responsibilityand Ethics in Washington et al. v. Trump, No. 18-474 (2nd Cir. 2018) ( online at
http://guptawessler.com/wp-content/uploads/2018/05/Doc-49-Legal-Historians-amicus-brief.pdf).
30 U.S. Constitution, Article II, § 3 .
31 AkhilReedAmar, America'sConstitution: A Biographyat 187( 2005) .

See James Madison's Version [ 18 June 1787] , National Archives Founders Online ( online athttps://founders.archives.gov/documents/Hamilton/01-04-02-0098-0003 ) ; Republican Government, Records oftheFederal Convention [ 1 : 134 ; Madison, 6 June 1787] (online at https://press
pubs.uchicago.edu/founders/documents/v1ch4s12.html ); Debates Which Arose In the House of Representatives ofSouth Carolina on the Constitution Framed for the United States at 12 ( 1831) ( online athttps://books.google.com/books?id=f06EhGPTz74C&pg=X&ved=2ahUKEwjrvMjp_cblAhUywVkKHc6eCgQQ6A# v = onepage& q % 22might
20to 20live

20in% 20greater% 20splendor% 20when 20out
20of

20his

20of 20office% 2C% 20he20receive% 20a% 20bribe% 20which
20in% 20another

20would% 20enable% 20him

20country% 20than% 20his% 20own% 3B% 20and

20was% 20no% 20more% 20interested

20country % 20than % 20any% 20other% 20patriotic

18

20citizen % 22 & f

20in% 20the% 20prosperity

false ) .

violations of the Clause, Trump in effect sought to govern as a get- rich- quick king, rather than anelected president acting in the exclusive fiduciary interest ofthe people.

As one federal court has observed , the Foreign Emoluments Clause was unquestionably
adopted against a background of profound concern on the part of the Framers over possible
At the end
foreign influence upon the President ( and, to be sure, upon other federal officials ) .
ofthe American Revolution, the Founders feared that foreign government influence would
corrupt the fledging American political experiment . In testament to the prominence of this fear,
and in rejection of the traditional gift- giving customs ofeighteenth - century European diplomacy ,the Articles of Confederation

not known for their restrictive natureprohibited the receipt ofany present, emolument , office, or title of any kind whatever , from any king, prince , or foreign
State ."

A decade later, at the Constitutional Convention, the delegates were deeply concernedthat foreign interests would try to use their wealth to tempt public servants and sway the foreign
policy decisions of the new government.
Forthat reason, a similar anti-foreign corruption
provision was added , without noted debate, to the Constitution. The Constitution's drafters
provided a single exception to this categorical prohibition against foreign government
emoluments for cases in which explicit congressional consent is granted to allow a president toretain them. 37 The retention of the Foreign Emoluments Clause by the Framers reflected theirconcern about the continuing risks of foreign corruption entangling high-rankingAmerican
officials. Itis notably one of the few phrases to make the jump from the Articles ofConfederation to the Federal Constitution, and it did so despite being a difficult provision tofollow
The carve- outallowingemolumentsfrom foreignstates only whenCongressgrants
approvalunderscoresboththe breadthand purposeofthe ForeignEmolumentsClause. By
submittingan emolumentfor congressionalapproval, an officeholder brings transparencyand
accountabilityto transactionsthat mightotherwiseremainburied, forcing federal officeholdersto

Dist ofColumbia v . Trump, 315 F. Supp.3d 875, 896 (D. Md. 2018) (citingZephyr Teachout, Corruptionin America: From Benjamin Franklin's Snuff Box to Citizens United 1-5 (2014) ).

34 ArticlesofConfederation, art VI, 1 (online at www.archives.gov/milestone-documents/articles-ofconfederation#transcript) ; Dist. ofColumbiav. Trump, 315 F. Supp.3d 875, 888-89 (D. Md. 2018) (citing Zephyr
Teachout, CorruptioninAmerica: FromBenjaminFranklin's SnuffBoxto Citizens United 1-5 (2014)) .
Dist. ofColumbia v. Trump, 315 F. Supp.3d at 896 ( quoting Zephyr Teachout , The Anti-Corruption
Principle, 94 Cornell L. Rev. 341, 361 (2009)) ( online athttps://scholarship.law.cornell.edu/cgi/viewcontent.cgi?article=3123&context=clr ) .

See The Emoluments Clauses andthe Presidency: BackgroundandRecentDevelopments, Congressional
Research Service, at 2 (Nov. 5 , 2019 (online at https://crsreports.congress.gov/product/pdf/R/R45992) (citingThe
Records ofthe Federal Convention of1787, at 389 (Max Farrand ed. , 1911)) .
37 Deborah S. Sills, The Foreign Emoluments Clause: Protecting Our National Security Interests, 26
Brooklyn Works , Journal of Law & Policy 63, 70–71 (2018) (online athttps://brooklynworks.brooklaw.edu/jlp/vol26/iss1/2/) .
38

Zephyr Teachout , Gifts, Offices , and Corruption , 107 Nw. U. L. Rev. 30, 39 (2012 ) (online athttps://scholarlycommons.law northwestern.edu/cgi/viewcontent.cgi?article=1039&context=nulr_online
19).

examine their judgments and opening the entire arrangement to probing scrutiny
Congressmust validate a transaction as not influencing a federal officeholder's judgment, or else must
accept political responsibility for unleashing foreign money, with all its corrupting and corrosive
influence, into the halls of federal power. 40 Further, the Clause is intended to reach not only
clear instances of quid pro quo corruption, to which Congress would never rationally consent,
but alltransactions , including ostensible market transactions , through which a foreign
government could subtly curry favor and ingratiate itself with any person holding an Office ofProfit or Trust . 41
Throughout the history of the Republic , both the Executive and Legislative Branches
have strictly adhered to the spirit and letter of the Foreign Emoluments Clause. In 1830,
President Andrew Jackson petitioned Congress to keep a gold medal presented to him by
Colombian President Simón Bolívar. Congress rejected his request and required that the medal
In 1840, President Martin Van Buren personallybe deposited in the Department of State.
refused multiple gifts from the Imam of Muscat, explaining that in doing so, he was observing afundamental law of the Republic which forbids its servants from accepting presents fromforeign States or Princes.

President Van Buren wrote , I deem it my duty to lay the

proposition before Congress for such disposition as they may think fit to make of it.

Congress

instructed him to give the items to the State Department or sell the items and give the proceeds to
the U.S. Treasury
In 1862, during the Civil War, President Abraham Lincoln informed
Congress that the King of Siam had personally presented him with a ceremonial sword and twoelephant tusks , amongst other favors.46 As beloved as Lincoln was to the Republican-controlled
Congress , it ordered him to deposit the gifts with the Department ofthe Interior.
47

Norman L. Eisen, Richard Painter, and Laurence H. Tribe, The Emoluments Clause: Its Text, Meaning
andApplication to Donald J. Trump , at 7 , Brookings Governance Studies (Dec. 16 , 2016) (online atwww.brookings.edu/wp-content/uploads/2016/12/gs_121616_emoluments-clause1.pdf ) .

. (citing Zephyr Teachout, Gifts, Offices, and Corruption, 107 NorthwesternUniversity Law Review
Colloquy 30, 36 ( 2012) ) .
41.

Message from the President ofthe United States 3 (Jan. 22 , 1834) , in Message from the Presidentof
the United States to the Two Houses ofCongress at the Commencement ofthe First Session ofthe Twenty-Third
Congress 259 (1833) .

Zephyr Teachout, Gifts, Offices, and Corruption, 107 NorthwesternUniversity Law ReviewColloquy30,
42 (2012) (citing 14 Abridgmentof the Debates of Congress from 1789 to 1856 141( Thomas HartBentoned.,
1860)) .
The AmericanPresidencyProject, MartinVan Buren, SpecialMessageto Congress( onlineat
www.presidency.ucsb.edu/node/200980) ( accessedDec.8 , 2023) .

45

S.J. Res . 4 , 26th Cong., 5 Stat. 409 ( 1840) (enacted) .
Lincolnto ThaiKing: ThanksbutNoThanksfor the Elephants, StateJournal- Register( Apr. 1 , 2018)( onlineatwww.sj-r.com/story/news/2018/04/01/lincoln-to-thai-king-thanks/12849296007/).

See J. Res. 20, 37th Cong. ( 1862) ( A Resolution providing for the Custody of the Letter and Gifts fromthe King of Siam ) . U.S. Senate, Party Division (online atwww.senate.gov/pagelayout/history/one_item_and_teasers/partydiv.htm ) ( accessed Dec. 12 , 2023) ; U.S. House ofRepresentatives, Party Divisions ofthe House ofRepresentatives, 1789 to Present (online athttps://history house.gov/Institution/Party-Divisions/Party-Divisions/) (accessed Dec. 12, 2023) ; White House,
Abraham Lincoln The 16th President OfThe United States (online at www.whitehouse.gov/about-the-white20

Inthe modern age, the treatment of honors received by Presidents John F. Kennedy andBarack Obama from foreign nations once again confirmed the broad scope of the Foreign
Emoluments Clause. In 1963 , the Irish Government awarded President Kennedy honorary Irish
citizenship . Reiterating the conclusion that the Foreign Emoluments Clause was directedagainst every kindofinfluence by foreign governments upon officers of the United States, basedon our historic policies as a nation, the DOJ determined that acceptance would fall within thespirit, ifnot the letter of the Clause’s prohibition.

President Kennedy declined the honor.49 In

2009, President Obama accepted the Nobel Peace Prize only after the DOJ determined that the
selection process was independent from the influence ofthe Norwegian government . Inreaching
this conclusion, however, the DOJ Office of Legal Counsel ( OLC) once again affirmed that theClause applies to the President because the President surely holds an Office ofProfit or
Trust
President Obama promptly donated the $ 1.4 million Nobel Prize money to charity.51
Inadvisoryopinionsissuedduringthe modernera, the DOJhas broadlydefined" emolument as reachingthe benefits, gains, or advantagesthat flow from transactionalbusiness
relationshipswith foreigngovernmentsor entities, includingprivatetransactions.

Moreover,federaldistrictcourtsthat addressedthis issue incases broughtagainstthen- PresidentTrump
havelikewiseconcludedthat the Clausereachesprofitsarisingfrom privateor market

house/ presidents/ abraham- lincoln/ ) ( accessedDec. 13, 2023) .
48

Proposal That the President Accept Honorary Irish Citizenship , 1 Op. O.L.C. Supp . 278 (1963) (onlineat www.justice.gov/d9/olc/opinions/1963/05/31/op-olc-supp-v001-p0278_0.pdf).

Blumenthal, Dems to Sue Trump Over Emoluments Clause , New Haven Register (June 14, 2017) (onlineat www nhregister.com/connecticut/article/Blumenthal-Dems-to-sue-Trump-over-Emoluments-11313611.php
50).

Applicabilityofthe EmolumentsClause andthe ForeignGifts andDecorationsAct to the President's

Receiptofthe NobelPeace Prize, 33 Op . O.L.C.370, 374 (2009) (onlineat
www.justice.gov/d9/opinions/attachments/2020/12/22/2009-12-07-potus-nobel.pdf) . PresidentTrump didnot
disputethat the ForeignEmoluments Clause applied to the Presidentin litigationchallenginghis receiptsof foreign
paymentsthatwere dismissedon standinggrounds. Dist. of Columbia v. Trump, 315 F. Supp. 3d 875, 880 (D.Md.
2018) (findingthe Foreign EmolumentsClause applies to the Presidentbecause amicus curiaeraisedissue);Blumenthalv. Trump, 373 F. Supp. 3d 191, 196 n.3 (D.D.C.2019) ( The parties do notdispute that the [ Foreign
Emoluments] Clause applies to the President. ) .
The White House, Press Release: The PresidentDonates NobelPrize Money to Charity (Mar. 11, 2010)(online at https://obamawhitehouse.archives.gov/the-press-office/president-donates-nobel-prize-money-charity).

Applicability ofEmoluments Clause to Proposed Service ofGovernment Employee on Comm'n ofInt'lHistorians, 11 Op . O.L.C. 89 , 90 ( 1987) ( online at www.justice.gov/d9/olc/opinions/1987/07/31/op-olc-v011
p0089_0.pdf) (The Foreign Emoluments Clause encompasses every kind of influence by foreign governments upon
officers of the United States due to its expansive language and underlying purpose. ) ; Applicability ofthe
Emoluments Clause to Non-Government Members ofACUS , 17 Op. O.L.C. 114 ( 1993) (online atwww.justice.gov/file/20456/download ) (finding that the Foreign Emoluments Clause does not permit a part-time
federal officer to receive income, earned in market transactions, from a private business partnership that includes
earnings from a foreign government client , even where the federal officer did not represent or interact with theforeign client) ; Memorandum for H. Gerald Staub, Office of ChiefCounsel, NASA, from Samuel A. Alito, Jr. ,DeputyAssistant Attorney General, Office ofLegal Counsel, Re. Emoluments Clause Questions raised by NASA
Scientist's Proposed Consulting Arrangement with the University ofNew South Wales (May 23 , 1986) (online atwww.politico.com/f/?id=00000158-b547-dble-alf9-ff7f60920001 ) ( concluding summarily that a stipend or
consulting fee from a foreign government would ordinarily be considered an emolument within the meaning ofthe
constitutional prohibition even when the work was performed inthe employee's private business capacity).
21

transactions .

The opinions are consistent with the expansive language of the Clause, whichrefers to any present , Emolument , Office, or Title , ofany kind whatever

and also the Framers

intent to protect against the possibility that foreign nations would propose personal business
transactions with American federal officials to obtain preferential policy treatment from them.54

Former President Trump's shocking departure from these deeply established and longobserved principles caused significant public controversy during his Administration . Although
he never sought congressional permission to keep any of the millions of dollars he collected fromforeign governments and foreign government- owned companies , the American public took
notice ofthe rampant flow of funds to his businesses from these sources . The attorneys generalofthe Districtof Columbia and Maryland, Members of Congress , several public interest groups,
and others brought or supported legal actions to try to stop these violations of the Foreign
Emoluments Clause. Ultimately, the lawsuits were never decided on the merits because thecourts dismissed them on threshold procedural grounds , including that the parties lacked legal
standing to sue or that the litigation became moot after Donald Trump left office.
As one of those courts concluded with respect to former President Trump :S ole or substantial ownership of a business that receives hundreds of thousands or
millions of dollars a year in revenue from one of its hotel properties where foreign anddomestic governments are known to stay (often with the express purpose of cultivating
the President's good graces) most definitely raises the potential for undue influence, andwould be well within the contemplation of the [Foreign and Domestic Emoluments]
Clauses 56
President Trump's refusal to divest from his expansive business empire andcorresponding refusal to stop doing business with foreign governments and royalty set up the
likelihood of repeated breaches of the Foreign Emoluments Clause and a clash between his
business interests and his obligations to the nation that existed throughout his Administration .
Both the constitutional violations and the ethical conflicts of interest came to pass in strikingly
swift, vivid, and nefarious ways .
Donald Trump's Refusal to Divest from His Businesses Upon Entering Office andResulting Foreign Conflicts

President Trump entered office with two primary sets of business assets particularly
susceptible to foreign influence: his domestic business holdings, including hotels and real estate,Dist. ofColumbia v. Trump, 315 F. Supp . 3d 875 (D. Md. 2018) ; Blumenthal v. Trump, 373 F. Supp. 3d
191 (D.D.C. 2019) .
54 U.S.Constitution, Article I ,9 , cl. 8 .

See Congressional Research Service, The Emoluments Clausesof the U.S. Constitution, at 2 (Jan. 27,2021) ( citing Citizens for Responsibility & Ethics in Washington v . Trump, No. 17- CV-458 (S.D.N.Y.) ; Dist. of
Columbiav . Trump, No. 17-1596 (D. Md. ); and Blumenthal v. Trump, No. 17-1154 (D.D.C.)) (online athttps://crsreports.congress.gov/product/pdf/IF/IF11086).
Dist. ofColumbiav . Trump, 315 F. Supp. 3d 875, 899 ( D. Md. 2018) .
22

which were positioned to reap revenues from foreign government or state - linked customers ; andhis business holdings abroad, which were also positioned to reap revenues while being directly
subject to the regulation and oversight of foreign governments . As one federal appellate judge
explained in one of the cases brought against former President Trump under the Emoluments
Clause arising out of precisely this conflict :Governments and their diplomats perceive it as crucial to their success in diplomacy with
the United States to secure the personal goodwill of the President and avoid the risk of
incurring his displeasure . The President's favor is a lucrative prize for a foreign diplomat
whose visits to our country often have the purpose of seeking some favorable action fromthe government which the President largely controls
In addition , the President ,according to the allegations ofthe complaint , has announced to the world his favoritism
for nations that patronize his businesses . It follows with undeniable logic that the envoys
offoreign nations, who are free to choose equivalent venues , will be strongly motivatedto choose the President's establishments , so as to advance their objective of currying thePresident's favor, and to avoid the risk of displeasing him by choosing his competitors .

This concern was borne out shortly after Mr.Trump's election in 2016, whenapproximately 100 foreign diplomats from a range of foreign governments gathered at a
promotional event for the Trump International Hotel in Washington, D.C. As the Washington
Post reported:
Believe me, all the delegations will go there,

said one Middle Eastern diplomat who

recently toured the hotel and booked an overseas visitor. The diplomat said many stayed
away from the hotel before the election for fear of a Clinton backlash, but that now it's
the place to be seen.
Ininterviewswith a dozen diplomats, many of whom declined to be named because they
were not authorized to speak about anything related to the next U.S. president, some said
spendingmoney at Trump's hotel is an easy, friendly gesture to the new president.

Why wouldn'tI stay at his hotelblocks from the White House, so I can tell the newpresident,
love your new hotel Isn'tit rude to come to his city and say, I am staying
at your competitor? said oneAsiandiplomat.
Guests at the Trump hotel have begun parking themselves in the lobby, ordering

expensive cocktails, hoping to see one of the Trump family members orthe latest Cabinet
pick One foreign official hoped

famous for the personal interest he takes in his

businesses , might check the guest logs himself.

Between Mr.Trump's election and his assumption of office, both Republican and
Democratic ethics experts urged Donald Trump to divest from his business holdings and place
Citizens for Responsibility & Ethics in Washington v . Trump , 971 F.3d 102 ( 2d Cir. 2020) .

For Foreign Diplomats, Trump Hotel Is Place to Be, Washington Post (Nov. 18, 2016) (online atwww.washingtonpost.com/business/capitalbusiness/2016/11/18/9da9c572-ad18-11e6-977a
1030f822fc35_story.html ) .

23them in an independent blind trust to avoid the appearance of divided loyalties. One letter,signed by 29 such experts, issued a blunt warning:

As long as you continue to maintain ownership of The Trump Organization , no othersteps that you take will prevent the serious conflicts of interest , appearance of conflicts ,and Emoluments Clause problems that will exist throughout your presidency . Inthesecircumstances , you cannot separate the presidency from your business enterprises .59

Donald Trump cavalierly ignored this warning . Instead, before entering office , Mr.
Trump transferred nearly all of his business holdings , including the four properties discussed inthis report, into the Donald J. Trump Revocable Trust . This trust , however, was anything but
independent . It was controlled by two trustees : Donald Trump Jr. and Trump Organization
Chief Financial Officer Allen Weisselberg . Although this structure created the illusion of
separation between Mr. Trump and his business interests , in reality, President Trump retained
effective control over , and the complete financial benefit of, his businesses.60
By its own terms, the purpose of the Trust is to hold assets for the benefitof Donald J.
Mr.Trump Jr. and Mr. Weisselbergmanagedthe Trust accordinglyand could
Trump
distributenet income or principalto DonaldJ. Trump at his request.

PresidentTrump wasable to quietly draw downany moneyfrom his trust whenever he wanted as well as receive
reports on anyprofit, or loss, on his businesses.
For example , in 2019 , the Committee obtained documents and testimony showing
evidence that both President Trump and the Donald J. Trump Revocable Trust reimbursed Mr.

EthicsAdvocates Warn Trump That He Needs to Do Moreto Divestfrom Family Business, Washington
Post (Jan. 2, 2017) (online at www.washingtonpost.com/news/post-politics/wp/2017/01/02/ethic-advocates-warn
trump-that-he-needs-to-do-more-to-divest- from-family -business ) . Then-Ranking Member Cummings hosted aforum inDecember2016 with bipartisan ethics experts who addressed the unprecedented conflicts faced by thenPresident-Elect Trump. Committee on Oversight and GovernmentReform Democrats, PressRelease: Cummings to
HostForum with Bipartisan EthicsExperts on Trump's Conflicts ofInterest (Dec. 13, 2016) (online athttps://oversightdemocrats.house.gov/news/press-releases/cummings-to-host-forum-with-bipartisan-ethics-experts
on- trump - s- conflicts - of- 0 ) .

Allen WeisselbergResignedfrom the Top ofThe Trump Organization. So Who's Runningthe Company
Now Washington Post ( July 21, 2021) (online at www.washingtonpost.com/politics/2021/07/21/weisselberg
trump-organization-eric-donald-ivanka ) . Donald Trump's lawyer confirmed, from the beginning of his presidency,that his most profitable real estate holdings, including Trump Tower, Mar-a- Lago, and 40 Wall Street, weretransferred into the Trust .
Falls ort in Every Respect : Ethics Experts Pan Trump's Conflicts Plan, NewYork Times (Jan. 12, 2017) (online at www.nytimes.com/interactive/2017/01/12/us/politics/ethics-experts-trumps
conflicts-of-interesthtml) .
Certification of Trustee of the Donald J. Trump Revocable Trust , at 161 (Feb. 10, 2017) (online atwww.gsa.gov/cdnstatic/Contracting_Officer_Letter_March_23_2017_Redacted_Version.pdf).

62 Id.; See, e.g. , Trust Records Show Trump Is Still Closely Tied to His Empire, New York Times (Feb. 3 ,2017) (online at www.nytimes.com/2017/02/03/us/politics/donald-trump-business

63html) .

Trump Can Quietly Draw Moneyfrom Trust Whenever He Wants, New Documents Show Washington

Post(Apr. 3 , 2017) (online at www.washingtonpost.com/politics/trump-can-quietly-draw-money-from-trust
whenever- he- wants- new- documents- show/ 2017/ 04/ 03/ 7f4c0002-187c- 11e7-9887-1a5314b56a08_story.html) .

24

Trump's personal lawyer, Michael Cohen, for illegal campaign contributions .
This information
formed the core of Manhattan District Attorney Alvin Bragg's April 2023 indictment of former
President Donald Trump in the Supreme Court of New York State. Also in 2019, Mr. Cohentestified before the Oversight Committee that Mr. Trump inflated the value of his assets instatements to banks and insurers in order to obtain more advantageous terms for loans andinsurance coverage, and in addition, that Mr. Trump provided deflated valuations to lower realestate taxes on certain assets.66 Mr. Cohen's testimony led the New York State Attorney General
to open an investigation of Mr. Trump and The Trump Organization that same year, and later
bring the lawsuit in which Mr. Trump was found to have defrauded banks and insurers byproviding these false valuations.67
ClaimedDonationof Profits by The Trump Organization to the U.S. Treasury Did
NotAvoid Trump's MyriadViolations ofthe Foreign Emoluments Clause

Several months into President Trump's term , The Trump Organization issued a pamphlet
describing its voluntary directive to donate all profits from foreign governments patronage at
our hotels and similar businesses during President Trump's presidential term to the U.S.
Treasury
This policy however, clearly failed to comply with the Constitution , which
imposes a total ban on the receipt of any revenue from foreign governments
not just
profits

absent congressional approval .

Because itwas limited to profits,

and did not extend to revenues generally, this policy

was insufficient on its face to comply with the Foreign Emoluments Clause . The standard legal

Committee on Oversight and Reform, PressRelease: New InformationRevealed in Oversight Hearing
with Michael Cohen (Feb. 27, 2019) (online at https://oversightdemocrats.house.gov/news/press-releases/new
information-revealed-in-oversight-hearing-with-michael-cohen); Committee on Oversight and Reform, Hearing
with Michael
FormerAttorney to PresidentDonaldTrump, 116th Cong, Transcript 14, 21-22 (Feb. 27,2019) (online at www.congress.gov/116/chrg/CHRG-116hhrg35230/CHRG-116hhrg35230.pdf).
65 The Porn Star The Checks and The President: Trump's Tawdry Pathto Peril, Washington Post (Mar.21,2023) (online at www.washingtonpost.com/politics/2023/03/21/trump-stormy-payments/ ); Manhattan District
Attorney's Office, Press Release : District Attorney BraggAnnounces 34- Count Felony Indictment ofFormer
PresidentDonaldJ. Trump ( Apr. 4, 2023 ) (online at https://manhattanda.org/district-attorney-bragg-announces-34
count-felony-indictment-of-former -president-donald-j-trump/) .
Committee on Oversight and Reform , Hearing with Michael Cohen, Former Attorney to President
Donald Trump , 116th Cong, Transcript at 13 , 19, 37–39, 160 (Feb. 27, 2019) ( online atwww.congress.gov/116/chrg/CHRG-116hhrg35230/CHRG-116hhrg35230.pdf ) .

67 Office ofthe New York State Attorney General, Press Release: Attorney General James Takes Action to
Force Trump Organization to Comply with Ongoing Investigation Into FinancialDealings (Aug. 4, 202) (online athttps://ag.ny.gov/press-release/2020/attorney-general-james-takes-action-force-trump-organization-comply
ongoing) Trump Committed Fraudby InflatingHis Assets, Judge Rules , Forbes (Sept. 26, 2023) (online atwww.forbes.com/sites/alisondurkee/2023/09/26/trump-committed-fraud-by-inflating-his-assets-judge-rules ).

Letter from RankingMember ElijahE.Cummings, Committee on Oversight and Government Reform, toGeorgeA. Sorial, ExecutiveVice Presidentand ChiefComplianceOfficer, Trump Organization(May 24, 2017)(online at https://oversightdemocrats house.gov/sites/democrats.oversight.house.gov/files/documents/2017-05
24.EEC 20to 20Trump 20Organization.pdf) ; Trump Organization, DonationofProfitsfrom Foreign
GovernmentPatronage( onlineat
https://oversightdemocrats.house.gov/sites/democrats.oversight

hlet

20Foreign% 20Profits.pdf) .
25

house.gov/files/documents/Trump%20Org%20Pamp

dictionary definition of emolument, as well as rulings by federal courts that have addressedthe
issue, make clear than an emolument includes anybenefit, gain, or advantage. 69 As one ofthose courts observed, this definition essentially cover[ s] anything ofvalue

Byits own

terms, The Trump Organization's claimed donation of profits to Treasury, therefore, stillallowedformer PresidentTrump to retain significant emoluments in the form of revenues, which
its policy excluded from the funds designated for donation.

Moreover, the policy substantially limited the scope of profits it covered to those ( 1)generated from foreign governments patronage from wholly -owned Properties, and (2 )generated from management fees earned from managed hotels and condominium -hotels
attributed to foreign governments patronage .
By excluding non-wholly owned and non- hotel
Trump properties , the policy omitted potentially significant sums from the already truncatedcategory of emoluments that it covered . For example, this report identifies more than $ 1 million
in foreign emoluments paid to Trump World Tower in New York which fall outside the scope of
The Trump Organization's policy.
The policy further reserved the right of The Trump Organization to exclude from its
calculation of profit state- owned and state- controlled entities in industries such as aerospace anddefense , banking , finance , healthcare , energy and others , which may not be reasonably
identifiable as foreign government entities [ .]Finally, the policy expressly stated that The Trump Organization would not even attempt
to identify all emoluments , claiming that complying with this constitutional requirement would
be impractical and that a policy that requires all guests to identify themselves would impede
As such, under The
upon personal privacy and diminish the guest experience of our brand.
Trump Organization's policy, the only profits reported were those volunteered by foreign
governments, and Trump -owned businesses never opened their books to allow review of theirtreatment ofthese payments. It is hard to imagine a more ludicrous and half-hearted approach tothe categorical prohibition in the Constitution.

The significant benefit to former President Trump from revenues generallyof any profits

regardlessis demonstrated by the precarious financial condition ofthe Trump International

Hotel in Washington , D.C., during his presidency. As Committee Democrats have previously
69

Congressional Research Service, The Emoluments Clauses ofthe U.S. Constitution, at 1 (Jan. 27, 2021)( emphasis added) ( online at https://crsreports.congress.gov/product/pdf/IF/IF11086 ) (citing Blumenthal v. Trump ,373 F. Supp.3d 191, 207 (D.D.C. 2019) ; Dist. ofColumbia v . Trump , 315 F. Supp.3d 875,889 (D. Md . 2018);.

Dist. of Columbiav. Trump, 315

875,889(D. Md. 2018) .

Letter from Ranking Member Elijah E. Cummings, Committee on Oversight and Government Reform, toGeorge A. Sorial, Executive Vice President and Chief Compliance Officer, Trump Organization (May 24, 2017)(online at https://oversightdemocrats house.gov/sites/democrats.oversight.house.gov/files/documents/2017-05
24.EEC 20to%20Trump%20Organization.pdf); Trump Organization, DonationofProfitsfrom Foreign
Government Patronage (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight

hlet

20Foreign 20Profits.pdf) .

.
.

26

house.gov/files/documents/Trump%20Org%20Pamp

reported, a review of financial documents regardingthe Trump International Hotelin

Washington , D.C., provided by the General Services Administration (GSA) revealed that while
President Trump claimed on required financial disclosures that he made $ 156 million in
employment income from the hotel between 2016 and 2020, the hotel in fact lost more than $73
million during this period.74 Reflecting the serious financial problems at the Trump International
Hotel in Washington , D.C., annual financial statements obtained by the Committee also revealthat one of President Trump's holding companies , DJT Holdings LLC , injected tens ofmillions
ofdollars into the Trump International Hotel as loans , the vast majority of which were neverrepaid and were later converted to capital contributions . The hotel's significant losses were due
inpart to the hotel's fixed costs, including general and administrative expenses, sales andmarketing expenses , and property operations and maintenance .75 Given that the hotel was
operating at a significant loss, foreign government revenue would have helped to cover a portionof these fixed costs, even ifalleged profits were donated.
Underthe Trump Administration, FederalAgencies Acquiesced to President Trump's
Receiptof UnconstitutionalForeign Emoluments

Incontravention of the Constitution's explicit prohibition on a president's receipt of
foreign emoluments , federal agencies under the Trump Administration repeatedly acquiesced toformer President Trump's desire to continue profiting from his businesses while in office. One
notable instance involved the Trump International Hotel in Washington , D.C., which is located in
the Old Post Office Pavilion an historic building that has a lease overseen by the federal GSA .
The contract for the lease included a provision specifying that noelected official ofthe
Government ofthe United States
benefit that may arise there from.

shall be admitted to any share or part of this Lease, or to any
Despite the clear language of this provision , the agency

released a statement in March 2017 explaining that the agency had found that then- President
Trump was in full compliancewith the lease because his trust was a party to the lease rather

than him personally.77 Some within GSA , however , were concerned that this position violated
the Foreign Emoluments Clause , the Domestic Emoluments Clause , and the plain terms ofthelease prohibiting elected officials from being leaseholders.78 These concerns were merited, and74 Letter from Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, to Administrator
Robin Carnahan, General Services Administration (Oct. 8 , 2021) ( online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/2021-10
08.CBM

20GEC % 20to % 20Carnahan - GSA% 20re %75

20Post20Office

20Building

20Lease.pdf) .

.

TrumpLeasesHisD.C.Hotelfrom a GovernmentAgency He'llSoon Be inCharge of WashingtonPost(Nov.15, 2016) (online at www.washingtonpost.com/posteverything/wp/2016/11/15/trump-needs-to-give-up-his
trump-hotel-lease-right-now ) .

General Services Administration , Press Release: GSA Releases Statement on Old Post Office Lease(Mar. 23, 2017) (online at www.gsa.gov/about-us/newsroom/news-releases/gsa-releases-statement-on-old-postoffice-03232017 ) .

78 General Services Administration , Office of the Inspector General, Evaluation of GSA's Management andAdministration ofthe Old Post Office Building Lease ( italics in original ) (JE19-002 , Redacted ) (Jan. 16, 2019)( online at www.gsaig.gov/sites/default/files/ipa-reports/JE19-002%20OIG%20EVALUATION%20REPORTGSA 27s%20Management %20%26%20Administration %20of% 20Building 20Lease_January 2016%2
02019_Redacted.pdf) .
27

the GSA InspectorGenerallater determinedthat

decision-makingprocess regardingthis

matter includedseriousshortcomings. Accordingto GSA's InspectorGeneral, GSA's lawyers
understoodthat PresidentTrump's continuedinterestin the Trump InternationalHotel was a
possibleviolationof the ForeignEmolumentsClause but neverthelesssimply decidedto puntand notto address the issue.
the Constitution."As the InspectorGeneral'sreport succinctlystated, GSAIgnored

Similarly, in 2017 , the Department of State approved leases by foreign governments at
Trump World Tower in New York thereby creating a situation in which an agency overseen by
the president directly sanctioned unconstitutional emoluments flowing to the president.80 Itis
unclear to what extent the State Department considered the Constitution before approving theseleases. It is clear , however, that the President accepted these emoluments without seeking
Congress's approval in violation of the prohibition set forth in the Constitution .
TheOwnershipStructureofTrump PropertiesDiscussedinthis Report

This reportfocuses on foreignspendingand relatedconflicts in connectionwiththree
Trumppropertiesfor whichMazars produced records to the Committee:
The Trump International Hotel in Washington, D.C.;
The TrumpInternational
Hotelin LasVegas, Nevada; andThe TrumpWorldTower at 845 UnitedNationsPlazain NewYork, New York.

In addition, the report discusses foreign spending at the Trump Tower on FifthAvenue in
New York, New York, as reflected in publicly available information.

As of2020, the Donald J. Trump Revocable Trust owned, either directly or indirectly, asprawling web of 558 corporate entities , which together comprised The Trump Organization .
Given the number of corporate entities , the four properties discussed in this report constituted
less than 1% of the businesses Donald Trump owned while he was President . The Committee
did not receive from Mazars any documents regarding at least 80% of Donald Trump's business
entities . For many other entities , Mazars produced only a single document . Accordingly , theMazars records and publicly available information shed light on only a small fraction of thesecompanies , leaving unknown the purpose and financial activities of hundreds of opaque entities
under Mr. Trump's control. ( italics inoriginal)
Exclusive : Foreign Government Leases at Trump World Tower Stir More Emoluments Concerns , Reuters(May 2 , 2019) ( online at www reuters.com/article/us-usa-trump-emoluments-exclusive/exclusive-foreign
government - leases- at- trump- world - tower- stir- more- emoluments - concerns- idUSKCN1S80PP ) .

.

Office of Government Ethics , Executive Branch Personnel Public Financial Disclosures (OGE Form278e) (Donald J. Trump ) (Filed June 14, 2017) (online at https://s3.documentcloud.org/documents/21154684/trumpoge -2017.pdf); Office of Government Ethics ,Executive Branch Personnel Public Financial Disclosures (OGE Form278e) (Donald J. Trump ) (Filed May 15, 2018) (online at https://s3.documentcloud.org/documents/21154685/trumpoge -2018.pdf); Office of Government Ethics , Executive Branch Personnel Public Financial Disclosures (OGE Form278e) (Donald J. Trump ) (Filed May 15,2019) (online at https://s3.documentcloud.org/documents/21154683/trump28

Based on former President Trump's required disclosures with the Office of Government
Ethics for the years 2017 through 2020 , following the transfer of his assets to the Trust , the four
properties discussed in this report were owned either solely by the Trust, or co- owned by theTrust with Mr. Trump's children or a Trump business associate , through various entities whollyor partially owned by Mr. Trump . As the charts below demonstrate , Mr. Trump and his family
members owned each of these properties through a complex web of limited liability corporations
and other entities.

And as detailed in this report, through these intricate and opaque ownership

structures , former President Trump received millions of dollars from foreign governments ,foreign government - owned or -controlled entities , and individuals acting on behalf of them .

oge- 2019.pdf) ; Office of Government Ethics, Executive Branch Personnel Public Financial Disclosures (OGE Form278e) (Donald J. Trump) (Filed July 31, 2020 ) (online athttps://s3.documentcloud.org/documents/7012257/President-Donald-Trump-2020-financial-disclosure.pdf) ; OfficeofGovernment Ethics, Executive Branch Personnel Public Financial Disclosures (OGE Form 278e) (Donald J.
Trump ) (Filed Jan. 15, 2021 ) (online athttps://extapps2.oge.gov/201/Presiden nsf/PAS +Index/ 6E78B163F816EF6A852586630075291D / $FILE/ Trump, 20
Donald 20J 202021 Termination 20278.pdf) ; see also Decision and Order, People ofthe State ofNew York v
DonaldJ. Trump et al., Index No. 452564/2022 at 32 (N.Y. Sup. Ct. Sept. 26, 2023 ) ( Defendants do not disputethat DJT Holdings LLC and DJT Holdings Managing Member LLC are entities that sit at the top ofthe Trump
Organization's organizational chart and together own many of the Trump -affiliated entities that comprise the Trump
Organization . DJT Holdings LLC owns 100% of the Trump Organization and DJT Holdings LLC owns 100% ofthe
Trump Organization LLC ) (online at www.documentcloud.org/documents/23991872-ny-ruling-on-trump-businessfraud) ; Trump, His Children , and 500+ Potential Conflicts ofInterest, Wall Street Journal (Jan. 19 , 2017) (online atwww.wsj.com/graphics/donald-trump-potential-conflicts-of-interest/ ) ; What Trump's Disclosure ofHis 500
Can and Can't Tell Us, NBC News (May 16, 2018) (online at www nbcnews.com/business/taxes/what-trump-s
disclosure -his-can-can-t-n874391) .
Id.; Prepared from information contained in Executive Branch Personnel Public Financial Disclosure
Reports filed by Donald J. Trump for the years 2017-2020 .

Source: Office of Government Ethics, Executive Branch Personnel Public Financial Disclosures ( OGE
Form278e) (Donald J. Trump) (Filed June 14, 2017) (online athttps://s3.documentcloud.org/documents/21154684/trump-oge-2017.pdf) ; Office of Government Ethics, Executive
Branch Personnel Public FinancialDisclosures (OGE Form 278e) (Donald J. Trump) (Filed May 15, 2018) (online
at https://s3.documentcloud.org/documents/21154685/trump-oge-2018.pdf) ; Office of Government Ethics,
Executive Branch Personnel Public Financial Disclosures ( OGE Form 278e) (Donald J. Trump) (Filed May 15,2019) (online at https://s3.documentcloud.org/documents/21154683/trump-oge-2019.pdf); Office of Government
Ethics, Executive Branch Personnel Public Financial Disclosures ( OGE Form 278e) (Donald J. Trump) (FiledJuly
31, 2020) (online at https://s3.documentcloud.org/documents/7012257/President-Donald-Trump-2020-financial
disclosure.pdf) ; Office of Government Ethics, Executive Branch Personnel Public Financial Disclosures (OGE Form278e) (Donald J. Trump) (FiledJan. 15, 2021) (online athttps://extapps2.oge.gov/201/Presiden
nsf/ PAS+ Index/6E78B163F816EF6A852586630075291D/ $ FILE/Trump
20J

202021 Termination

20278.pdf) .

29

2

Trump InternationalHotelWashington D.C.

Trump FamilyMembers

DonaldJ. TrumpRevocableTrust

IvankaTrump
RevocableTrust

DonaldJ. Trump Jr.
Revocable Trust

Eric F. Trump
RevocableTrust

100%

IvankaOPO LLC
DJT HoldingsManaging

Don

LLC

EricOPO LLC(Eric

7.5%

Member LLC

IvankaTrump)(DonaldTrumpJr.)

TrumpJr.)

7.425
%

7.425
%

7.425%

%

7.5
%

1 %

%

99
%

TrumpOPO MemberCorp.

DJT Holdings LLC

76.725%

1 %Trump OPO LLC( TrumpInternational
HotelWashingtonD.C.
)

30

Trump International Hotel Las Vegas

DonaldJ. TrumpRevocable
Trust

-100
%

-99
%

DJT Holdings
Managing
Member LLC

100%
-1
%

DJT Holdings LLC

TrumpLasVegasCorp
-94%
94
%

6 %

6 %

TrumpLasVegasManaging

TrumpLasVegasMemberLLC

Hyde Park LLC

MemberLLC-49%

TrumpRuffinLLC

-50%

100%

TrumpRuffinTowerI LLC

100
%

LLC
TrumpRuffinCommercial( TrumpInternationalHotelLasVegas)

31

-1
%

Trump World Tower , 845 United Nations Plaza

DonaldJ.TrumpRevocable
Trust

-100%

100%

99.9
%

Trump845 U.N. MGR Corp.

-0.1%

Trump 845 U.N. GP LLC

845 LP LLC

-40 %

-

%

845U.N.LimitedPartnership( TrumpWorldTower)

32

TrumpTower CommercialCondominiumProperty, New York

Donald J. Trump Revocable Trust-100 %

100%

99%

Tipperary Realty Corp

Trump TowerManaging

Trump Equitable Fifth Avenue

MemberInc.

Company-1%99%

Trump Tower CommercialLLC
1 %( Trump Tower Commerical Condominium
Property, New York)The Committee's Investigation

Daysafterthe2016 presidential election, RepresentativeElijah E. Cummings, then
RankingMemberofthe Committee on Oversight and GovernmentReform (subsequently
renamedthe Committee on Oversight and Reform and then the Committee on Oversight andAccountability) , expressed concerns that Mr. Trump's business entanglements could threaten theaccountabilityand transparency of the Executive Branch and threaten U.S. nationalsecurity.
RankingMemberCummingswrote to then-ChairmanJason Chaffetz:
to requestthatthe OversightCommitteeimmediatelybegin conductinga reviewof
President- elect DonaldTrump's financialarrangementsto ensurethat he does not haveany actualor perceivedconflictsofinterestand that he and his advisors comply with alllegaland regulatoryethicalrequirementswhenhe assumes the presidency.85

Letter From Ranking Member Elijah E. Cummings , Committee on Oversight and Government Reform,
to Chairman Jason Chaffetz , Committee on Oversight and Government Reform ( online athttps://oversightdemocrats.house.gov/sites/democrats .oversight house.gov/files/documents/2016-11
14.EEC%20to% 20JC%20%28003% 29.pdf) .
33

The Committee on Oversight and Accountability is charged by the House ofRepresentatives with legislative and oversight jurisdiction over the federal civil service ,including the Office of Government Ethics, which oversees the compliance of officers andemployees ofthe United States with federal ethics laws and rules . Further, the Committee on
Pursuant
Oversight and Accountability may at any time conduct investigations of any matter.
86

to these authorities , the Committee has examined the adequacy of existing ethics and financial
disclosure laws and agency implementation to inform Congress's consideration of proposed
ethics reforms , including reforms specifically applicable to the President .

InApril 2017, the Republican- led Committee sent a bipartisan letter to The Trump
Organization requesting documents and information about its processes for identifying paymentsfrom foreign governments and entities they control . The letter noted that a Trump Organization
spokesperson on March 17 announced that the company has developed a policy to identify
foreign government customers and donate profits but expressed concern that details of the plan
to donate profits derived from foreign government payments, however, are still unclear.
The
letter requested documents and a meeting with Trump Organization officials to determine how
the President intended to comply with the Constitution's prohibition on foreign emoluments . In
response to its letter, the Committee received the approximately 40-sentence pamphlet discussed
above that detailed The Trump Organization's voluntary directive to donate all profits fromforeign governments patronage at our hotels and similar businesses during President Trump's
presidential term to the U.S. Treasury
In its letter enclosing the pamphlet , The Trump Organization stated that for several oftheCommittee's specific document requests including , among others , the Committee's requests for
documents regarding public reporting on donations to the U.S. Treasury made by The Trump
Organization , whether donations would be claimed by The Trump Organization or by President
Trump as tax deductions , and the specific entities within The Trump Organization that would be
donating profits

we believe it is premature to respond at this time insofar as final

86

Rules ofthe HouseofRepresentatives, 118th Cong. (hereinafter House Rules ) Rule X.1(n) ( 1) ; U.S.
Officeof GovernmentEthics, WhatWe Do ( online at www.oge.gov/web/ogensf/ about_what- we-do) (accessedDec.
18, 2023) .
87 HouseRulesat RuleX ,4 ( c) ( 2) .

See, e.g. H.R. 1, Forthe PeopleAct, 116thCong. (2019); H.R. 745, ExecutiveBranchComprehensive
EthicsEnforcementActof2019, 116thCong. (2019) ; see also H.R. 5314, ProtectingOurDemocracyAct, 117th
Cong. ( 2021) .
88

89

Letter from Chairman Jason Chaffetz and Ranking Member Elijah E. Cummings, Committee onOversightandGovernment Reform, to Sheri A. Dillon, Partner, Morgan Lewis (Apr. 21, 2017) ( online athttps://oversight.house.gov/wp-content/uploads/2017/04/2017-04-21-JEC-EEC-to-Dillon-Trump-Emoluments
Plan.pdf).
90

Trump OrgSays Singling Out Profitsfrom Foreign Guests Is Impractical Politico (May24, 2017)( online at www.politico.com/story/2017/05/24/trump-organization-foreign-guests-238771) ; Trump Organization,
Donation ofProfitsfrom Foreign Government Patronage, Politico ( May 24, 2017) ( online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/documents/Trump%20Org%20Pamp
hlet
20Foreign 20Profits.pdf) .
34

determinations regarding these matters are dependent on many factors that will not be known to
TTO [ The Trump Organization] until after the close ofthis year.

May 24, 2017, observing the inadequacy ofthis response, Ranking Member
Cummings sent a letter directly to George Sorial, Executive Vice President and Chief
Compliance Counsel for The Trump Organization, renewing the Committee's request for
documents. He explained:
Complyingwiththe UnitedStates Constitutionis not an optionalexercise, but arequirementfor servingas our nation'sPresident. IfPresidentTrump believesthat
identifyingallofthe prohibitedforeignemolumentshe is currentlyreceivingwouldbe
too challengingor would harmhis businessventures, his options are to divesthis
92

ownershiporsubmita proposalto Congressto ask for our consent.

the Committee's investigations progressed and The Trump Organization failed toprovide responsive documents , Mazars, the former President's accounting firm, was identified asa possible custodian of documents possessing information relevant to foreign government
spending at Trump properties , as well as information concerning misleading disclosures by the
President and information about various items of concern involving the lease and management of
Trump International Hotel in Washington ,On April 15, 2019 , after a negotiation andconsultation process, Chairman Cummings issued a subpoena to Mazars seeking several
categories of documents , including all financial statements created by Mazars for President
Trump and certain of his businesses for calendar years 2011 through94

President Trump objected to the production of these records by Mazars , and in April 2019his personal attorneys sued in the U.S. District Court for the District of Columbia to block
Mazars from producing responsive

The Trump Organization argued that the

Letter from George A. Sorial, ExecutiveVice Presidentand ChiefCompliance Counsel, The Trump
Organization, to ChairmanJason Chaffetzand RankingMemberElijah E. Cummings, Committeeon Oversightand
GovernmentReform(May 11, 2017) ( onlineat
https://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/documents/Trump%20Org%20to%2
20Committee% 205-11-17_Redacted.pdf).

Letterfrom Ranking Member Elijah E. Cummings, Committee on OversightandGovernment Reform, toGeorge A. Sorial, Executive Vice President and Chief Compliance Counsel, The Trump Organization (May24,2017) (online at https://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/documents/201705-24.EEC 20to% 20Trump 20Organization.pdf).

See Memorandum from Chairman Carolyn B. Maloney , Committee on Oversight and Reform , toMembers of the Committee , Update on Committee Subpoena to Mazars and Subsequent Litigation ( Aug. 26 , 2020)(online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/MASTER%20Mazars%20Memo%2008.28.2020 % 20R3.pdf) .
94

See Memorandum from Chairman Elijah E. Cummings , Committee on Oversight and Reform, toMembers ofthe Committee , Notice ofIntent to Issue Subpoena to Mazars USA LLP, (Apr. 12, 2019) (online atwww.politico.com/f/?id=0000016a-131f-da8e-adfa-3b5f319d0001 ) .
95

Trump v. Committee on Oversight & Reform ofthe U.S. House ofRepresentatives , 380 F. Supp.3d 75(D.D.C. 2019). The plaintiffs complaint originally named then- Chairman Cummings and the Committee's thenChief Investigative Counsel, and Mazars as defendants , but following discussions with the Committee , the plaintiffs
consented to the Committee's intervention as a defendant and agreed to dismiss Chairman Cummings and the Chief

35

Committee's subpoena violated the separation of powers and lacked a valid legislative purpose .
After the court declined to issue an injunction invalidating the Mazars subpoena , and the U.S.
Court of Appeals for the District of Columbia Circuit affirmed, the Supreme Court agreed to96

review the Court of Appeals ruling and granted a petition for a writ of certiorari .
InJuly 2020

after 15 months of litigation

the Supreme Court issued a 7-2 decision

upholdingthe Committee's broad and indispensable power to conduct oversight ofthe
ExecutiveBranchand the President himself.97 The Justices held that Congress's legislative
authority includes the power to issue a subpoena directed at the President's personal
information and affirmed that [ w hen Congress seeks information needed for intelligent
The Court
legislative action, it unquestionably remains the duty of all citizens to cooperate.
then held that courts must performa

careful analysis that takes account of the separation of

powers amongthe branches of the federal government, including both the significant legislativeinterests of Congress and the unique position of the President.

The Court set forth four factors

to guide the analysis for subpoenas issued to a sitting President and remanded to the lower courts
to apply these factors to the subpoena issued by the Committee to Mazars.

The matter returned to the District Court , which again upheld the Committee's re-issued
99
subpoena , but narrowed its reach to encompass only certain parties and certain years. The
Court ofAppeals , similarly , upheld the Committee's subpoena under the newly minted Mazars
standard but slightly narrowed its reach
OnAugust 29, 2022, after the Committee's successive courtvictories, The Trump
Organization, the Committee, and Mazars reached a three- way agreement for Mazarsto begin
producingdocuments underthe narrowed subpoena. The documents to be produced included: 10

Accountingrecords, source documents, and engagement letters from 2014-2017 thatreference, indicate, or discuss any undisclosed, false, or otherwise inaccurateinformation
about PresidentTrump's or a Trump entity's reportedassets, liabilities, or income;InvestigativeCounselfromthe action. See Id. at 88.
96

97

Trump v Mazars USA, LLP, 140 S. Ct . 660 ( 2019 ) .

Trump v. Mazars USA, LLP, 140 S. Ct. 2019 (2020) . When the SupremeCourtgrantedthe petition, it

consolidatedthe matterwithTrump v. DeutscheBankAG, 943 F.3d627 (2d Cir. 2019) , anothercase involvinga
congressionalsubpoenafor the President'sfinancialrecords.
98

Mazars, 140 S. Ct. at 2035–36. The four factors to be applied are: ( 1) whetherthe serted legislative
purpose warrants the significant step of involvingthe Presidentandhis papers, includingconsiderationofthe
availability of other sources that would reasonablyprovide the informationsought; (2) whetherthe subpoena is no
broaderthan reasonablynecessary to supportCongress'slegislativeobjective ; ( 3) whether the subpoena advances
a valid legislativepurpose ; and (4) assessment of the burdens imposed on the Presidentby a subpoena. Id.
99

Trump v . Mazars USA , LLP, 560 F. Supp.3d 47 ( D.D.C. 2021) .

100 Trump v . Mazars USA , LLP, 39 F.4th 775 ( D.C. Cir . 2022) .

See Stipulated Agreement, attached as ExhibitA to Order, DonaldJ. Trump, et al. v. Committeeon
OversightandReform ofthe U.S. House ofRepresentatives, et al., Civil Action No. 1 : 19-cv- 01136-APM (D.D.C.
Sept. 11, 2022) .
36

Associatedcommunicationsfrom 2014-2018 relatedto potential concernsthat
informationin[ PresidentTrump's financial disclosures] was incomplete, inaccurate, orotherwise unsatisfactory;
All requested documents from November2016-2018 belonging to Trump

Post

Office LLC [the business entity created to operate the Trump InternationalHotel inWashington, D.C. ;All documents from November 2016-2018 referencing, indicating, discussing, orotherwise relating to the Old Post Office lease; andAll documents from 2017-2018 related to financial relationships, transactions , or ties
between President Trump or a Trump entity and any foreign state or foreign state agency,
the United States, any federal agency, any state or any state agency, or an individual
government official.
Pursuantto this agreement, Mazarsbeganproducingdocumentsto the Committeein
September2022, beginningwith documentsrelatingto the Old PostOffice buildingin
Washington, D.C., and The Trump Organization'slease ofthat property, under whichitoperated
the TrumpInternationalHotel in Washington, D.C.
Chairman Comer's Termination of the Committee's Subpoena

As discussed above , in January 2023 , almost immediately after Republicans took the
majority in the House of Representatives , the Committee , apparently acting through Donald
Trump's personal attorneys , informed Mazars that it no longer needed to comply with its
obligation to produce additional documents under the subpoena . On January 19 , 2023 , a lawyer
for Donald Trump wrote to Mazars's counsel :I do not know the status of Mazars [sic]production , but my understanding is that the Committee has no interest in forcing Mazars tocomplete itand is willing to release it from further obligations under the settlementagreement .

In communications with Mazars's counsel , that attorney confirmed that theActing General Counsel of the House of Representatives , in his capacity as counsel to theCommittee , had so informed him .103
102 Email from Patrick Strawbridge , Consovoy McCarthy PLLC, on behalf of Donald Trump , to Counsel
for Mazars USA LLP, (Jan. 19, 2023 ); Letter from Ranking Member Jamie Raskin to Chairman James Comer ,Committee on Oversight and Accountability (Mar. 12, 2023) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/FINAL%202023.03.12.%20JBR%2
20Comer 20re% 20Mazars

20BofA

20Subpoena.pdf) ; Comer Stymies Probe into Trump Tax Records,

House Democrats Say, Washington Post (Mar. 13, 2023) (online atwww.washingtonpost.com/politics/2023/03/13/trump-tax-records-investigation/) .

103 Email from Patrick Strawbridge, Consovoy McCarthy PLLC, on behalfof DonaldTrump, to Counsel
for Mazars USALLP, ( Jan. 20, 2023) . After receivingthese communications, Minority staff repeatedly sought
written confirmationfromMazars that Chairman Comer had agreed to release it from its obligations underthe
subpoena and court- supervised settlementagreement. See also LetterfromRankingMemberJamie Raskinto
ChairmanJames Comer, Committee on Oversightand Accountability (Mar. 12, 2023) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/FINAL%202023.03.12.%20JBR%2
20Comer 20re 20Mazars 20BofA% 20Subpoena.pdf) ; Comer Stymies ProbeInto Trump Tax Records,
HouseDemocratsSay, Washington Post (Mar. 13, 2023) (online at37

Chairman Comer effectively curtailed the Committee's investigation just four months
after Mazars had begun producing documents to the Committee . Although Committee
Democrats had been, for years , trying to obtain former President Trump's financial records from
Mazars as part of one ofthe Committee's most high -profile and heavily reported investigations ,104
Chairman Comer claimed : I honestly didn't even know who or what Mazars was .
Notwithstanding his termination of the investigation shortly after the Committee began to receive
responsive documents from Mazars, Chairman Comer complained that Democrats had been
investigating Trump for six years .

105

Chairman Comer's decision to release Mazars from its obligation to produce records
pursuant to the Committee's subpoena only weeks after Committee Democrats began working
with counsel for Mazars to identify documents showing payments from foreign entities has
Further,
severely limited the Committee's access to highly material and relevant information .
in working with Donald Trump's attorneys to halt the production of documents only months after
itstarted , Chairman Comer buried further evidence of former President Trump's misconduct bydepriving the Committee's Democratic staff of the ability to work with Mazars to conduct further
searches for responsive records , including any documents relating to Russia , South Korea , South
Africa , and Brazil.
In June 2023 , the Committee

under Chairman Comer's direction

and the parties to thelitigation filed a joint motion for dismissal and termination of the case . The District Court
granted the motion on July 5, 2023 , ending the litigation and the Court's supervision ofthe
parties agreement .
In the face of mounting evidence that foreign governments sought toinfluence the Trump Administration by playing to President Trump's financial interests ,Chairman Comer and President Trump's representatives appear to have acted in coordination to108bury evidence of his misconduct .

www.washingtonpost.com/politics/2023/03/13/trump-tax-records-investigation/).

104 HouseRepublicansQuietlyHaltInquiryinto Trump'sFinances, NewYork Times( Mar.13, 2023)( onlineatwww.nytimes.com/2023/03/13/us/politics/house-trump-finances-investigation.html
).

105

.

106 Fordetails on ChairmanComer's efforts to obstruct inquiries into former PresidentTrump's conduct,
see Letterfrom RankingMember Jamie Raskin, Committee on Oversight and Accountability, to ChairmanJames
Comer, Committee on Oversight and Accountability(Mar. 12, 2023) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/FINAL%202023.03.12.%20JBR%2% 20Comer 20re% 20Mazars 20BofA% 20Subpoena.pdf).
107See Order, Trumpv . Committeeon OversightandAccountabilityofthe U.S. HouseofRepresentatives,
et al., CivilActionNo. 1 : 19- cv- 01136- APM ( D.D.C.July 5, 2023) .

Letterfrom Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, to Debra Steidel
Wall, ActingArchivist of the United States, NationalArchives and Records Administration (Nov. 14, 2022) (online
at https://oversightdemocrats house.gov/sites/democrats.oversight.house.gov/files/2022-11
14.CBM

20to% 20Steidel

20Wall- NARA % 20re % 20Mazars

38

20Docs.pdf ) .

REPORT METHODOLOGYAND DOCUMENT LIMITATIONSBefore Chairman Comer relieved Mazars of its obligation to produce relevant documents ,the Committee received documents from Mazars showing substantial payments by foreign
governments and entities to three Trump properties :The Trump International
HotelinWashington, D.C.;The Trump International Hotel in Las Vegas , Nevada; andThe Trump World Tower at 845 United Nations Plaza in New York, New York.

Inaddition, publicly available information shows significant spendingby a state- owned
Chinese bank at a fourth Trump property, Trump Tower on FifthAvenue in New York, NewYork however, Mazars did not produce any ledgers to the Committee for this property.

As noted , the documents that were produced by Mazars are only a subset of the financial
records the Committee subpoenaed from the company . Even this very limited set of documents ,however , provides ample evidence that President Trump received millions of dollars fromforeign governments and entities while he occupied the Oval Office , in blatant violation of theForeign Emoluments Clause of the Constitution .
ReportMethodology

This report is based on an analysis of emoluments from foreign governments and foreign
entities identified in records provided by Mazars as well as public information . This report
includes foreign spending at Trump properties that has been reported in the media only ifsuch
in thespending could be confirmed through Mazars records produced to the Committee orcase of ICBC's expenditures at Trump Tower in New York
information .

through publicly available

This report focuses only on payments that constitute emoluments within the meaning of
the Foreign Emoluments Clause of the Constitution . It therefore includes charges incurred byforeign government departments , agencies , embassies , and royal family members , as well as
their officials and employees

all of which are components of a foreign State ." Consistent withthe history and text of the Foreign Emoluments Clause , as well as opinions from the DOJ's OLC ,which provides legal advice to the President and executive branch agencies , this also includes
payments by corporate entities that were owned by a foreign government .
109

109 See, e.g NOAA Employee's Receipt ofthe Göteborg Award for Sustainable Development, 34 Op.
O.L.C.210, 213 (2010) ( online at www.justice.gov/d9/opinions/attachments/2021/02/02/2010-10-06-noaa
goteberg.pdf) ; President's Receipt of the Nobel Peace Prize, 33 Op. O.L.C. 370, 379-81 (2009) (online atwww.justice.gov/d9/opinions/attachments/2020/12/22/2009-12-07-potus-nobel.pdf) ; Applicability of Emoluments
Clause to Employment of Government Employees by Foreign Public Universities, 18 Op . O.L.C. 13,( 1994)(online at www.justice.gov/d9/olc/opinions/1994/03/31/op-olc-v018-p0013_0.pdf) ; Applicability ofthe Emoluments
Clauseto Non-Government Members of ACUS, 17 Op . O.L.C. 114, 122–23 (1993) (onlineat
www.justice.gov/d9/olc/opinions/1993/10/31/op-olc-v017-p0114_0.pdf) . OLC has determined that the Foreign
EmolumentsClause applies to instrumentalities offoreign states, even ifsuch entities or individuals are formallydistinct from the foreign government or do not engage in political, military, or diplomatic functions, where theentity or individual is sufficiently influenced or controlled by the foreigngovernment. Thus, corporations owned
or controlled by a foreign government are presumed to be foreign states for purposes of the Clause. NobelPeace39

At every step, this report has taken a very conservative approach to tallying foreign
spending reported in the Mazars records and public information. For example, in several casessuch as the stay at the Trump International Hotel in Washington , D.C., by the Embassy of thePeople's Republic of China the Mazars records show an advance deposit or partial payment toa Trump property but do not show the total amount ultimately paid for the event or stay. Inthese
instances, this report reflects only the advance deposit or partial payment , even though these arealmost certainly only a portion ofthe total payment for an event or stay. Further, out of anabundance of caution , this report does not include as foreign emolument spending expendituresby Chinese corporate entities whose ownership structures were opaque during the time frame
under consideration and that therefore cannot be definitively identified as state- owned or state
controlled. The report excludes these entities payments from the emolument totals it presents
despite indications that these entities were closely aligned with the government of the People's
Republic of China or appeared to have become state-owned . This report also excludes from total
emolument spending more than $283,000 paid to the Trump International Hotel in Washington ,D.C. for the Sheikh Al Thani Family Extended Stay, an apparent reference to members of the
Qatari royal family. In a letter to then-Chairwoman Maloney in 2022, the Qatari Ambassador
asserted that no representative ofthe Embassy of Qatar, and no other government official oftheState of Qatar, was a guest at the Trump International Hotel at the
Although theAmbassador's assertion did not explain whether the stay involved members of the Qatari royalfamily, in keeping with the report's conservative approach, the expenditures related to this staywere not counted as foreign emoluments .
With respect to Trump World Tower , Mazars produced records only for the year 2018.
Accordingly , the report identifies the monthly common charges paid by foreign governments andentities for units in Trump World Tower for the year 2018 as noted in the Mazars records. In
addition, where public records confirm that a foreign government owned a property at Trump
World Tower throughout the Trump presidency
charges throughout this period

and therefore incurred monthly common

this report also includes an estimated total for the entire Trump

presidency using the 2018 figures provided by Mazars . For example , Saudi Arabia owned the45th floor of Trump World Tower throughout the Trump presidency. Mazars records show thatin 2018, itpaid a monthly base charge of $ 11,189 for this property, totaling $ 134,270 for thewhole of 2018. This report includes the $ 134,270 figure based on the Mazars records , as well as
an estimated total emolument of $537,080 four times the 2018 total to account for the four
years ofthe Trump

Given that these common charges likely increased after 2018 ,.

Prize, 33 Op . O.L.C. at 379 n.6

Letter from Meshal Al-Thani, Ambassador ofthe State of Qatar, to Chairwoman Carolyn B. Maloney,
Committee on Oversight and Reform (Nov. 22 , 2022) ( online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/Embassy%20of%20the%20State%2
20Qatar.221122.NARA

20Letter% 20re% 20Trump% 20OPO.pdf) .

EXCLUSIVE: Donald Trump Made Millions from SaudiArabia, but Trashes Hillary Clintonfor Saudi
Donationsto Clinton Foundation, New York Daily News (Sept. 4 , 2016) ( online atwww.nydailynews.com/news/politics/exclusive-donald-trump-made-millions-saudi-government-article-1.2777211);
MAZARS- OVERSIGHT
COMMITTEE- 00027371; MAZARS- OVERSIGHTCOMMITTEE- 00027416;

MAZARS- OVERSIGHT_COMMITTEE- 00027464; MAZARS- OVERSIGHT_COMMITTEE- 00027512;

MAZARS- OVERSIGHT_COMMITTEE- 00027577; MAZARS- OVERSIGHT_COMMITTEE- 00027628;
MAZARS- OVERSIGHT_COMMITTEE- 00027675; MAZARS- OVERSIGHT_COMMITTEE- 00027721;
MAZARS- OVERSIGHT_COMMITTEE- 00027769; MAZARS- OVERSIGHT_COMMITTEE- 00027808;
40

the projections included in this report likely understate the emoluments received by Donald
Trump's businesses from the foreign governments that had properties in Trump World Tower .

112

In addition , the properties in Trump World Tower incurred special assessments , electric charges ,and, in some cases , fees and interest arising from late payments . These assessments , charges ,and fees are noted within the relevant sections , but are not included in the totals shown for the
Trump World Tower properties .
Finally, incertaininstances, the reportdiscussescharges incurredby actors such as
lobbyistswho, though not themselvescomponentsof foreigngovernments, were nonethelessactinginthe interestsof foreigngovernments. Althoughthesepaymentsdo not constituteemolumentsand are not includedin tallies of emolumentpaymentsin this report, they are notedbecausethey raisesimilarconcernsregardingconflictsbetweenformerPresidentTrump's
personalfinancialand businessinterestsandhisduty to conductforeignpolicy solelyintheinterestofthe United States.
Extent andLimitations ofMazars Documents

The Mazars documents summarized in this report provide only a modest window into the
web ofover 500 active business entities , foreign government expenditures , and resulting
conflicts of interest and constitutional violations that pervaded the Trump presidency . The reportis unable to provide a complete accounting of all foreign government emoluments former
President Trump's businesses received even during the time period covered by the Committee's
subpoena because ( 1) Chairman Comer, in coordination with Donald Trump's attorneys , blocked
the production of documents as soon as he became Chairman in 2023, as discussed above; and(2) Former President Trump and his entities failed to provide to Mazars
retain many key documents .

or Mazars failed to

The set ofdocuments that Mazars produced before Chairman Comer shut down the
production also contained highly troubling omissions . For example , the Committee's
Democratic staff specifically requested that Mazars provide records related to a $20 million loan
from Daewoo, a South Korean entity, that was not reported on former President Trump's 2015,2016, or 2017 public financial disclosures . Spreadsheets prepared by Jeffrey McConney, The
Trump Organization's former controller, reflect that former President Trump's LOANSPAYABLE included a loan for $ 19,760,000 owed to L / P Daewoo as of June 30,
Thisloan remained outstanding until Daewoo was bought out of its position on July 5, 2017.
Critically, as Forbes reported:

114

Although the debt appeared on The Trump Organization's

internal paperwork , it did not show up on Trump's public financial disclosure reports, documents
he was required to submit to federal officials while running for president and after taking

MAZARS- OVERSIGHT_COMMITTEE- 00027853; MAZARS- OVERSIGHT_COMMITTEE- 00027898.

This report does not include any ofthe sometimes significant late fees paid by these governments in its
calculations as they might not be replicable across years .
113

JeffreyMcConneysupportingdataspreadsheetfor DonaldJ. Trump, Statementof FinancialCondition( June30, 2015) ( onlineat https://ag ny.gov/sites/default/files/complaint_with_exhibits_part2.pdf).
114

Jeffrey McConney supporting data spreadsheet for Donald J. Trump, Statement of Financial Condition(June 30, 2017) (online at https ://ag ny.gov/sites/default/files/complaint_with_exhibits_part2.pdf).
41

officeYet Mazars informedthe Committee'sDemocraticstaff it had no records to produce
regardingtheDaewoo loan.
The Committee's Democratic staff also requested hotel guest ledgers for the Trump
International Hotel in Washington , D.C. covering the 2017 presidential inauguration anddocuments regarding Chinese mega - bank ICBC's nearly two -million dollar a year lease in Trump
Tower. Once again, Mazars represented it had no documents responsive to either oftheserequests .
Mazars also did not provide any ledgers before the subpoena was terminated forproperties which reportedly received a large number of foreign government visitors , including :Trump Turnberry Hotel and Resort in Scotland ; Trump International Hotel and Tower in
Chicago , Illinois ; and Trump International Hotel in New York , New York.

Mazarsalso indicated that it had no specific accountingof foreign government spendingat Trump-owned properties. This is stunning in light of former PresidentTrump's pledge that
Trump hotelproperties would donate all profits from foreign government payments to the U.S.
Treasury and the policy announcedby The Trump Organizationpurportedly intendedto
effectuate that pledge.¹
116

The records provided by GSA also show the significant omissions in Mazars's records
regarding foreign government spending at Trump -owned properties , particularly the Trump
International Hotel in Washington , D.C. Last Congress , based on records provided by GSA ,former Committee Chairwoman Maloney estimated that total foreign government payments tojust the Trump International Hotel in Washington , D.C., from 2017 through 2019 would havebeen $

This estimate was based on the hotel's representations that , for these three
115

Trump OwedHiddenDebt While in Office, Forbes (Dec. 4 , 2022) (online at

www forbes.com/sites/danalexander/2022/12/04/trump-owed-hidden-debt-while-in-office/).

TrumpVowsto DonateHotelProfits to U.S. Treasury, GovernmentExecutive(Jan. 11, 2017) (onlineat
www.govexec.com/management/2017/01/trumps-vow-donate-hotel-profits-would-f/134509/) ; Letterfrom Ranking
MemberElijahE. Cummings, Committeeon Oversightand GovernmentReform, to GeorgeA. Sorial, Executive
VicePresidentand Chief ComplianceOfficer, TrumpOrganization(May24, 2017) ( onlineat
https://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/documents/2017-05
24.EEC 20to 20Trump% 20Organization.pdf); TrumpOrganization, DonationofProfitsfrom Foreign
GovernmentPatronage( online at116

https://oversightdemocrats.house.gov/sites/democrats.oversighthlethouse.gov/files/documents/Trump%20Org%20Pamp% 20Foreign 20Profits.pdf) .
Letter from Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, to Administrator

Robin Carnahan, General Services Administration (Oct. 8 , 2021) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/2021-10

08.CBM 20GEC% 20to%20Carnahan-GSA% 20re%% 20Post 20Office% 20Building 20Lease.pdf) . TheCommittee'sDemocraticstaffcould only arriveat an estimategiventhe lack ofsufficientinformation. Whereasthe
donations tothe U.S.Treasuryare reportedby calendaryear, the Mazarsfinancialstatements(includinggrossoperatingprofit, grossrevenue, and averagedaily ratefigures) are reportedon the basis ofa year that runsfrom
September1 to August31. Accordingly, the Committee'sDemocraticstaffestimatedthe TrumpInternational
Hotel'stotalforeigngovernmentpaymentsfor 2017through2019 usingthe best informationavailableto it. The
Committee'sDemocraticstaffusedthe grossoperatingprofit, grossrevenue, and averagedaily rate fromthe
unauditedsupplementalschedulefromthe Mazarsfinancialstatementsfor years 2017-2019, as wellasthe amountofthe donation to the U.S. Treasuryreportedinthe Mazarsfinancialstatementsfor years 2018-2020(because42years , it had identified $ 355,687 in foreign government profits ( which it had remitted to DJT
Holdings LLC, another Trump - owned entity; which DJT Holdings LLC had remitted to the
Trump Corporation ; and which the Trump Corporation in turn had donated to the U.S.
Treasury on behalf of The Trump Organization )However , only a fraction of this foreign
government spending at the Trump International Hotel in Washington , D.C., is reflected in the
documents provided by Mazars and discussed in this report.
Ultimately, this report is based on the records the Committee was able to obtain from
Mazars before Chairman Comer released the former President's accounting firm of its
obligations and on public information . Although these records clearly establish that former
President Trump received millions of dollars from foreign governments and entities in violation
ofthe Constitution's Foreign Emoluments Clause, they are incomplete . Specifically , the records
provided by Mazars include the following items for three of the former President's properties :these financialstatementsreportedthe “ donation to the U.S. Treasury for the previous calendar year) . Seealso
Letterfrom George A. Sorial, ExecutiveVice Presidentand Chief Compliance Officer, The Trump Organization, toRankingMemberElijahE. Cummings, Committee on Oversightand GovernmentReform (Apr. 6, 2018) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/2018.04.06%20Trump%20Organizat
ion.Response 20to% 20EEC% 20re% 20Emoluments_Redacted%20v.2.pdf) ( The Gross OperatingProfit
percentagewas obtainedby dividingthe dollaramount of Gross OperatingProfit for the property by the Total
OperatingRevenue for the property. The Gross OperatingProfitpercentagefor the propertywas then multipliedby
the foreign governmentpatronagerevenueat the property, resultingin the foreign governmentpatronagegrossoperatingprofitfor the property. The calculated foreign governmentpatronagegross operatingprofit was theamountdonated from that property to the Treasury Department. ) ; Trump Old Post Office LLC Financial
Statements(Aug. 31, 2017) ( online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/Selected 20Documents 20Related% 20to% 20GSA% 20Lease% 20for%% 20Post% 20Office% 20Building% 20Part% 203.pdf# page= 3 ); Trump Old
PostOffice LLC Financial Statements (Aug. 31, 2018) ( online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/Selected%20Documents%20Related% 20to 20GSA% 20Lease 20for%
20Post 20Office% 20Building% 20Part 203.pdf# page= 19); Trump
PostOfficeLLC FinancialStatements( Aug.31, 2019) (onlineat
https://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/Selected%20Documents%20Related% 20to% 20GSA% 20Lease% 20for%% 20Post 20office% 20Building 20Part 203.pdf# page= 36) ; TrumpOld

PostOfficeLLC FinancialStatements( Aug. 31, 2020) ( onlineat
https://oversightdemocrats.house.gov/sites/democrats.oversight

20to% 20GSA% 20Lease % 20for %20Posthouse.gov/files/Selected%20Documents%20Related

20Office% 20Building

20Part203.pdf# page53) .

Letter from Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, to Administrator
Robin Carnahan, General Services Administration (Oct. 8 , 2021) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/2021-10
08.CBM

20GEC% 20to % 20Carnahan - GSA% 20re %% 20Post

43

20Office% 20Building

20Lease.pdf) .

Property

Categories and Dates of Mazars Records

Trump InternationalHotel,

Hotel Ledger , which details customers , advance

Washington, D.C.

deposits, and account balances , among other information :November December 2016
August 2017
December2017

PostingJournalReports, with individualpages
identifiedas Guest Ledger Charges ( which identify
customersby name, room number, and roomrate) :September 2017 June 2018
August 2018

TrumpInternationalHotel, Las
Vegas, Nevada

Guest LedgerDetail, dated December 31, 2017, andcoveringbookings inclusive of that date ( this ledger also
includes severalbookings that do notinclude the date ofDecember 31, 2017, but that includedates close in time)
Deposit Ledger, dated December31, 2017, andincludingbookingsfrom late December2017 throughmid-November2018

Trump World Tower, New

TrumpWorldTower CondominiumStatus Report,

York, New York

whichliststenants, balances, amountsbilled, andpayments, among other information:
January 2018 December 2018

ReleaseandRedactionofMazarsRecords

With this report, the Committee's Democratic staff is publicly releasing redacted versions.

of the underlying Mazars records on which the calculations of emolument spending set forth in
the report are based Remaining unredacted are the names of individuals identified as foreign
officials at the ministerial level or above, and employees of foreign governments identified
through public reporting.

44

PEOPLE'S REPUBLIC

OF CHINAThe Committee's Democratic staff has documented more than $5.5 million in spendingat Trump -owned properties during former President Trump's time in office by the government of
the People's Republic of China (P.R.C. ), as well as by the state- owned Industrial andCommercial Bank of China (ICBC) and Hainan Airlines Holding Company , a Chinese state
owned airline . Former President Trump violated the Constitution when the businesses he owned
accepted these emoluments paid by the P.R.C. without the consent of Congress . Critically, thesefigures are based on the limited records from Mazars that are available to the Committee and ona public record maintained by the U.S. Securities and Exchange Commission ( SEC) . As such,these emoluments represent the minimum amount of unconstitutional payments from thegovernment ofthe P.R.C. and state-owned entities that Trump -owned businesses accepted during
former President Trump's term .
This report also discusses former President Trump's recent disclosures regarding a
sprawling trademark portfolio that the government of the P.R.C. enlarged during President
Trump's term . Although Mr. Trump was required to complete a financial disclosure form eachyear that he was in office , he neglected to include hundreds of trademarks he owns on these119
As Business Insider noted : The belated disclosures mean that
forms during his presidency.
Americans had little insight into the scope of Trump's foreign asset holdings during his
presidency, and are only learning about them as he runs for a second term in the 2024
election

Notably , if not surprisingly , the ability of Trump family businesses to secure

trademarks in China improved markedly and rapidly after Trump entered office.
Finally, the documents provided by Mazars also record expenditures at Trump -owned
properties by two Chinese companies that are closely aligned with the P.R.C.: Huawei; andHongkong Huaxin Petroleum Unlimited , a subsidiary of CEFC China Energy ( CEFC ) . While
the government of the P.R.C. has been linked with both Huawei and CEFC , given the opacity andconvoluted ownership and financing arrangements of these companies , this report does not

119
Trump Waited UntilAfter HeLeft Office to DiscloseTrademarksHe Owns in China andRussia,
BusinessInsider (Nov. 3 , 2023) (online at www.businessinsider.com/trump-disclose-china-russia-foreign
trademarks-after- presidency-2023-10) . BusinessInsider pointedout that the countries where former President
Trump ownstrademarks includes China, Venezuela, Iran, Cuba, Belarus, and other countries heavily sanctionedby
the UnitedStates. Mr.Trump amendedhis 2023 disclosure to removea trademark he had listed that was issued by
Saudi Arabia.

,,
content/uploads/2023/08 /Disclosure - Report-Part-1-8-14-23.pdf ) (Part 2 online at www.citizensforethics.org/wp
content/uploads/2023/08 /Disclosure - Report -Part -2-8-14-23.pdf ) (Part 3 online at www.citizensforethics.org/wp
content/uploads/2023 /08/Disclosure - Report-Part-38-14-23.pdf) (Part 4 www.citizens forethics.org/wp
content//2023 / 08/Disclosure -Part.

120
Office of Government Ethics Executive Branch Personnel Public Financial Disclosures (OGE
Form 278e) (Donald J. Trump) (Filed Aug. 14 2023 ) (Part 1 online at www.citizensforethics.org/wp

uploads

Report4-8-14-23.pdf)

Donald Trump filed trademark applicationsin China beginningin 2006. Fromthe time he announced
hiscandidacyfor the presidencyin 2015 through2019, roughly200 trademark applications by DonaldTrump and
IvankaTrump were pendingin China. Center for American Progress, Trump's ConflictsofInterestin China(June14, 2017) ( online at www.americanprogress.org/article/trumps-conflicts-interest-china/) ; Trump Trademark
ApplicationsSpikedAroundthe World When He StartedRunningfor President, CNBC (Dec.4, 2019) (online atwww.cnbc.com/2019/12/04/trump-accelerated-trademark-requests-while-running-for-presidenthtml) .
45

classify their expenditures among the emoluments paid by the P.R.C. to Trump-owned
businesses. However, the receipt by former PresidentTrump's businesses of expendituresfrom
these entities while Mr.Trump was in office created conflicts of interest.
People'sRepublicof China's EmolumentSpendingat TrumpProperties

Location

Expenditure

AmountAugust 27, 2017

Trump InternationalHotel( Washington, D.C.)

Embassy of China$ 19,391¹

November4 ,DateDelegation

TrumpInternationalHotel

Hainan Airlines

January1,( LasVegas, NV)

Holding Company Li

February 2017
October 31,2019

Trump Tower

Industrial and( NewYork, NY)

CommercialBank of

2016

122

$195,662

2018

1,948,180124(annualdue
from 2012

China

through October
31, 2019)$ 5,357,495(February 2017

throughOctober
31, 2019)
EMOLUMENTSPAIDBYP.R.C.

$ 5,572,548( 2017-2020)

As a candidate, Donald Trump accused China of stealing U.S. jobs , orchestrating thegreatest theft in the history of the world, and raping the United States with its trade policy 125
Inoffice, however, President Trump's public rhetoric and engagement with the P.R.C. initially
softened. While then-President Trump's policies toward the P.R.C. were frequently inconsistent,
they repeatedly deviated from the combative approach he articulated when he made China
126
According to John Bolton who served as Mr.
bashing a pillar ofhis 2016 campaign.
Trump's National Security Advisor from April 2018 through September 2019

Mr. Trumpcommingled the personal and the national not just on trade questions but across the whole field127
of national security.
Axios also observed that Trump-era China policy often featured two
122 MAZARS- OVERSIGHT_COMMITTEE- 00021348.

123 MAZARS- OVERSIGHT_COMMITTEE - 00027206 .

124 Securities and Exchange Commission , Free Writing Prospectus Structural and Collateral Term Sheet(Sept. 12, 2012) (online at www.sec.gov/Archives/edgar/data/850779/000153949712000490/fwp.htm).

125DonaldTrump Calls China's TradePracticethe GreatestTheftin the World ABCNews (May 2,2016) (onlineat https://abcnews.go.com/Politics/donald-trump-calls-chinas-trade-practices-greatest
theft/ story?id 38812125) .
126

Trump Promised to Bring China to Heel. He Didn't and the Result is a Pitched Conflict Between theWorld's Two Major Powers., Washington Post (Oct. 11, 2020) (online at www.washingtonpost.com/politics/trumpchina-xi-biden/2020/ 10/11/9c6e3146-0270-11eb -a2db- 417cddf4816a_story html).
127 John Bolton Book: Trump Asked China for Help with 2020 Election, Offered Personal Favors to46

separate tracks : policies Trump personally led, and policies spearheaded by officials with China
expertise .
128

From April through September 2017, then - President Trump engaged in meetings with the
P.R.C.'s President , Xi Jinping , regarding bilateral trade and threats from North Korea . Despite
the P.R.C.'s reluctance to pressure North Korea to halt its ballistic missile program anddenuclearize , then - President Trump repeatedly lauded his relationship with President Xi .

Shortly after taking office, then-PresidentTrump hostedPresidentXi for two days oftalks in April 2017 at his Florida residence in Mar-a-Lago, where he cited tremendous progress
inthe U.S.-China relationshipand characterizedhis personal relationship with PresidentXi at thetime as outstanding.
One commentator observed about this meetingthat it seemed to bebuilt upon the assumptionthat personal chemistry would compel Xi to override his national
interests 130
Inan October2017 television interview, then-PresidentTrump remarkedabout his
relationshipwith PresidentXi, stating,
thing.

we have a very good relationshipand that's a positive

President Trump's remarks came shortly after PresidentXi's opening speech at thestart of his fifthterm as President in which he expressed support for China moving closerto thecenter stage and expandingits economic dominance in contrastto Western values. 132

From November 8 to November 10, 2017

after the Chinese Embassy had spent at least$19,391 as an advance deposit for a stay beginning in late August 2017 at the Trump
International Hotel in Washington , D.C. then-President Trump traveled to China where helavished praise on President Xi and, notably, defended Chinese trade practices in stark contrast to
his previous public pronouncements blaming China's policies for the U.S.-China tradeimbalance. 133 Then-President Trump complimented President Xi, stating , My feeling toward

Dictators, CNBC (June 17, 2020 ) (online at www.cnbc.com/2020/06/17/john-bolton-book-trump-asked-china-for
help-with-2020 - election html).
128

Special Report: Trump's U.S.- China Transformation , Axios (Jan. 19, 2021) (online atwww.axios.com/2021/01/19/trump-china-policy-special-report ).

The White House, Remarks by PresidentTrump After MeetingwithPresidentXiofChina (Apr. 7, 2017)(online at https://trumpwhitehouse.archives.gov/briefings-statements/remarks-president-trump-meeting-president-xi
china ) .

130

Trump Promisedto Bring China to Heel. HeDidn'tand the Resultis a Pitched ConflictBetweenthe

World'sTwo MajorPowers., WashingtonPost (Oct. 11, 2020) (online at www.washingtonpost.com/politics/trumpchina-xi-biden/2020/ 10/ 11/9c6e3146-0270-11eb-a2db-417cddf4816a_storyhtml) .
President Trump : Some Call Xi Jinping theKing of China,

TIME (Oct. 26 , 2017) (online athttps://time.com/4998720/donald-trump-kind-china-xi-jinping/ ) .
Jinping's Marathon Speech : Five Takeaways , New York Times ( Oct. 18 , 2017) (online atwww.nytimes.com/2017/10/18/world/asia/china-xi-jinping-party-congress.html).

133 MAZARS- OVERSIGHT_COMMITTEE -00021348 . The records provided to the Committee by Mazars
do not indicate the dates or total length of the stay or whether the Chinese government expended more than theamount provided in the advance deposit . See Trump China Visit : U.S. Leader Strikes Warmer Tone with Xi
Jinping, BBC (Nov. 9 , 2017) (online at www.bbc.com/news/world-asia-china-41924228 ); In Beijing, Trump
Declines to HitPresident Xi Jinping on Trade :Don't Blame China, Washington Post (Nov. 9 , 2017) (online at47

you is an incredibly warm one .

134

Trump also stated that he did not blame China

for the trade

deficit between the two countries , declaring , [ a ]fter all, who can blame a country for being able
to take advantage of another country for the benefit of its citizens? I give China great credit.
The nextyear, however, then-President Trump launched a trade war against China as partof a broad protectionist economic policy and trade strategy. According to commentators at
Brookings, BetweenJuly 2018 andAugust 2019, the United States announced plans to impose
tariffs on more than $ 550 billion of Chinese products, and China retaliated by imposing tariffs on
more than $ 185 billion worth of U.S. goods 136 The two countries reached a Phase One
tentative dealto reduce trade tensions in January
analyst,Ultimately, however, according to one

China actually boughtnone of the additional $ 200 billion of exports that it promised in

the agreement.

Accordingto a January 2021 report from the U.S.- China Business Council, a

nonpartisanassociation of more than 270 American companies that do business with China,
Tariff rates remain[ ed] at a multi- decade high despite both countries reaching a phase one trade
agreement in early 2020.

The report found that the trade war with China reduced US

economic growth and employment, resultingin an estimated peak loss of 245,000 jobs
failed to achieve major policy goals outlined by the Trump administration.

andAnd yet, amid

what became a tense trade conflict, Mr. Trump inexplicably took positions favorable to specific
Chinese interests as discussed below.

Dismissing Concerns About Chinese Government HumanRightsAbuses

During his Administration, former PresidentTrump repeatedly dismissedconcerns about
the humanrights abuses perpetratedby the Chinese CommunistParty ( CCP) . Duringa June2019 phone call, then- PresidentTrump reportedly promised PresidentXi that, while tradewww.washingtonpost.com/news/post-politics/wp/2017/11/08/in-beijing-trump-lavishes-praise-on-chinese-leader
touts - great- chemistry - between - them/ ) .

134

Trump HeapsPraise on Very Special Xi in China Visit, Reuters (Nov. 9 , 2017) (online at
www reuters.com/article/us-trump-asia-china-bromance/trump-heaps-praise-on-very-special-xi-in-china
visitidUSKBN1D91C8 ) .

135

Trump, Once Criticalfrom Afar, Gives China a Pass in Trade War, NBC News (Nov.8 , 2018) ( onlineat www.nbcnews.com/news/world/trump-says-he-doesn-t-blame-china-taking-advantage-u-n819221).
136

RyanHass and AbrahamDenmark, MorePainThan Gain: How the US-China Trade War Hurt
America, Brookings (Aug. 7, 2020) (online at www.brookings.edu/articles/more-pain-than-gain-how-the-us-china
trade-war-hurt-america/) .
137.

China Promised Trump a Better Dealfor America ItDidn't Actually Deliver, NPR (Feb.15,2022)(online at www.npr.org/sections/money/2022/02/15/1079761270/china-promised-trump-a-better-deal-for-america
it-didnt- actually -deliver ) (italics in original text).

US-China BusinessCouncil, The US-ChinaEconomicRelationshipa CrucialPartnershipata Critical
Juncture(Jan.2021) (onlineat www.uschina.org/sites/default/files/the_us-china_economic_relationship__a_crucial_partnership_at_a_critical_juncture.pdf) ; US-China BusinessCouncil,Aboutthe US-ChinaBusinessCouncil( onlineat www.uschina.org/about) (accessedNov.8, 2023).
US- China Business Council, The US- China Economic Relationship a CrucialPartnership at a Critical
Juncture (Jan.2021) (online at www.uschina.org/sites/default/files/the us -china economic relationship _a_crucial_partnership_at_a_critical_juncture.pdf) .
48

negotiations continued, the United States would refrain from criticizing China over its brutal
Shortlypolice crackdown against pro-democracy, pro-independence dissenters in Hong Kong.
141

thereafter, President Trump said he believed that President Xi had acted very responsibly withrespect to the riots in Hong Kong adopting the Chinese government's dubious vernacular todescribe the pro- democracy protests in that country.
142

Accordingto former National Security Advisor Bolton, in June 2019 at the G -20 Summit,
PresidentTrump told PresidentXi that Xi should move forward with buildingcamps to detain
Uyghur Muslimsin Xinjiang, which Trump thought was exactly the right thing to do.
Emoluments
Paid by the P.R.C.to Trump- OwnedBusinesses

According to a document produced to the Committee by Mazars , an Embassy of China
Delegation made an advance deposit of $ 19,391 to the Trump International Hotel inWashington , D.C., for an Arrival

date ofAugust 27, 2017.144 The advance deposit ledger does
not specify an end date to the planned stay. 145 The advance deposits recorded in the Mazars
documents produced to the Committee likely comprise only a fraction ofthe funds ultimately
expended for a stay or event . Because Chairman Comer allowed Mazars to terminate its
production ofresponsive documents , the Committee is unable to determine the total spending by
the Embassy of China Delegation for this stay or the length of its duration .
Chinese State Emolument Spending at Trump Properties : Hainan Airlines Holding
Company

Hainan Airlines (also referred to as Hainan Airlines Holding Company ), China's fourth
biggest carrier , is a widely recognized Chinese state -owned enterprise . Hainan Airlines and its
146

141

Trump PromisedXi U.S. Silence on Hong Kong Democracy Protests as Trade Talks Stalled, CNN (Oct.
4, 2019 (online at www.cnn.com/2019/10/04/politics/trump-xi-hong-kong-protests/index html) . See also Council on
Foreign Relations, HongKong's Freedoms: What China PromisedandHowIt's Cracking Down (May 19, 2022)( online at www.cfr.org/backgrounder/hong-kong-freedoms-democracy-protests-china-crackdown#chapter-title-0-5 ) .
142

Trump Says China's XiHas Acted Responsibly on Hong KongProtests, Reuters (July 22, 2019) (onlineat www.reuters.com/article/us-usa-trade-china/trump-says-chinas-xi-has-acted-responsibly-on-hong-kong-protests
idUSKCN1UH20Q ; Did the U.S. President Greenlight a Potential Chinese Crackdown in Hong Kong?,
Washington Post (Aug. 6, 2019) (online at www.washingtonpost.com/opinions/2019/08/06/did-us-president
greenlight-potential-chinese-crackdown- hong- kong ) .

Bolton BookBombshells : Trump Asked China's Xifor Reelection Help and Told Him to Keep Building
Concentration Camps , CNN (June 18, 2020) (online at www.cnn.com/2020/06/17/politics/bolton-booktrump/index html) .
144 MAZARS- OVERSIGHT_COMMITTEE- 00021348.

145 MAZARS- OVERSIGHT_COMMITTEE -00008041. The Committee had not received a guest ledger
for August 2017 for the Trump International Hotel in Washington , D.C., before Chairman Comer released Mazars
from producing documents responsive to the Committee's subpoena .

146 International Civil AviationOrganization, Listof Government- Owned andPrivatized Airlines (online atwww.icao.int/sustainability/SiteAssets/Pages/Eap_ER_Databases/FINAL_Airlines%20Privatization.pdf) (accessed
Dec. 7 , 2023) ; HainanAirlines Says Govt Is ControllingShareholderNow, ButChangePossible, Reuters (May 17,2018) (online at www.reuters.com/article/china-hainan-airlines/update-2-hainan-airlines-says-govt-is-controllingshareholder- now- but- change- possible- idUSL3N1SO3E4/) .
49

affiliates, Grand China Air and HNA Group, are all enterprises controlled by the provincial
governmentof Hainan through its investment arm, Hainan Development Holdings.

147

In2015 , Chinese state -owned banks supplied Hainan Airlines affiliate HNA Group withbillions of dollars in cheap loans and a $ 67.4 billion line of credit .
HNA Group employed
148

these cheap loans to embark on a Chinese government - encouraged campaign of overseas
investment in Western Europe and the United States .

According to documents Mazars produced to the Committee , Hainan Airlines began what
was apparently a 14- month stay at the Trump International Hotel in Las Vegas , Nevada, on
November 4 , 2016 four days before the 2016 Presidential election .
At the time , its affiliate
HNA Group, faced increasing scrutiny from U.S. federal regulators due to the Group's opaqueownership structure and ties to the Chinese state apparatus .

150

As it sought to expand its portfolio in the United States , HNA Group launched a lobbying
campaign to improve its image in Washington , D.C., and secure U.S. government approval ofits
targeted acquisitions . After Mr. Trump won the 2016 election and began his term as President,
and as HNA Group was patronizing the Trump International Hotel in Las Vegas , senior
executives enjoyed access to high- level Trump Administration officials . In early June 2017 ,HNA Group executives met with then- Vice President Mike Pence at a public dinner in
Washington , D.C. On June 19 , 2017 , HNA Group's then- CEO and Vice Chairman met with
then- Treasury Secretary Steven Mnuchin, the head of the Committee on Foreign Investment in
the United States ( CFIUS) , while several HNA Group acquisitions were undergoing review by
CFIUS

HNA Group executives reportedly met with additional Treasury officials with147

HainanAirlines Co., Ltd., 2010AnnualReport( 2010) ( onlineat

www hainanairlines.com/go/Annual_Report/en/2010Annual
Report_EN.pdf?v 2013.8-2) ; HainanAirlines Co., Ltd.,
FinancialStatements and Reportofthe Auditors for the Year Ended 31December 2014 (2014) (online atwww.hainanairlines.com/go/Annual_Report/en/2014Annual
Report_EN.pdf?v 2013.8-2) . See also Hainan Airlines,
Hainan Airlines Co., Ltd., 2016 AnnualReport, at Page 3 ( 2016) (online at
www hnair.com/guanyuhaihang/tzzgx/cwbg/201905/P020190522481912759332.pdf) (languagetranslatesto:

Actualcontrollerof the company/ actual controller/ HainanProvincial State- owned Assets Supervisionand
AdministrationCommissionrefers to HainanProvincialGovernmentState-owned Assets Supervisionand
AdministrationCommission ) ; HainanAirlines, HainanAirlines Co., Ltd., 2017 AnnualReport, at Page 4 (2017)( onlineat www.hnair.com/guanyuhaihang/tzzgx/cwbg/201905/P020190522481944475417.pdf) (languagetranslates
to: The actual controller of the company/ actual controller/ HainanProvincial State- owned Assets Supervisionand
AdministrationCommissionrefers to the HainanProvincialGovernment State- owned Assets Supervisionand
AdministrationCommission ) ; Hainan Airlines, HainanAirlines Co., Ltd., 2018Annual Report, at Page 5 (2018)( onlineat www.hnair.com/guanyuhaihang/tzzgx/cwbg/201905/P020190522481912759332.pdf) (languagetranslates
to: Actual controller of the company/ actual Controller/ Hainan ProvincialState-owned Assets Supervision and
AdministrationCommission and Refersto the State- owned Assets Supervisionand AdministrationCommissionof the HainanProvincialGovernment. ) .
148.

149 MAZARS- OVERSIGHTCOMMITTEE- 00027206.

U.S.

Expanding Power to Block Chinese Firms. HNA Was Already No Match, New York Times(Aug. 2 , 2018) (online at www nytimes.com/2018/08/02/business/hna-group-skybridge-scaramucci.html).

151 See also HNA Group, Press Release: HNA Group Joins the Atlantic Council, PR Newswire (June 7 ,2017) (online at www.prnewswire.com/news-releases/hna-group-joins-the-atlantic-council-300470430.html ) ;Department ofthe Treasury, Secretary Mnuchin's Calendar February 201750

June 2017 (online atauthority over CFIUS later that month.

152

These efforts, however, failed to address CFIUS's concerns about HNA's threat tonational security, and consequently , several prospective deals fell through. HNA Group's
proposed acquisition of future Trump advisor Anthony Scaramucci's investment firm, SkyBridge
Capital, failed a review by CFIUS because HNA Group reportedly did not make sufficiently
clear who owned the company during the regulatory review.
Further, inAugust 2018, citing
national security concerns, CFIUS ordered HNA Group to sell its controlling stake in a New
York City building just blocks from Trump Tower, in part because the HNA building housed a
New York Police Department precinct with officers who protected Trump Tower and thenPresident Trump.154
November 12, 2020 after the 2020 Presidential election but before President Trumpleft office then-President Trump issued Executive Order 13959, Addressing the Threat fromSecurities Investments That Finance Communist Chinese Military Companies (CCMC) , which
prohibited investments by U.S. citizens in companies that benefit the CCP.155 On January 14,
2021 just six days before President Trump left office the State Department published a list ofidentified CCMCs, including Grand China Air, a major shareholder of Hainan Airlines alongside
HNA Group 156
By the end ofthen-PresidentTrump's term, HNA Group had beendirectly seizedby the
Hainanprovincialgovernment, whichinitiateda restructuringplan followinga debt- financed$ 50 billioninternationalspending spree.
The Chinese governmentreportedlyrestructured
HNAGroup's debt and aligned investmentswith state goals, establishedstate trusteeship, andtransferredassets to state investors.
Total HainanEmoluments

https://home.treasury.gov/system/files/236/Secretary-Mnuchin-Calendar-February-2017-June-2017-FINAL.pdf)( accessedNov.
29, 2023) .

152 U.S.

Expanding Power to Block Chinese Firms. HNA Was Already No Match, New York Times(Aug. 2 , 2018) (online at www nytimes.com/2018/08/02/business/hna-group-skybridge-scaramucci.html ) .

153.

154 U.S. Orders Chinese Company to SellManhattan Building Near Trump Tower, Wall Street Journal(Aug. 10, 2018) (online at www.wsj.com/articles/u-s-orders-chinese-company-to-sell-manhattan-building-neartrump-tower-1533917797)

155 Exec. OrderNo. 13959, 85 Fed. Reg. 73185 ( Nov. 17, 2020) .

Departmentof State, CommunistChinese Military Companies ListedUnder E.O. 13959HaveMore
Than 1,100Subsidiaries (Jan. 14, 2021) (online at https://2017-2021.state.gov/communist-chinese-militarycompanies- listed-under-e- o- 13959-have- more-than-1100-subsidiaries ) .
156

Chinese Officials Are Taking Control ofTroubled Airline Operator HNA , CNN (Mar. 2 , 2020 ) (online athttps://cnn.com/2020/03/02/business/hna-group-china-government/indexhtml) ; HNA Restructuring Advances$5.7BN Airline Funding , Nikkei Asia ( Sept. 28, 2021) (online at https://asia.nikkei.com/Business/Markets/China
debt-crunch/HNA -restructuring -advances -with - 5.7bn - airline-funding) .
158 Congressional Research Service , Evergrande Group and China's Debt Challenges (Oct. 21, 2021)(online at https://crsreports.congress.gov/product/pdf/IF/IF11953/2 ) .
51

BetweenNovember4 , 2016

four days before the 2016 presidentialelection

January 1, 2018, HainanAirlines HoldingCompany Li[mited]

and(HainanAirlines) incurred$ 195,662 inchargesat the Trump InternationalHotelinLasVegas for what appearsto havebeen
an astonishing14-month
159

TRUMP
INTERNATIONAL
HOTEL
LAS
VEGAS

TRUMP

12-31-17

05:53

NA GuestLedgerDetail

Arr Date

Room
No.Name

9290

HainanAirlinesHoldingCompany 11-04-16

Dep Date

Persons

RoomCharges

01-01-18

0.00

OtherCharges

195,662.04

Credit180,730.19

Balance

14,931.85

Rate Payment
MethodFolio
Status0.00CAThe documents in the Committee's possession record Hainan Airlines arrival date,departure date, and other charges . They do not specify the exact services rendered to Hainan
Airlines (such as food service or other services typically provided to a hotel guest) over the 14
month period of the Hain Airlines booking or precisely when they were provided within thistime frame. Mazars confirmed to the Committee's Democratic staff that after performing a
diligent search, it had no further documentation on Hainan Airlines or HNA Group in its records,
suggesting that The Trump Organization may not have turned over all of the documents
associated with these charges . Inany event, the charges incurred by Hainan Airlines constitutethe largest single expense, by a significant amount , reflected on either of the two ledgers
produced to the Committee by Mazars regarding the Trump International Hotel in Las Vegas.
ChineseState EmolumentSpendingat TrumpProperties: ICBCICBC is one of China's biggest state -owned commercial banks.
Prior to October
2005, ICBC was wholly-state-owned by the P.R.C.161 Following State Council approval on
October 28, 2005, ICBC was restructured and incorporated as a joint- stock limited
162
As of December 2023, the bank's controlling shareholders are the P.R.C.'s
company. "Ministry of Finance and the Central Hujin Investment Company an investment firm owned by
China's central bank 163

159 MAZARS- OVERSIGHT_COMMITTEE-00027206. The estimated payments madethrough Hainan
Airlines stay at Trump InternationalHotel in Las Vegas are derived from the charge labeled Other Charges,
which isthe sum oftwo charges labeled Credit and Balance. HNA may have incurred additional charges
outside ofthe limited period for which the Committee has records.

160 Industrial& Commercial Bank of China Ltd.: Company Background, Nikkei Asia (online athttps://asia.nikkei.com/Companies/Industrial-Commercial-Bank-of-China-Ltd) (accessed Dec. 7, 2023).
161 Industrialand Commercial Bank of China, AnnualReport 2016 (2016) ( online at
http://v.icbc.com.cn/userfiles/Resources/ICBCLTD/download/2017/7_20170421.pdf
).
162

.

163Industrialand CommercialBankof China,( onlineatwww.icbc

ltd.com/ICBCLtd/Investor%20Relations/IR%20Contacts%20and%20Services/FAQs/ ) ( accessed Aug. 23, 2023);
Congressional Research Service, China's Sovereign Wealth Fund: Developments and Policy Implications
Archived (Sept. 23, 2010) (online at https://crsreports.congress.gov/product/pdf/R/R41441/2 ) .
52

While campaigning for the presidency in 2016 , then - candidate Trump repeatedly boastedof his business dealings with ICBC, whose U.S. headquarters were located in Trump Tower in
New York . For example , in his June 2015 campaign announcement speech at Trump Tower , hestated :love China ! The biggest bank in the world is from China . You know where their
United States headquarters is located ? In this building , in Trump Tower .
Similarly , in March 2016 , when asked about China's territorial claims in the South China
Sea, Trump stated ,I do deals with them all the time .

The largest bank in the world , 400

million customers , is a tenant of mine in New York , in Manhattan .

According to Bloomberg

News , ICBC wasspace on three floors ,bank branch,

one of Trump Tower's largest office tenants

andabout 100 employees .

with

a

Bloomberg News also reported that , [ a ] s of

September 2012 , ICBC paid $95.48 per square foot for its Trump Tower space , more than any
other major office tenant in the tower

167

ICBC made significant payments to then- President Trump's businesses in the firstyear of his presidency , the bank came under scrutiny for conducting financial transactions forfront companies funneling money to the North Korean regime, including the country's
sanctioned nuclear program . In 2016 , the DOJ alleged that ICBC, among other Chinese financial
institutions , had provided bank accounts for a Chinese company that allegedly conspired with aNorth Korean bank to evade U.S. sanctions .
In mid-2017 , in the face of widespread evidence
that large Chinese banks had worked with North Korean front companies , the Trump
Administration reportedly weighed sanctions against several major Chinese banks that had
facilitated North Korean financial activity in the United States .
164

Trump's CommentsAfter Not Attacking Nike RaiseEvenMoreQuestions, Washington Post (Sept. 5,2018) (onlineat www.washingtonpost.com/news/politics/wp/2018/09/05/trumps-explanation-for-not-attacking-nikeraises-even-more-questions/) .

165 When Chinese Bank's Trump Lease Ends,Potential Conflict Begins , Bloomberg (Nov. 28, 2016) (onlineat www.bloomberg.com/politics/articles/2016-11-28/trump-s-chinese-bank-tenant-may-negotiate-lease-during-his
term ).
166 China'sBiggestBank to ReduceIts Space at Trump Tower, Bloomberg News (Jan. 9 , 2019) (online atwww.bnnbloomberg.ca/china-s-biggest-bank-to-reduce-its-space-at-trump-tower-1.1195744
).

167
168

.
Trump Administration Weighed Sanctions Against Major Chinese Banks Tied to North Korea ,Washington Post (Mar. 2 , 2018 ) (online at www.washingtonpost.com/business/economy/trump-administrationconsidered -but-refrained-from- tougher -north-korea- sanctions/2018/03/ 02/ 7eafdc84-1c15-11e8 -ae5a
16e60e4605f3_story.html ) . The DOJ brought a civil forfeiture action as to the proceeds in the relevant Chinesebanks, including ICBC, but did not allege wrongdoing against those banks . See Department ofJustice , Press
Release: Four Chinese Nationals and China-Based Company Charged with Using Front Companies to Evade U.S.
Sanctions Targeting North Korea's Nuclear Weapons and Ballistic Missile Programs (Sept. 26, 2016) (online atwww.justice.gov/opa/pr/four-chinese-nationals-and-china-based-company-charged-using-front-companies-evadeus) ; Complaint , United States v. All Funds in the Accounts ofBlue Sea Business Co. , Ltd., et al. (D.N.J. Sept. 26,
2016) (online at www.justice.gov/d9/press
releases/attachments / 2016/09/26/ dhid_et_al_civil_forfeiture_complaint.pdf ) ; Department ofJustice, Press Release :Four Chinese Nationals and Chinese Company Indicted for Conspiracy to Defraud the United States and Evade
Sanctions (July 23 , 2019) (online at www.justice.gov/opa/pr/four-chinese-nationals-and-chinese-company-indictedconspiracy -defraud -united - states-and) .
U.S. Considered BlacklistingTwo ChineseBanks Over NorthKorea Ties, Bloomberg (Apr. 13, 2018)
53

InSeptember2017, the HouseForeignAffairs Committee's RepublicanChairman,
RepresentativeEdwardR.Royce, released a statement callingon the Administrationto apply
maximum financialand diplomatic pressure" to stop the NorthKoreannuclear program,includingby targetingmore Chinese banks that do business with North Korea with or without
Beijing's cooperation.
Despitethesepleas from members ofhis own party, then-President
Trump and his Administration did not take any formal actionagainst Trump Tower tenant
171
170

In the midst ofthe ongoing controversy , the bank's lease at Trump Tower neared its
expiration on October 31, 2019 , and the bank was considering whether to exercise its optional
renewal clause .

In an interview at a financial conference held earlier that month, Eric Trump

explained that he could not simply kick out this controversial tenant ifthey decided to exercise
173
their five- year option to renew.
Eric Trump and The Trump Organization provided only vague statements regarding the
ICBC tenancy . Eric Trump said that while ICBC had decided to keep a couple of floorsin

Trump Tower , ithad agreed to lease a much larger New York office space in another building .174
A Trump Organization spokesperson later offered that ICBC had exited the vast majority of
their space in Trump Tower, in a transaction Forbes described as somewhat murky.
However , in a notable development , earlier this year , Forbes reported that ICBC suddenly
departed Trump Tower shortly after former President Trump left office in the first half of2021(online at www.bloomberg.com/news/articles/2018-04-13/china-banks-aiding-north-korea-are-said-too-big-to

punish).

House Committee on Foreign Affairs , Press Release : Chairman Royce Statement on North Korea (Mar.
9 , 2017) ( online at https://foreignaffairs house.gov/press-release/chairman-royce-statement-north-korea/ ) .

171

RankingU.S.LawmakerSeeks Sanctionson 12 ChineseBanks Over N.Korea, Korea Herald (Sept. 13,2017) (online at www.koreaherald.com/view.php?ud=20170913000909) ; HouseCommittee on ForeignAffairs,
PressRelease: ChairmanRoyceStatementon NorthKorea (Sept. 3 , 2017) ( online athttps://foreignaffairs.house.gov/press-release/chairman-royce-statement-north-korea/# ) . See also U.S. Lawmakers
Want Supercharged

Response to N. Korea Nuclear Tests , Reuters (Sept. 15, 2017) (online atwww.reuters.com/article/northkorea-missiles-congress/u-s-lawmakers-want-supercharged-response-to-n-korea
nuclear- tests- idUSL2N1LTOYD ) .
172

Managing UnderPressure: Eric Trump: Trump Organization EVP, Yahoo! Finance (Oct. 10, 2019)( online at https://finance.yahoo.com/video/managing-under-pressure-eric-trump-164422827.html).
Id.;Duringthe same interview, Eric Trump madethe false claim that the government stayed at Trump
properties for free or cost for house- keeping
a statement directly contradicted by detailed information obtainedby the Committee showing that, in some instances, Trump-owned businesses charged the Secret Service far inexcess ofthe government rate. See Letterfrom Chairwoman Carolyn B. Maloney, Committee on Oversightand
Reform, to DirectorKimberly Cheatle, United States Secret Service (Oct. 17, 2022) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/2022-10
17.CBM% 20to% 20Cheatle- USSS% 20re% 20Exorbitant % 20Charges

174

20at% 20 Trump% 20Properties.pdf ) .

ManagingUnderPressure: Eric Trump: Trump Organization EVP, Yahoo! Finance (Oct. 10, 2019)( online at https://finance.yahoo.com/video/managing-under-pressure-eric-trump-164422827.html).

175Forbes Estimates China Paid Trump at Least $ 5.4 Million Since He Took Office, Via Mysterious Trump
Tower Lease, Forbes (Oct. 23, 2020) (online at www forbes.com/sites/danalexander/2020/10/23/forbes-estimateschina-paid-trump - at-least-54 -million-since-he- took -office-via- mysterious -trump -tower-lease/) .
54

and lessthantwo years after the bank exercisedwhat EricTrump . . . describedas a five year
extension. 176
TotalICBCEmolumentsIdentifiedinPublicRecords

ICBC signed a lease in Trump Tower for commercial office space in 2008 and became along-term tenant of Trump Tower Commercial Condominium Property in New York . According
to a debt prospectus filed with the SEC, ICBC entered into a lease with Trump Tower
Commercial LLC and agreed to pay $ 1,948,180 in annual rent through October 31, 2019.¹

177

Based on this information and with the assumption ofno variable adjustments , this report
estimates that ICBC paid Trump Tower at least $5,357,495 between February 2017 and October
31, 2019 the date at which the lease was set to expire per the debt prospectus .
178

Major TenantsCreditRatingTenantFitch
Moody's
&P

Name

NRSF

NRSF

Major
Tenants
AmericaGroup

CONCACAF

The
TrumpCorporation(andaffiliates
Total
Major
Tenants

90.00

NR

NR

13,733%70.00

13.733

%

62.00

400

961,310

%
76.0
%
98.7%

241,357$$ 103.91

Date

%
%

3.3%

%
%
23,751,675
5,782,251
29,533,926

Lease
Expiration%%
185,709

VacantSpace
Collateral Total

384.40%Non-MajorTenants
Occupied
CollateralUW Base
Rent

Rent

%

)

Marc
FisherMarcraft Apparel

Rent
PSF

%

Industrial
andCommercial
BankofChinaof Total Annual

AnnualAnnualTenant2/28/2026
10/31/2019

10/31/2018
6/30/201512/31/2015

%

%
100.0
%

1.3
%

244,482

100.0%

Counsel for Mazars informed the Committee that following a comprehensive search ofits
records , the firm identified no responsive documents in its database relating to the Industrial

176 ChinaPaidTrump Millionsin Rent. Then He Leftthe WhiteHouse, Forbes(Apr. 10, 2023) ( online at
www forbes.com/sites/danalexander/2023/04/10/china-paid-trump-millions-in-rent-then-he-left-the-white-house/).
ICBCcontinuedto list 725 FifthAvenue, 20th floor, New York, NY (i.e., the address of Trump Tower) as its
businessaddress on some public facingwebsites for its New York branch through at least December2023.
Industrialand CommercialBank of China, Welcome to ICBCNew York Branch(online atwww.icbkus.com/en/column/1438058343720960077
html) (accessed Dec. 8, 2023) . Forbesreportedin its April
2023 article, Forbesdid manage to connect with someone answeringthe phones at ICBC'sbranchin Queens. That
personconfirmedthat ICBCno longer has any space in Trump Tower.

Forbes Estimates China Paid Trump at Least $5.4 Million Since He Took Office, Via Mysterious Trump
Tower Lease, Forbes (Oct. 23 , 2020 ) ( online at www forbes.com/sites/danalexander/2020/10/23/forbes-estimateschina-paid-trump - at-least-54-million-since- he- took -office -via- mysterious -trump-tower-lease ) ; Securities andExchange Commission , Free Writing Prospectus : Structural and Collateral Term Sheet , Wells Fargo Commercial
Mortgage Trust 2012 LC5 ( Sept. 12, 2012 ) (online atwww.sec.gov/Archives/edgar/data/850779/000153949712000490/fwp htm) .
This figure was calculated using base annual rent for space occupied by Industrial and Commercial

Bank of Chinaat the Trump Tower CommercialCondominiumPropertyfor a 33- monthperiod, from February 1,
2017, to October 31, 2019. Securitiesand Exchange Commission, Free Writing ProspectusStructuralandCollateralTerm Sheet (Sept. 12, 2012) (online atwww.sec.gov/Archives/edgar/data/850779/000153949712000490/fwphtm) .
55

and Commercial Bank of China or ICBC.

The absence of these records from Mazars's files

raises troubling concerns about The Trump Organization's candor with its accounting firm.
Apparent

Pro

:

179

TrumpTrademarksin China

Trademarks are a significant component of the business model employed by Mr. Trump's
companies , which had registered hundreds of trademarks in more than 80 countries by the time
Donald Trump entered office .
Given that trademarks are granted and can be revoked byforeign governments , and because they have value , they are potential foreign emoluments
themselves .
As of2023 , Mr. Trump had 114 trademarks registered in China more than in181

any other country by far.
By comparison , Trump businesses reportedly have 57 trademarks
183
registered in the United States .

While public reporting makes clear that the Trump family's businesses continued to
expand their trademark portfolios in China during Trump's time in office, any visibility into thissignificant aspect of his finances is sharply limited, because [ u] ntil this year, the former US
president's ethics forms didn't disclose his trademarks in foreign countries .
For Mr. Trump's businesses , trademarks serve multiple purposes and cover a range of
products . New York Times reported in February 2017 that [ h ] is trademarks in recent years havecovered all manner of potential products across the world , from alcohol to video games andgambling
The Times added : Sometimes Mr. Trump's trademarks are markers for venturesthat never materialized or construction projects underway where he is licensing his name . Other
times they appear to be part of a defensive strategy to ward off trademark infringement . 186
FormerPresidentTrump first disclosedhis ownershipoftrademarkson ethicsforms hefiled as a presidentialcandidatein 2023, which coveredhisfinances only from November2021.
AlthoughMr.Trump was requiredto completethis same financialdisclosureform eachyear he
was inoffice, he neglectedto includehundredsoftrademarkshe owns on theseforms during
his presidency. BusinessInsidernoted:

The belateddisclosuresmeanthat Americanshad little

State ofNew York Officeof the Attorney General, Depositionof DonaldBender, at 69 (Apr. 18, 2023).
From Trumpthe Nationalist, a Trail ofGlobalTrademarks, New York Times (Feb. 21, 2017) (online atwww.nytimes.com/2017/02/21/business/donald-trump-trademarks-chinahtml) .

181 Trump Waited Until After He Left Office to Disclose Trademarks He Owns in China and Russia,
Business Insider (Nov. 3 , 2023 ) (online at www.businessinsider.com/trump-disclose-china-russia-foreign
trademarks -after -presidency -2023-10 ); Business Insider pointed out that the countries where former President
Trump owns trademarks includes China, Venezuela , Iran, Cuba , Belarus , and other countries heavily sanctioned by
the United States . Mr. Trump amended this disclosure , at which time he removed a trademark he had listed thatwas issued by Saudi Arabia . .
182

.

183

.

184

.

185 Id From Trump the Nationalist, a Trail of Global Trademarks , New York Times (Feb. 21, 2017)( online at www.nytimes.com/2017/02/21/business/donald-trump-trademarks-china.html
186

.

56

).

insight into the scope of Trump's foreign asset holdings during his presidency, and are only
learning about them as he runs for a second term in the 2024 election. 187

The ability of Trump family businesses to secure trademarks in China clearly improved
markedly and rapidly when Trump entered office. 188 For example , for a decade , Mr. Trump had
been in a bureaucratic battle trying to wrest the rights to his name back from a man named
Dong Wei, according to the Associated Press.

The Chinese government conspicuously

awarded then-President Trump a trademark shortly after he assumed office, which the AssociatedPress described as a surprise win for Trump and reported, may well be the first foreign
Moreover , it was granted mere days
trademark to be handed to Trump during his presidency.
after then-President Trump agreed to honor China's One-China policy

an arrangement underwhich the U.S.recognizes formal diplomatic relations with China but not Taiwan
then- President Trump had with President Xi.

during a call

The expansion of Trump business interests in China also included former President
Trump's daughter and White House Advisor , Ivanka Trump . The Chinese government granted
Ivanka Trump's business first trial approval on one trademark on May 6, 2018 , and registration
approval for five additional trademarks the following day. 192 Within a week , on May 13 , 2018,
President Trump announced on Twitter that he had personally instructed the Commerce
Department to reverse its decision to sanction ZTE, a Chinese telecommunications company .

193

187

Trump Waited UntilAfter HeLeft Office to DiscloseTrademarksHe Owns in China andRussia,
BusinessInsider(Nov. 3 , 2023) ( online at www.businessinsider.com/trump-disclose-china-russia-foreign
trademarks-after-presidency-2023-10); Office of GovernmentEthics, ExecutiveBranchPersonnelPublicFinancial
Disclosures(OGE Form 278e) (DonaldJ. Trump) (Filed Aug. 14, 2023) (Part 1 online atwww.citizensforethics.org/wp-content/uploads/2023/08/Disclosure-Report-Part-1-8-14-23.pdf) (Part2 onlineat
www.citizensforethics.org/wp-content/uploads/2023/08/Disclosure-Report-Part-2-8-14-23.pdf) (Part 3 onlineat
www.citizensforethics.org/wp-content/uploads/2023/08/Disclosure-Report-Part-38-14-23.pdf) (Part4 online atwww.citizensforethics.org/wp-content/uploads/2023/08/Disclosure-Report-Part-4-8-14-23.pdf).
188Donald Trump filed trademark applicationsin China beginningin 2006. From the time he announced
his candidacyfor the presidency in2015 through2019, roughly 200 trademark applicationsby DonaldTrump and
Ivanka Trump were pendingin China. Center for American Progress, Trump's Conflicts ofInterest in China (June14, 2017) (online at www.americanprogress.org/article/trumps-conflicts-interest-china/) ; Trump Trademark
Applications SpikedAround the World When He Started Runningfor President, CNBC (Dec.4 , 2019) (online atwww.cnbc.com/2019/12/04/trump-accelerated-trademark-requests-while-running-for-presidenthtml) .
China Awards Trump Valuable New Trademark , Associated Press (Feb. 16, 2017) ( online athttps://apnews.com/article/5870a27432b54e92b9a8cb7734eb57d5 ) .
190.

Trump Agrees to Support One China Policy in Xi Jinping Call, The Guardian (Feb. 10,2017)(online at www.theguardian.com/world/2017/feb/10/donald-trump-agrees-support-one-china-policy-phone-call-xi
jinping).
192IvankaTrump's BusinessWins Approvalfor MoreChina Trademarks, Citizens for Responsibilityand
Ethicsin Washington (June 27, 2018) ( online at www.citizensforethics.org/reports-investigations/crew
investigations/ivanka-trumps-business-wins-approval-for-more-china-trademarks ) .
Donald J. Trump (@realDonaldTrump ), X (formerly Twitter ) (May 13, 2018) (online athttps://x.com/realDonald Trump /status /995680316458262533 ?s 20 ); Factbox: U.S. Bans Sales to Major Chinese

Telco Equipment Vendor ZTE, Reuters ( Apr. 17, 2018 ) (online at www reuters.com/article/usa-china-zte.
57

The followingmonth, on June 7 , 2018, IvankaTrump Marks LLC receivedtrademark
registrationapproval for three additionaltrademarksin China.194

her official role, Ms. Trump met with world leaders as a representative of the UnitedStates abroad and alongside then - President Trump . Although Ms. Trump reportedly curtailed
her day-to- day involvement in her company in January 2017 , she did not divest from it, and thecompany continued applying for trademarks abroad to license the Ivanka Trump name.

195

Early in the Trump Administration, the Chinese government reportedly identified Ms.
Trump and her husband, Jared Kushner, as a promising channel through which to thaw relations
with the new president after his abrasive campaign rhetoric regarding China.
On March 28,
2017, IT Operations LLC, one of Ivanka Trump's holding companies, filed 14 applications for
trademarks in China.
One day later, Ivanka Trump formally joined the Trump Administration
as an Advisor to the President. The next month, in April 2017, the Chinese government
preliminarily granted three trademarks for Ivanka Trump Marks LLC, another holding company
owned by Ivanka Trump, to expand her brand in China. Ms. Trump received the trademark
approvals the same day that then-President Trump hosted Chinese President Xi in Mar- a-Lago,
Florida, along with Ivanka Trump and Mr. Kushner, who was then a Senior Advisor to President
Trump 198

State Administration for Industry and Commerce of the People's Republic of China, TrademarkDetails(Ivanka Trump Marks LLC) ( online at www.citizensforethics.org/wp-content/uploads/legacy/2018/06/June-2018
trademarks.pdf) (accessed Dec. 8, 2023) ; Trump StrikesDealto Save China's ZTE as NorthKorea Meeting Looms,
New York Times (June 7, 2018) (online at www.nytimes.com/2018/06/07/business/us-china-zte-dealhtml); Ivanka
Trump'sBusiness WinsApprovalfor More China Trademarks, Citizens for Responsibilityand Ethics in Washington(June27,2018) ( online at www.citizensforethics.org/reports-investigations/crew-investigations/ivanka-trumps
business-wins-approval-for-more-china-trademarks/) .
194

195 Ms.Trump formerly served as President, Treasurer, and Secretary ofIT Operationsbefore assuminga
positionin the Trump Administrationin 2017. Office of GovernmentEthics, ExecutiveBranchPersonnelPublic
FinancialDisclosureReport(OGE Form278e) ( IvankaTrump) (FiledJune 12, 2017) (online atwww.politico.com/f/?id=00000161-87a8-d53a-a5f5-b7fc5f7f0001) ; IvankaTrump, ShiftingPlans, Will Becomea
FederalEmployee, New York Times (Mar.29, 2017) (online at www nytimes.com/2017/03/29/us/politics/ivanka
trump- federal-employee-white- house.html) ; IvankaTrump's BusinessWins Approvalfor 16NewChinese
TrademarksDespiteShuttingDown, Citizens for Responsibilityand Ethicsin Washington(Nov.5, 2018) (online atwww.citizensforethics.org/reports-investigations/crew-investigations/ivanka-trump-trademarks/).
China WoosIvanka, Jared Kushner to SmoothTies with Trump, Bloomberg (Feb. 7, 2017) (online at.

www.bloomberg.com/politics/articles/2017-02-07/china-courts-ivanka-jared-kushner-to-smooth-ties-with-trump)
197 Letter from Representative John Conyers , Jr. et al. , Committee on the Judiciary , to Abigail Klem,
President, IT Operations LLC, 115th Cong. (June 12, 2017) (online at https://democrats

judiciary house.gov/sites/democrats.judiciary.house.gov/files/documents/response%20letter%20to%20it%20operati
206.12.2017.pdf) . Ms. Trump formerly served as President, Treasurer, and Secretary ofOperations
before assuming a position in the Trump Administration in2017. Office of GovernmentEthics, ExecutiveBranch
PersonnelPublic FinancialDisclosureReport( OGE Form278e) (Ivanka Trump) (Filed June 12, 2017) (online atwww.politico.com/f/?id=00000161-87a8-d53a-a5f5-b7fc5f7f0001).
China Defends Trademark Grants for Ivanka Trump Products , NPR (Apr. 19, 2017 ) ( online atwww.npr.org/sections/thetwo-way/2017/04/19/524765086/china-defends-trademark-grants-for-ivanka-trump
products) .
58

199

Inmid-2018, Ivanka Trump announced she would dissolve her fashion brand.
Despitein
China.
The
this announcement, Ivanka Trump Marks LLC continued to retain trademarks
Chinese government preliminarily granted first-trial approval for 16 trademarks for fashion
items and other goods including, notably, voting machines to Ivanka Trump in 2018.200
Ivanka Trump continued to receive trademarks from the Chinese government through 2019,
when Ivanka Trump Marks LLC received provisional approval for five trademarks that covered,for example, child care centers [ ] brokerage, charitable fundraising and art valuation
services 201
Publicreportingindicatedthat by April2019, the Chinese governmenthad granteda total
of41trademarksto companiesassociatedwith IvankaTrump and that her companieshad
receivedtrademark approvalsroughly40% faster after DonaldTrumpwon the 2016 U.S.
202

presidentialelectionthan hadbeenthe case priorto the election.²
AdditionalSpendingat Trump- OwnedProperties

Chinese State Involvementin the PrivateSector

China's President Xi has overseen a policy that enmeshes the CCP into the private
economy, blurring the line between state- owned enterprises and private industry.203 The Chinese
economy mixes centralized control with market forces that President Xi has praised as
market economic reform.

socialist

Further, numerous laws nominally enacted for national security

purposes have placed companies under tighter government control, including measures that
require telecommunications companies to give technical support and assistanceto thegovernment , including the national security apparatus .205 In addition, in 2018, as several major
Chinese companies faced towering debts and potential defaults , the Chinese government steppedin and took over these firms to prevent further damage to their domestic economy.
206

Citizensfor Responsibilityand Ethicsin Washington,Ivanka Trump's BusinessWins Approvalfor 16
New ChineseTrademarks Despite ShuttingDown (Nov. 5, 2018) ( online at www.citizensforethics.org/reports
investigations/crew- investigations/ivanka-trump-trademarks/) .
200 Id Ivanka Trump Receives 5 Trademarksfrom China Amid Trade Talks, CBS (Jan. 21, 2019) (online atwww.cbsnews.com/news/ivanka-trump-receives-5-trademarks-from-china-amid-trade-talks/).
201IvankaTrumpReceives5 TrademarksfromChinaAmid TradeTalks, CBS ( Jan. 21, 2019) ( onlineat
www.cbsnews.com/news/ivanka-trump-receives-5-trademarks-from-china-amid-trade-talks/).

202Ivanka'sTrademark Requests WereFast-Trackedin ChinaAfter Trump Was Elected, Forbes (Apr. 14,2022) (onlineat www.forbes.com/sites/tommybeer/2020/09/22/ivankas-trademark-requests-were-fast-tracked-inchina-after-trump-was-elected) .
203 Congressional Research Service , China's Recent Trade Measures and Countermeasures : Issuesfor
Congress (Dec. 10 , 2021) ( online at www.crs.gov/reports/pdf/R46915/R46915.pdf ) .

204 In Xi's China, the Business of Business Is State- Controlled , New York Times (Oct. 17, 2022) (online atwww.nytimes.com/2022/10/17/business/china-xi-jinping-business-economyhtml) .

205

Library of Congress , China: New Regulation on Police Cybersecurity Supervision and Inspection
Powers Issued (Nov. 13, 2018) (online at www.loc.gov/item/global-legal-monitor/2018-11-13/china-new
regulation-on-police-cybersecurity-supervision-and-inspection-powers-issued).
206

AnbangTakeover Puts China's Companies on Notice, Reuters (Feb. 25, 2018) (online atwww.reuters.com/article/us-china-anbang-takeover-analysis/anbang-takeover-puts-chinas-companies-on-notice59

The documents provided to the Committee by Mazars record payments to Trump- owned
businesses by corporate entities whose ownership structures are highly opaque but that havenumerous ties to the government of the P.R.C. Given the opacity ofthese companies ownership
structures and the uncertain nature of their specific ties to the government of the P.R.C.—
including the CCP

this report does not classify expenditures at Trump -owned properties bythese companies recorded in the documents Mazars produced to the Committee as emoluments .
Nonetheless , spending by these entities at President Trump's properties during his presidency
raised potential conflicts of interest .
Additional
Spendingat TrumpProperties: Huawei

The U.S. government has long expressed significant concerns about the national security
risks posed by Huawei , a leading Chinese telecommunications equipment provider . More than adecade ago, a 2012 report by the House Permanent Select Committee on Intelligence ( HPSCI) ,led by then- Chairman Republican Mike Rogers, determined that Huawei was a national security
threat due to its attempts to obtain intelligence and other sensitive information through Americancompanies . At the time, HPSCI obtained documents showing that Huawei furnished an elitecyber- warfare unit within the People's Liberation Armywith special network services .207

Inthe springof2017, the Departmentof the Treasuryand the Departmentof Commerce
reportedlyhad investigationsunderwayto examine whether Huaweihad violated U.S. trade
208

controlswith respectto Cuba, Iran, Sudan, NorthKorea, and Syria.²

While these investigations progressed , Congress included provisions in Section 1656 of
the Fiscal Year 2018 National Defense Authorization Act (NDAA) prohibiting the U.S.
Department of Defense (DOD) from using Huawei technology in any nuclear control or ballistic
missile defense system absent a waiver 209 President Trump signed the Fiscal Year 2018 NDAA
on December 12,

The Mazars records reveal that just a week later, on December 19,

2017 , Huawei made a deposit to the Trump International Hotel in Las Vegas , Nevada, for a
Huawei Device USA Meeting scheduled for January 2018 at the hotel.211

idUSKCN1G909L).

207 House Permanent Select Committee on Intelligence , Investigative Report on the U.S. National Security
Issues Posed by Chinese Telecommunications Companies Huawei and ZTE ( Oct. 8, 2012 ) (online athttps://intelligence.house.gov/sites/intelligence house.gov/files/documents/huawei
zte 20investigative % 20report %20 (final) .pdf) .
208 Huawei Chinese Technology Giant, Is Focus ofWidening U.S. Investigation, New York Times (Apr.
26, 2017) (online at www.nytimes.com/2017/04/26/business/huawei-investigation-sanctions-subpoena.html).
Pub. L. No. 115-91, § 1656 (2017) ; Congressional Research Service, U.S. Restrictionson Huawei
Technologies : National Security, Foreign Policy, and EconomicInterests (Jan 5. 2022) (online athttps://crsreports.congress.gov/product/pdf/R/R47012/2) .

Departmentof Defense, Press Release: Trump Signs FiscalYear 2018DefenseAuthorization (Dec.
12, 2017) (online at www.defense.gov/News/News-Stories/Article/Article/1394990/trump-signs-fiscal-year-2018
defense-authorization/) .
211 MAZARS- OVERSIGHT_COMMITTEEE - 00027218.

60

While a Trump - owned hotel was doing business with Huawei , others in the federal
government continued to sound the alarm about the Chinese company . On February 13, 2018 ,six U.S. intelligence chiefs testified before Congress that American consumers should not buy
Huawei devices and services.212

In August 2018 , Congress enacted the Fiscal Year 2019 NDAA , which restricted theentire U.S. government from doing business with Huawei or entities that used Huawei
equipment .
213

Also in August2018, the DOJfiled a sealed indictmentallegingthat Huawei undertook amulti-year criminal scheme to violate U.S. sanctions on Iranby operating an unofficial
subsidiaryto obtain otherwise prohibited U.S.-origin goods, technology and services for its
Iran- basedbusiness 214 Accordingto the DOJ, when Huawei and HuaweiUSA became aware
ofthe U.S. government's criminal investigation in 2017, the company made efforts to movewitnesses withknowledge ofthe scheme to China and to destroy and conceal evidence in the
UnitedStates

In January 2019, when announcingthe indictments against Huawei and otherdefendantspublicly, the Director of the FederalBureau of Investigation, ChristopherWray,On
warned that Huaweiposes a dual threat to both our economic and national security
October24, 2022, the DOJannounced that it had charged two intelligence officers ofthe P.R.C.
for attempting to obstruct a criminal prosecutionin the EasternDistrictof New York against a
217

Chinese telecommunicationsfirm which, according to public reporting, was Huawei.²

Senate Select Committee on Intelligence, OpenHearing on Worldwide Threats, 115th Congress, (Feb.
13, 2018) (online at www.intelligence.senate.gov/hearings/open-hearing-worldwide-threats-0#) ; Six Top US
Intelligence Chiefs Caution Against Buying HuaweiPhones, CNBC (Feb. 13, 2018) (online atwww.cnbc.com/2018/02/13/chinas-hauwei-top-us-intelligence-chiefs-caution-americans-away.html).

213. L. No. 115-232,

889 (2018) .

214 SeeSupersedingIndictment, Doc. 126 (Feb. 13, 2020) , UnitedStates ofAmericav. HuaweiTechnologies
Co., LTD HuaweiDevice Co., Ltd., HuaweiDeviceUSAInc., FutureweiTechnologies, Inc., Skycom Tech Co. Ltd.
WanzhouMeng, E.D.N.Y(No. 1-18- cr- 00457-AMD- CLP) (online at www.justice.gov/opa/press
release/ file/ 1248961/download) . HuaweiChiefFinancialOfficerWanzhouMengentered into a deferred
prosecutionagreement(DPA) with federal prosecutorsand pursuantto the DPA, took responsibilityfor her
principalrole in perpetratinga scheme to defrauda global financialinstitution. Departmentof Justice, Press
Release: HuaweiCFO MengWanzhouAdmits to MisleadingGlobalFinancialInstitution( Sept. 24 , 2021) ( online atwww.justice.gov/opa/pr/huawei-cfo-wanzhou-meng-admits-misleading-global-financial-institution).
215 See id

DepartmentofJustice, PressRelease: Chinese TelecommunicationsConglomerateHuaweiandHuawei
CFO Wanzhou Meng ChargedwithFinancialFraud(Jan. 28, 2019) (online at www.justice.gov/opa/pr/chinese
telecommunications-conglomerate-huawei-and-huawei-cfo-wanzhou-meng- charged-financial) .
216

217

Department of Justice, Press Release: Two Arrested and 13 Charged in Three Separate Cases forAlleged Participation in Malign Schemes in the United States on Behalf ofthe Government ofthe People's RepublicofChina (Oct.24, 2022) (online at www.justice.gov/opa/pr/two-arrested-and-13-charged-three-separate-cases.

alleged-participation-malign- schemes-united) See also U.S. Charges Two Chinese Nationals with Obstructing
Huawei Case, Source Says , Reuters (Oct. 24 , 2022 ) (online at https://reuters.com/legal/us-charges-two-chinese
defendants -with-trying -obstruct -telecom-prosecution -2022-10-24/) .
61

While both Congress and officials inside the Trump Administration sought to take a hardline on Chinese companies operating in a manner contrary to U.S. national security, thenPresident Trump repeatedly contradicted administration officials in an apparent effort to blunt the
restrictions the U.S. government was placing on Huawei.218 His seeming pushback provoked
bipartisan backlash across Congress.
In May 2019 , the Commerce Department placed Huawei on its Entity List

commonly

known as the Commerce blacklist
prevented the firm from buying American products
without U.S. government approval . 219 However , a little over a month after Huawei was placedon the Entity List, then- President Trump declared that after consultation with President Xi, hewould lift the blacklist of Huawei, stating on Twitter :At the request of our High Tech companies , and President Xi, I agreed to allow Chinesecompany Huawei to buy product from them which will not impact our National Security
Importantly , we have opened up negotiations
220
them continues to be a very good one .
Forbes reported thatagain with China as our relationship with

Trump told reporters that U.S. companies can sell their equipment

to Huawei, as long as its [ sic] equipment where there's no great national security problem . He
221suggested this was a personal favor to Xi.
Lawmakers from both parties strongly condemned former President Trump's reversal.
For example , Senator Marco Rubio ( R - FL) tweeted :PresidentTrump has agreed to reverse recent sanctions against #Huawei he has made acatastrophic mistake. Itwill destroy the credibility of his administrations warnings about
the threat posedby the company, no one will ever again take them seriously [ sic]
The reversal was , however, greeted with enthusiasm by Huawei on its Twitter account ,which posted a link to the story and issued the following tweet:

223

218

Trump's Offer ofU.S. Tech Lifelinefor Huawei Prompts FiercePoliticalBacklash, Forbes (June 29,2019) (online at www.forbes.com/sites/zakdoffman/2019/06/29/trumps-offer-of-u-s-tech-lifeline-for-huawei
prompts-fierce-political-backlash ) .
.

Bureauof Industryand Security, AdditionofEntitiesto the EntityList, 84 Fed. Reg 22961( May21,2019) ( finalrule) .

220 Donald J. Trump (@realDonaldTrump ), X (formerly Twitter) (June 29, 2019) ( online athttps://twitter.com/realdonaldtrump/status/1145097779632627712) . See also White House WillReportedly Waiton
GrantingHuaweiLicenses as the Trade War Ramps Back Up, CNN Business (Aug 9 , 2019) (online atwww.cnn.com/2019/08/08/tech/huawei-licenses/indexhtml) .
221

Trump's OfferofU.S.TechLifelinefor HuaweiPrompts FiercePoliticalBacklash, Forbes (June 29,2019) (online at www.forbes.com/sites/zakdoffman/2019/06/29/trumps-offer-of-u-s-tech-lifeline-for-huawei
prompts- fierce-political-backlash) .
222 MarcoRubio( @marcorubio) , X ( formerly Twitter) ( June 29, 2019) ( online athttps://twitter.com/marcorubio/status/1144977483101593601).
223 HuaweiFacts( @HuaweiFacts) , X ( formerly Twitter) ( June29, 2019) ( online athttps://twitter.com/HuaweiFacts/status/1144882620804689921).
62

Huawei Facts
HUAWEI

Following@HuaweiFacts

U - turn ? Donald Trump suggests he would
allow #Huawei to once again purchase U.S.
technology ! #HuaweiFacts

While Huaweiultimately remained on the blacklist, then-President Trump's
Administration granted Huaweisix temporary general licenses, generally known as reprieve[s]betweenMay 2019 and August 2020, allowing American companies to continue doing businesswith Huawei.224 In November 2019, the Department of Commerce announcedthat it would not
only extend Huawei's temporary general license, but would approve additional, morepermanent licenses that would allow Huaweito fully resume its engagement with certain U.S.
firms 225
InNovember 2019, a bipartisan group of 15 Senators
Cotton, Josh Hawley, Elizabeth Warren , and Rick Scottincluding Chuck Schumer, Tomwrote to President Trump expressing

their strong disapproval of the decision to grant Huawei reprieves and requesting he suspend the
granting of licenses until he provided Congress with more information on the effect ofthis action
on national security .
The Trump Administration extended an additional three reprieves to
226

Huawei despite receiving this bipartisan letter. The Department of Commerce did not fully
implement the ban on Huawei until August 13,
into effect 227

months after it was scheduled to go

June 12, 2020 , the DOD published its inaugural list of entities

owned or controlled

by the Chinese military , which included Huawei.228 Later in June 2020 , the Federal

224 TheDepartmentof Commerce issuedthe initialTemporaryGeneral License on May22, 2019. The
TemporaryGeneralLicense'svaliditywas extendedonAugust 21, 2019, November18, 2019, February 18, 2020,
March 18, 2020, and May 18, 2020. Departmentof Commerce, HuaweiTemporaryGeneralLicenseExtension
FrequentlyAskedQuestions(FAQs) (May 18, 2020) ( online at https://bis.doc.gov/index.php/documents/pdfs/2446
huawei- entity- listtemporary-general-license- extension-faqs/ file) ; CongressionalResearchService, U.S.Restrictions
on HuaweiTechnologies: NationalSecurity, ForeignPolicy, andEconomicInterests (Jan 5. 2022) (onlineat
https://crsreports.congress.gov/product/pdf/R/R47012/2).
225 Letter from Senator Chuck Schumer , Senator Tom Cotton , et al. , to President Donald J. Trump (Nov.
19, 2019 ) ( online at www.democrats.senate.gov/ptsschhw?download ).
226.

227 CongressionalResearchService, U.S. Restrictionson HuaweiTechnologies: NationalSecurity, Foreign
Policy, andEconomicInterests( Jan. 5 , 2022) ( online at https://crsreports.congress.gov/product/pdf/R/R47012/2).

228 Under federal law, the Department ofDefense is required to track firms

owned or controlled by

China's People's Liberation Army that are active in the United States. Pub. L. No. 105-261 ( 1998) ; Department of
Defense, Qualifying Entities Prepared in Response to Section 1237 of the National Defense Authorization Act for
FiscalYear 1999 (PUBLIC LAW 105-261) (June 12 , 2020) ( online athttps://media.defense.gov/2020/Aug/28/2002486659/-1/

1/ 1/LINK_2_1237_TRANCHE_1_QUALIFIYING_ENTITIES.PDF ); Exclusive : Trump Administration Says
Huawei, Hikvision Backed by Chinese Military, Reuters (June 23 , 2020 ) (online at www reuters.com/article/us-usa
china-military-exclusive/exclusive -trump -administration - says -huawei-hikvision-backed-by-chinese-military
document-idUSKBN23V309 ; Huawei on List of 20 Chinese Companies That Pentagon Says Are Controlled by63

CommunicationsCommissiondesignatedHuawei
ZTE- as threatsto U.S. nationalsecurity.²

as well as Chinesetelecommunicationsfirm

229

Huawei'sExpenditureat Trump- OwnedProperty
According to ledgers that Mazars produced to the Committee, Chinese
telecommunications giant Huawei made a $5,377 advance deposit at the Trump International
Hotel in Las Vegas on December 19, 2017, for an event labeled Huawei Device USA Meetingscheduled to be held from January 11 to January 15, 2018.²
230 Huawei may have made additional
payments beyond this advance deposit, but the limited records provided by Mazars do notprovide any more information on this event. 231 In this instance as in so many others, Chairman
Comer's release of Mazars from its obligations to produce records under the Committee's
subpoena has prevented the Committee from determining with certainty the full amount ofthe
payments made by Huawei to Trump- owned businesses .
Additional Spending at Trump Properties: CEFC China Energy Subsidiary

Atits height, CEFC was one ofthe largest companiesinChina: an oil, coal, and financial
CEFC
conglomeratewithan estimated$40 billioninrevenueand 50,000 employees.
financed energyprojectsacross the globe and ownedconsiderablepropertyassets, includinga
condominiumunit at Trump World Tower.
is the same entity that Hunter Biden did business with during the Trump

presidency, including entering into an August 2017 consulting agreement in connection with thejoint pursuit of investments , as well as a September 2017 agreement for Mr. Biden to provide
legal representation to a CEFC official under federal investigation in the U.S.233
InMarch2018, as CEFC's financialsituationappearedto deteriorate, state mediainthe
P.R.C.reportedthat state- owned investmentfirm ShanghaiGuoshengGroup hadtakenover
Inthe absence of independentreportingon this event, this reporthas not classified

People's Liberation Army, TIME (June 25 , 2020) (online at https://time.com/5859119/huawei-chinese-militarycompany-list/).

229 FederalCommunications Commission, Press Release: FCCDesignates Huaweiand ZTE as National
SecurityThreats (June 30, 2020) (online at https://docs fcc.gov/public/attachments/DOC-365255A1.pdf) ; F.C.C.
Designates Huawei andZTE as NationalSecurity Threats, New York Times (June 30, 2020) (online atwww.nytimes.com/2020/06/30/technology/fcc-huawei-zte-national-securityhtml) .

230 MAZARS-OVERSIGHT_COMMITTEEE-00027218; Exclusive: Trump AdministrationSays Huawei,
HikvisionBackedby Chinese Military, Reuters (June 24, 2020) (onlineat wwwreuters.com/article/us-usa-china
military-exclusive/exclusive-trump-administration-says-huawei-hikvision-backed-by-chinese- military
idUSKBN23V309 ) .

231
As notedin the Methodologysection, advancedepositstypicallyconstituteonlypartof the total costof
an event

232 The Riseand Fallof a BeltandRoadBillionaire, CNN(Dec. 12, 2018) ( onlineat
www.cnn.com/interactive/2018/12/asia/patrick-ho-ye-jianming-cefc-trial-intl/).
233 InsideHunterBiden'sMultimillion-DollarDealswith a ChineseEnergyCompany, WashingtonPost( Mar.30, 2022) (onlineat www.washingtonpost.com/politics/2022/03/30/hunter-biden-china-laptop/).

234 China's CEFC Taken Over by Shanghai GovernmentAgency: SCMP Report, Reuters ( Mar. 2, 2018)64

CEFCas stated- owned, and therefore does not count its expendituresas emoluments. If,
however, the companytruly becamea state enterpriseinMarch2018, its expendituresafter thatdate wouldconstituteemolumentsunderthe standardpreviouslydiscussed.
In2012 , Hong Kong Huaxin Petroleum Company Limitedof CEFCa wholly owned subsidiarybought an apartment in Trump World Tower for $ 5.25 million dollars .

Hong Kong

Huaxin Petroleum Company Limited maintained this property throughout the Trump
presidency.236 Records provided to the Committee by Mazars and court documents indicate thatHong Kong Huaxin Petroleum Limited paid a standard common charge of $ 3,177.20 every
237
month in 2018.23
CEFC listed its apartment at Trump World Tower for sale on October 20 ,238
2020.2January 26, 2022 , CEFC sold the unit to an anonymous LLC named 845UN 78B
LLC for $4.625 million.239( online at www.reuters.com/article/us-china-cefc-probe/chinas-cefc-taken-over-by-shanghai-government-agency
scmp- report- idUSKCN1GE0X3) .

235

Trump TowerCEFC Deal, GovernmentExhibit2743 Trial ofPatrickHo, 17 CR 779 (online atwww.documentcloud.org/documents/5448620-Trump-Tower-CEFC-Deal-2743.html) . At the time, the contractof
salespecifiedthat the commoncharges for the apartmentwere$2,894 per monthwith monthlyassessmentsof$1,623. Id. , at Page 5. Seealso Inre ShanghaiHuaxinGroup (Hongkong) Limited(in Liquidation) , Southern
DistrictofNew York, at ExhibitB (Case No.19-11482(JLG)) (Doc. 2) (May 7, 2019) (online atwww.chinadocket.com/wp-content/uploads/2019/05/002-Verified-Petition-10.pdf).

New YorkCity Departmentof Finance, DocumentID: 2012030201095002(Feb.29, 2012) (online athttps://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImage
View?doc_id 2012030201095002) (accessedDec.
8, 2023) New York City Departmentof Finance, Final AssessmentRoll2016-2017, Borough: Manhattan, Block:
1340, Lot: 1342(Jan. 5, 2016) ( accessed Dec. 8, 2023) ; New York CityDepartmentof Finance, Final Assessment
Roll2017-2018, Borough: Manhattan, Block: 1340, Lot: 1342 (Jan. 5, 2017) ( accessedDec. 8, 2023); New York
CityDepartmentof Finance, Final AssessmentRoll2018-2019, Borough: Manhattan, Block: 1340, Lot: 1342(Jan.
2018) ( accessedDec.8 , 2023) ; New York City DepartmentofFinance, FinalAssessmentRoll2019-2020,
Borough: Manhattan, Block: 1340, Lot: 1342 (Jan. 5 , 2019) (accessedDec. 8, 2023) ; New York CityDepartmentof
Finance, FinalAssessmentRoll2020-2021, Borough: Manhattan, Block: 1340, Lot: 1342 (Jan. 5 , 2020) ( accessed
Dec.8 , 2023) .

237 Mazars provided records for Trump World Tower payments only for the year 2018. The 2018 records

indicate that in addition to the standard base charge , Hongkong Huaxin Petroleum Limited incurred a standard

charge titled "2017 SP ASSESS and varying electric utility fees . Per public reporting of apartment lease records ,Hong Kong Huaxin Petroleum Limited continued to lease in the Trump World Tower at least through 2021. See
StreetEasy , 845 United Nations Plaza # 78B (online at https://streeteasy.com/building/trump-world-tower/78b )(accessed Nov. 29 , 2023) . MAZARS -OVERSIGHT_COMMITTEE - 00027584 ; MAZARSOVERSIGHT COMMITTEE - 00027517 ; MAZARS -OVERSIGHT COMMITTEE - 00027726 ; MAZARSOVERSIGHT_COMMITTEE - 00027376 ; MAZARS -OVERSIGHT_COMMITTEE - 00027773 ; MAZARSOVERSIGHT COMMITTEE - 00027680 ; MAZARS -OVERSIGHT COMMITTEE - 00027633 ; MAZARSOVERSIGHT_COMMITTEE - 00027421 ; MAZARS -OVERSIGHT_COMMITTEE - 00027902 ; MAZARSOVERSIGHT_COMMITTEE -00027858 ; MAZARS - OVERSIGHT_COMMITTEE - 00027812 ; MAZARSOVERSIGHT_COMMITTEE - 00027469 .
238

StreetEasy , 845 United Nations Plaza #78B ( online at https://streeteasy.com/building/trump-world
tower/78b) (accessed Nov. 30, 2023 ) . 845 U.N. 78B, LLC was incorporated on October 11, 2021, roughly threemonths prior to CEFC's sale of Apartment 78B . OpenGov U.S., 845 UN78B, LLC (online athttps://opengovus.com/new-york-state-corporation/6300453 ) (accessed Nov. 30, 2023).

New York Department of Finance, CFRN : 2022012800663001 (online at https :// a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2022012800663001 ) (accessed Nov. 30, 2023).
239

65

Assumingthatthe base charges did not change during the four years ofthe Trump
presidency, HongKongHuaxinPetroleumLimitedpaidTrump World Tower at least $ 152,505
240

duringthe four years of the Trumppresidency.²

An excerpt ofthe Trump World Tower payment ledger for October 2018 appears
below 241

Building

Page

TRUMP WORLD TOWER CONDOMINIUM

TWT

845UNITEDNATIONS
PLAZA

3

43

Printed 2/5/2019

Status Report

MenuID MSR

All Tenants

October2018

Billing

Adjustments

PaymentDetail

Payments
Summarizedby
G / L

TenantUnit No

Lease

Opening

BaseExpires

Balance

ChargeHONGKONGHUAXIN

0.00

PETROLEUM
LIMITED3,177.20

Cde
7

154

MiscellaneousAmountChargesBilledELECTRIC
2017 SP ASSESS

157.20AdjustTotal Due

Charge Description

4,037.48

Date

G L

AmountPayment
10/01/18

703.08

BalanceDue Summarizedby

Account

Account

Description
MAINTENANCE/ REN

ChargeAmountCharge Description
3,177.20

ELECTRIC
INCOME

157.20

SPECIALASSESSM

703.08

Trump OrganizationBusinessDevelopment
in China

Documents produced to the Committee indicate that The Trump Organization , and the
Trump International Hotel in Washington , D.C. , may have continued to solicit business in China
after Mr. Trump entered office despite Trump's pledge not to engage in any new foreigndeals

during his time in office .242 In June 2017 , Patricia Tang, the Director of Sales andMarketing at the Trump International Hotel in Washington , D.C., billed the hotel $ 1,950 as areimbursable business expense for a Hotel in China.” 243

InNovember2017 the same monththat Mr. Trump made an official visit to China
Trump InternationalHotel expense reports reference a returntrip to China by Patricia
potentiallyreferringto Ms. Tang. Inaddition, a line item in a disbursement ledger indicates
reimbursementfor business cards printed by [redacted] for Patricia while on China Trip in
November 2017.
Ms. Tang's apparent active presence inChina suggests that The Trump
Organization continued to solicit business from foreign countries, especially China, during
Trump's presidency.

240

Trump World Tower records for all four years of Mr. Trump's presidency would be helpful to enablecalculation ofthe total common charges paid for this apartment, but the Committee's Minority staff is unable toreview these records because Chairman Comer released Mazars from its obligations under the Committee's
subpoena before all responsive documents could be produced.
241 MAZARS- OVERSIGHT_COMMITTEE- 00027858.

Would This Violate Trump's No-New-Foreign-Deals Pledge?, CBS News (Feb. 10, 2017) (online atwww.cbsnews.com/news/would-this-violate-trumps-no-new-foreign-deals-pledge/
243

MAZARS- OVERSIGHT_COMMITTEE - 00008260 .

244 MAZARS- OVERSIGHT_COMMITTEE- 00008644.
66).

Closing

BalanceSAUDIARABIA

Even the limited records that Mazars produced to the Committee make clear that former
President Trump's properties in Washington, D.C., and New York reaped hundreds ofthousands
ofdollars in unconstitutional emoluments from the government of the Kingdom of Saudi Arabia
between 2017 and 2020. Media reports have identified additional emoluments for which Mazars
never providedrecords to the Committee; as such, the total amount ofthe emoluments thenPresident Trump received from the Kingdom while he was in office is likely far higher than theamount shown in the limited set of documents provided by Mazars.
While he was receiving these emoluments , then -President Trump oversaw several highly
consequential decisions on a range of issues involving U.S. policy towards Saudi Arabia ,including the blockade by Saudi Arabia and its allies of Qatar , arms sales to Saudi Arabia , Saudi
Arabia's involvement in the conflict in Yemen , and the United States response to theassassination ofjournalist Jamal Khashoggi .

Inan unprecedented decision, and against the advice of his own Secretary of State , then
245 Just weeks
President Trump chose Saudi Arabia as the destination for his first foreign
after that trip, Saudi Arabia and its allies imposed a blockade against Qatar. President Trump
expressed support for this blockade almost immediately after it began, despite the presence of amajor U.S. military installation in Qatar.246 President Trump also expressed public support for
Saudi Arabia's military intervention in Yemen, even though its controversial air campaign had
caused a large number of civilian deaths.247 President Trump also supported arms sales to theKingdom and vetoed a bipartisan resolution demanding an end to U.S. military support for Saudi
actions in Yemen. 248 In addition , he also worked to cast doubt publicly on the conclusion oftheCentral Intelligence Agency ( CIA) his Administration's own intelligence service that Crown
Prince Mohammed bin Salman (commonly identified by his initials, M.B.S.) was responsible for249
the brutalmurder of Jamal Khashoggi.
245

After Helping Prince's Rise, Trump and Kushner Benefit from Saudi Funds , Washington Post (Feb. 11,2023 ) (online at www.washingtonpost.com/politics/2023/02/12/after-helping-princes-rise-trump-kushner-benefit
saudi-funds ).
246 Saudi Arabia, Egypt and Other Arab Nations CutDiplomatic Ties with Qatar , NPR (June 5, 2017)(online at www.npr.org/sections/thetwo-way/2017/06/05/531548717/saudi-arabia-egypt-and-other-arab-nations-cut
diplomatic -ties-with-qatar ); Trump Appears to Take Credit for GulfNations Move Against Qatar , CNN (June 6,2017) (online at www.cnn.com/2017/06/06/politics/trump-qatar-ideology/index html).
247 What You Needto Know About the Crisis in Yemen, TIME (Nov.3 , 2016) ( online athttps://time.com/4552712/yemen-war-humanitarian-crisis-famine/) ; The White House, Press Release: President
Trump's Speechto the Arab IslamicAmerican Summit (May 21, 2017) (online athttps://trumpwhitehouse.archives.gov/briefings-statements/president-trumps-speech-arab-islamic-american
summit) .

248

Trump To Resume Precision Munitions Deliveries to Saudis : Officials, Reuters (June 13, 2017) (onlineat www.reuters.com/article/us-usa-saudi-arms-congress/trump-to-resume-precision-munitions-deliveries-to-saudis
officials idUSKBN1942GG) ; S.J. Res. 7, 116th Cong. (2019) ; Trump Vetoes Measure to Force Endto U.S.
Involvement in Yemen War, New York Times (Apr. 6, 2019) (online atwww.nytimes.com/2019/04/16/us/politics/trump-veto-yemen html) .

249FullText: PresidentDonald Trump's Statement on SaudiArabia, Khashoggi Killing, Politico (Nov.20,2018) (online at www.politico.com/story/2018/11/20/donald-trump-statement-saudi-arabia-khashoggi-killing
67

The Mazars records show that, in just the year 2018 , the Kingdom of Saudi Arabia paid
then-President Trump's business entities more than $212,000 in emoluments through thecountry's ownership of the 45th floor of the Trump World Tower and a week -long stay in March2018 at the Trump International Hotel in Washington , D.C., by a Saudi government
delegation 250
While Mazars produced records for Trump World Tower only for the year 2018 , Saudi
Arabia owned its property in that building throughout the Trump Administration . Usingthe basecharges incurred for the property in 2018, and assuming that those charges did not change during
the four years ofthe Trump presidency, this report estimates that Saudi Arabia paid at least$615,422 inprohibited emoluments to former President Trump's businesses over the course of
his term in office from just that one property and the March 2018 stay at the Trump International
Hotelin Washington , D.C.
Since leaving office , former President Trump's business ties with the Saudi royal family
have only deepened , as Trump - owned golf courses have hosted events organized by LIV, a golf
tour funded by Saudi Arabia's sovereign wealth fund.251 On December 15, 2023 , for example ,former President Trump posted on social media :TRUMP NATIONAL DORAL , in Miami, has

just signed with LIV
to host a Championship Tournament in April , 2024. The event they
had at Doral in October was a major successAcknowledging Saudi willingness to transact business with him on unusually favorable
terms and perhaps signaling another future payback , former President Trump testified in an April
2023 deposition regarding his Turnberry golf course in Scotland that he believed he could sellthat to LIV Golf for a fortune , Saudi Arabia , among other potential buyers for a tremendous
amount of money, far beyond what it's worth by the money it makes , far beyond .
Similarly, former SeniorAdvisor Jared Kushner has also richly monetizedhis businessties with SaudiArabia

reportedlywith the direct assistance ofM.B.S. The day after his service

inthe Trump Administration ended, Mr. Kushner formed a company that became a private equity

1008219) .

-

-

-

250 MAZARS OVERSIGHT_COMMITTEE 00027371 ; MAZARS OVERSIGHT_COMMITTEE
00027416 MAZARS OVERSIGHT_COMMITTEE 00027464 ; MAZARS OVERSIGHT_COMMITTEE
00027512 ;MAZARS OVERSIGHT COMMITTEE 00027577 ; MAZARS OVERSIGHT COMMITTEE
00027628;MAZARS OVERSIGHT COMMITTEE 00027675; MAZARS OVERSIGHT COMMITTEE
00027721; MAZARS OVERSIGHT COMMITTEE 00027769 ; MAZARS OVERSIGHT COMMITTEE
00027808;
ARS OVERSIGHT_COMMITTEE 00027853 ;- OVERSIGHTCOMMITTEE
00027898 ;MAZARS OVERSIGHT_COMMITTEE 00008122 to MAZARS- OVERSIGHT_COMMITTEE
00008140.

251 Over 18Holes, Trump Praises LIV Golf, Its Saudi Backers, and His Own Courses, WashingtonPost(May 25, 2023) ( online at www.washingtonpost.com/sports/2023/05/25/trump-liv-golf-washington/).
252 DonaldJ. Trump ( @RealDonaldTrump), Truth Social (Dec. 15, 2023) (online athttps://truthsocial.com/@realDonaldTrump/posts/ 111584588355405636) .
253

Transcriptof DepositionofDonaldJ. Trumpat, 177–80( Apr.13, 2023) ( onlineat

www.documentcloud.org/documents/23932452

452564_2022_people_of_the_state_of_v_people_of_the_state_of_exhibit_s_859?responsive= 1 & title= 1) .
68

firm calledAffinityPartners.254 Withinsix monthsafter leavingthe White House, Mr. Kushnersecuredan investmentreportedlyworth $ 2 billionfrom Saudi Arabia's sovereignwealth255

Saudi Arabia's Emolument Spending at Trump Properties

Date

Expenditure

Location

2017-2020

45th

Trump World Tower
845 UnitedNationsPlaza

Amount256$ 134,2702

Trump World( NewYork, NY)( 2018)Estimated Total

Emolument for 4
Years :
$ 537,080( 2017-2020)
March, 2018

Trump International HotelRoyal Saudi( Washington , D.C.)

Embassy$ 78,342257

MinisterialVisit

ESTIMATEDEMOLUMENTSPAID BY SAUDIARABIA$ 615,422(2017-2020)

Before entering office, then- candidate Donald Trump spoke on several occasions about
his transactional relationships with Saudi Arabia and Saudi business interests. Duringhis firstcampaign speech at Trump Tower, he proclaimed, I love the Saudis. Many are in this258 InAugust 2015, Trump said, Saudi Arabia, I get along great with all ofthem.
building
They buy apartments from me. They spend $40 million, $50 million. He continued, Am I
supposed to dislike them? I like them very much! 259

254

After Helping Prince's Rise, Trump and Kushner Benefitfrom Saudi Funds, Washington Post (Feb. 11,2023) (online at www.washingtonpost.com/politics/2023/02/12/after-helping-princes-rise-trump-kushner-benefit
saudi - funds

---.

255

-----

-----

Before GivingBillions to Jared Kushner, SaudiInvestment FundHadBigDoubts, New York Times( Apr. 10, 2022) ( online at www nytimes.com/2022/04/10/us/jared-kushner-saudi-investment-fundhtml) .

256 MAZARS OVERSIGHT_COMMITTEE 00027371 ;MAZARS OVERSIGHT_COMMITTEE
00027416 MAZARS OVERSIGHT_COMMITTEE 00027464 ; MAZARS OVERSIGHT_COMMITTEE
00027512 MAZARS OVERSIGHT_COMMITTEE 00027577 ; MAZARS OVERSIGHT_COMMITTEE
00027628 ;MAZARS OVERSIGHT COMMITTEE 00027675 ; MAZARS OVERSIGHT COMMITTEE
00027721 ;MAZARS OVERSIGHT_COMMITTEE 00027769 ;MAZARS OVERSIGHT_COMMITTEE
00027808 ;ZARS OVERSIGHT_COMMITTEE 00027853 ;ZARS OVERSIGHT_COMMITTEE
00027898

257 MAZARS- OVERSIGHT_COMMITTEE - 00008122 to MAZARS - OVERSIGHT_COMMITTEE
00008140 .

258 Here'sDonald Trump's PresidentialAnnouncement Speech, TIME (June 16, 2015) (online at.

https://time.com/3923128/donald-trump-announcement-speech/) Ofnote, Mazars did not produce any ledgers to
the Committee regarding Saudi Arabia's occupancy ofany properties in Trump Tower.
259

Trump ClaimsHe Has No FinancialInterestsin SaudiArabia
He MakesLots ofMoneyfrom It,
CNBC ( Oct. 16, 2018) (online at www.cnbc.com/2018/10/16/trump-says-no-financial-interests-in-saudi-arabia-but
makes-money.html) .
69

Saudi State Visit and Blockade of Qatar

During then- President Trump's time in office , Saudi Arabia was led by King Salman bin
Abd al Aziz Al Saud. However, the central figure in Saudi policymaking was the King's son,Crown Prince Mohammed bin Salman (M.B.S.) .
King Salman formally appointed M.B.S. as
Crown Prince in June 2017 after he had served as Deputy Crown Prince from April 2015 ( as wellas in other senior government positions) 261

Trump's son-in-law and then-Senior Advisor Jared Kushner arranged for then-President
Trump to host the then-Deputy Crown Prince for a luncheon at the White House on March 14,
2017, which Mr. Kushner joined .262 President Trump's National Security Council urged against
the meeting, and Secretary of State Rex Tillerson didn't attend.263 Notably, it was reported
publicly in October 2018 that at some point during the Trump presidency, Kushner and M.B.S.
established direct communications with one another on WhatsApp , a private encrypted264

messaging platform.²

Reportedly, afterthe March2017luncheon, KushneraskedTrump to make Saudi
Arabiathe site of his first foreigntrip. Then- Secretaryof StateTillersonadvised
PresidentTrumpagainstchoosingSaudiArabiaas his inauguraloverseas visit andTrump, initiallytakingTillerson'sadvice, reportedlytold Kushner:
we're notgoingto SaudiArabia. Take no for an answer 265

Jared, read my lips:

Then- Senior Advisor Kushner, however, reportedly refused to take no for an answer andcontinued to push for the trip , arguing that it would be an opportunity to push the Saudis to:denounce terrorism in the region, sign deals that were supposed to create American jobs andpurchase U.S. arms. 266 Ultimately, Kushner prevailed , and on May 4 , 2017 , then-President
267

Trump announced that Saudi Arabia would be the destination of his first overseas trip.26

260 Congressional
ResearchService, SaudiArabia, ( Feb.4 , 2022) ( IFI0822) ( onlineat
https://crsreports.congress.gov/product/pdf/IF/IF10822/17) .

261Id Saudi Crown Prince Mohammed bin Salman, Power Behind the Throne, BBC (Oct. 6 , 2020) ( onlineat www.bbc.com/news/world-middle-east-40354415 ) .
262

TrumpMeetsSaudiPrinceas U.S. andKingdomSeek WarmerRelations, New York Times ( Mar. 14,2017) ( onlineat www.nytimes.com/2017/03/14/world/middleeast/mohammed-bin-salman-saudi-arabia-trumphtml) .

263Id After Helping Prince'sRise, Trump andKushnerBenefitfrom SaudiFunds, Washington Post (Feb.
11, 2023) (online at www.washingtonpost.com/politics/2023/02/12/after-helping-princes-rise-trump-kushner
benefit-saudi-funds/) .
264

Khashoggi Disappearance Prompts Kushner Retreat from Saudi Frontlines , CNN (Oct. 18, 2018)(online at www.cnn.com/2018/10/17/politics/jared-kushner-saudi-ties-jamal-khashoggi/indexhtml) .

After Helping Prince's Rise, Trump and KushnerBenefitfrom Saudi Funds, Washington Post (Feb. 11,2023) (online at www.washingtonpost.com/politics/2023/02/12/after-helping-princes-rise-trump-kushner-benefit
saudi-funds .
265

266

.

267SaudiArabia and Israel Will Be on Itinerary ofTrump's First Foreign Trip , New York Times (May 4,2017) (online at www.nytimes.com/2017/05/04/us/politics/trump-to-visit-saudi-arabia-and-israel-in-first-foreign
trip html).
70

President Trump's choice to make Saudi Arabia the first country he visited in office wasunprecedented , as no prior U.S. President had ever previously chosen any country in the Middle
East as the destination for his first overseas trip.268 Prior U.S. Presidents had almost exclusively
chosen either Canada or Mexico as their first international destination , including President
Trump's five immediate predecessors as president .269 Other presidents who did not choose
Canada or Mexico as their first destination have chosen long- standing allies . For example ,270
Presidents Carter and Nixon chose the United Kingdom and Belgium, respectively .
Inadvance of the announcement of the state visit to Saudi Arabia , then - Senior Advisor
Kushner reportedly was personally involved in arranging the arms deal that would eventually besigned during the visit . According to the New York Times, on May 1, 2017, Mr. Kushner" welcomed a high- level delegation of Saudis to a gilded reception room next door to the WhiteHouse and worked to arrange the " $ 100 billion-plus arms deal that the administration hoped toseal with Saudi Arabia . News reports indicated that Mr. Kushner was so closely involved heeven called the chief executive of Lockheed Martin to seek a price reduction for items being
considered for inclusion in the deal.271
Then- PresidentTrump arrived inRiyadh, SaudiArabia, on May20,

WhileinSaudiArabiafor the state visit, PresidentTrump and King Salman signedthe arms deal that
SeniorAdvisorKushnerhad helped orchestrate.273

Approximately three weeks after then- President Trump's state visit to Saudi Arabia , onJune 5, 2017 , it was reported that Saudi Arabia , the U.A.E. , and Egypt, among other nations,were cutting all ties with Qatar.

Saudi Arabia also sealed its border with Qatar

creating asignificant geopolitical rift in one ofthe most strategically sensitive regions in the world for theUnited States.274 President Trump thereafter made a series of public statements apparently siding
with the Saudis and U.A.E. in the dispute .
June 6 , 2017, then- President Trump tweeted :During my recent trip to the Middle

East I stated that there can no longer be funding of Radical Ideology. Leaders pointed to Qatar

268 How Trump's First Foreign Trip Compares with Past Presidents , CNN (May 20, 2017) (online atwww.cnn.com/2017/05/19/world/donald-trump-first-foreign-presidential-trips/index

269html) .

.

270

$ 110 Billion Weapons Sale to Saudis HasJared Kushner's Personal Touch, New York Times (May 18,2017) (online at www.nytimes.com/2017/05/18/world/middleeast/jared-kushner-saudi-arabia-arms-deal
lockheed.html).

DonaldTrump Landsin SaudiArabia onFirstOverseasVisitofPresidency, NBCNews ( May 20,2017) (onlineat www.nbcnews.com/storyline/trump-s-first-foreign-trip/donald-trump-lands-saudi-arabia-firstoverseas-visit-presidency-n762126) .
273

Trump Signs Kushner -negotiated $ 100B Saudi Arms Deal, CNN (May 20, 2017) ( online atwww.cnn.com/2017/05/19/politics/jared-kushner-saudi-arms-deal-lockheed-martin/indexhtml).

274 SaudiArabia, Egypt and OtherArab NationsCutDiplomaticTies withQatar, NPR (June 5, 2017)( onlineat www.npr.org/sections/thetwo-way/2017/06/05/531548717/saudi-arabia-egypt-and-other-arab-nations-cut
diplomatic-ties-with-qatar).
71

look ! 275 Later that same day, President Trump issued two consecutive tweets that explicitly
contrasted Saudi Arabia and Qatar: So good to see the SaudiArabia visit with the King and 50
countries already paying off. They said they would take a hard line on funding
followed byextremism and all reference was pointing to Qatar. Perhaps this will be the beginning of theend to the horror of terrorism
According to CNN, President Donald Trump appeared totake credit for the decision of major Gulf nations to cut diplomatic relations with Qatar, an
important US ally, putting his stamp ofapproval on the move despite Pentagon and State
Department attempts to remain neutral. 277
Whilespeakingto reporterson June 9 , 2017, then- SecretaryTillersonappearedto
contradictPresidentTrump, warning, The blockadeis hinderingUS militaryactionsin theregionand the campaignagainst ISIS

and he addedthat the UnitedStates

expectationis thatthese countries will immediatelytake steps to resolve the situation.
279

June 21, 2017, King Salman named M.B.S. as the Crown Prince of Saudi Arabia.²

Public reporting suggested that M.B.S. used Trump's visit to aid his sudden rise over a rival to
become crown prince.
June 23, 2017 , the Saudi- led coalition demanded that Qatar meet 13 conditions withinten days before the blockade would be lifted; among the demands were that Qatar

Curbdiplomatic ties with Iran;Sever all ties to terrorist organisations[ sic] ; Stop all means
offunding for individuals , groups or organisations [sic ] that have been designated as
terrorists by Saudi Arabia , the UAE, Egypt , Bahrain , the US and other countries ;281" Hand over terrorist figures.

andMarch20, 2018 , then- President Trump again welcomed M.B.S. to the White House.
Noting M.B.S.'s elevation in the line of succession within Saudi Arabia compared to his position
during his first White House visit the prior year, President Trump commented,
than the crown prince now.

You are more

During the meeting, President Trump stated:

275 DonaldJ. Trump( @realDonaldTrump) , X ( formerlyTwitter) ( June 6 , 2017) ( online athttps://twitter.com/realDonaldTrump/status/872062159789985792?s=20).
276

Tweetsof June 6 , 2017, The AmericanPresidencyProject, Universityof California, SantaBarbara( onlineatwww.presidency.ucsb.edu/documents/tweets-june-6-2017) .
277

Trump Appears to Take Credit for GulfNations Move Against Qatar , CNN (June 6 , 2017) (online atwww.cnn.com/2017/06/06/politics/trump-qatar-ideology/index.html ) .

278

Trump Qatar Must Stop Funding Terrorism, CNN (June 10, 2017) (online atwww.cnn.com/2017/06/09/politics/trump-qatar-saudi-gulf-crisis/index.html).

279 Saudi KingRewrites Succession, Replacing Heir with Son, 31, New York Times (June 21, 2017) (onlineat www.nytimes.com/2017/06/21/world/middleeast/saudi-arabia-crown-prince-mohammed-bin-salman.html ).
After Helping Prince's Rise, Trump and Kushner Benefitfrom Saudi Funds, Washington Post (Feb. 12,2023) (online at www.washingtonpost.com/politics/2023/02/12/after-helping-princes-rise-trump-kushner-benefit
saudi-funds ) .
280

QatarGiven10 Days to Meet 13 Sweeping Demands by SaudiArabia, The Guardian (June 23, 2017)( online at www.theguardian.com/world/2017/jun/23/close-al-jazeera-saudi-arabia-issues-qatar-with-13-demands-to
end-blockade) bold in originalsource]281

282 SaudiPrince's White House Visit ReinforcesTrump's Commitmentto HeirApparent, New York Times
72

It's a great honor to have the Crown Prince with us . Saudi Arabia has been a very greatfriend and a big purchaser of equipment and lots of other things . And one of the biggest
investments inthe United States is theirguess it's your big investment

is buying283

stock in companies and various other things in the United States and creating jobs.²
InApril2018, amid reportsthat SaudiArabiawas
borderwithQatarand dumpingnuclearwaste nearby

consider[ ing] digginga moatalongits

then- Secretaryof State Mike Pompeo

traveledto SaudiArabia, wherehe reportedlyurged his Saudi Arabiancounterpartto terminate
the blockadeofQatar. 284 Ultimately, however, the blockaderemainedin effectuntil January5 ,2021, when Saudi Arabia, the U.A.E., Bahrain, and Egyptagreedto liftthe blockadeandrestore
285
ties
Accordingto the WashingtonPost, shortly before Trump leftoffice, Kushnerflew to
SaudiArabiainearly January2021for his final officialmeetingwithM.B.S.and finalizedan
agreementto end Riyadh'sblockadeagainst Qatar.

286

President Trump Advances Large- ScaleArms Sales to SaudiArabia

Then-PresidentTrumppushedfor increasedarms sales to SaudiArabia even after reports
showedthatthe Saudi militaryused these weaponswithdisregardfor the lives ofcivilianswho
havebeencaught inthe years- longconflictinYemen.

In March 2015, Saudi Arabia entered the ongoing civil war in Yemen by initiating an air
campaign against the Houthis and a naval blockade . 287 The Houthis had previously ousted
Yemen's leader, Abd Rabbu Mansour Hadi ; the Saudi objective has ostensibly been to restore theHadi government . According to one analysis , Saudi Arabia's perception that the Houthis are an
Iranian proxy rather than an indigenous movement has driven Riyadh's military intervention .
The Saudi intervention has been supported by the U.A.E.289(Mar. 20 , 2018) (online at www.nytimes.com/2018/03/20/us/politics/saudi-crown-prince-arrives-at-white-house-to
meet-with-trump html) .
The White House, Remarks by President Trump and Crown Prince Mohammed Bin Salman of theKingdom of Saudi Arabia Before Bilateral Meeting (Mar. 20, 2018 ) (online athttps://trumpwhitehouse.archives.gov/briefings-statements/remarks-president-trump-crown-prince-mohammed-bin
salman- kingdom - saudi - arabia - bilateral- meeting ) .

284

Pompeo'sMessageto Saudis? EnoughIs Enough: Stop Qatar Blockade, New York Times (Apr. 28,2018) (onlineat www.nytimes.com/2018/04/28/world/middleeast/mike-pompeo-saudi-arabia-qatar-blockadehtml) .
285 CongressionalResearch Service, Qatar: Governance, Security, and U.S.Policy (Apr. 11, 2022)( R44533) (online at https://crsreports.congress.gov/product/pdf/R/R44533).
286

After Helping Prince's Rise, Trump and Kushner Benefitfrom SaudiFunds, Washington Post (Feb. 12,2023) (online at www.washingtonpost.com/politics/2023/02/12/after-helping-princes-rise-trump-kushner-benefit
saudi-funds ).
287 Timeline: Yemen War Began in 2014 When Houthis Seized Sanaa, Associated Press (Feb. 11, 2021)(online at https://apnews.com/article/joe-biden-saudi-arabia-ali-abdullah-saleh-united-arab-emirates-coronavirus
pandemic- 7a1c185cbd6cfb815dfbf7c21df1c0e1 ) .

Yemen's Tragedy : War, Stalemate, and Suffering, Council on Foreign Relations ( May 1 , 2023 ) (onlineat www.cfr.org/backgrounder/yemen-crisis ).

289

.
73

By late 2016, the conflict in Yemen was causing a humanitarian crisis that was pushing
the country to the brink of famine, as Saudi Arabia's air campaign was causing numerous
civilian casualties .
Nonetheless, in his prepared remarks for the Arab Islamic American
Summitheld during his state visit to Saudi Arabia in May 2017, then-President Trump expressed
support for the Saudi effort inYemen.291
In early June 2017 , then-President Trump notified Congress that his Administration
intended to deliver precision - guided bombs to Saudi Arabia , fulfilling part of a 2015 arms sale.
Former President Obama had blocked the arms delivery in late 2016 over concerns about civilian
deaths in Yemen , including the bombing of a funeral in October 2016 that killed and wounded
hundreds ofcivilians .

A 2017 report issued by Human Rights Watch documented 58

apparently unlawful airstrikes in the country, killing nearly 800 civilians and hitting homes ,293markets , hospitals , schools , civilian businesses , and mosques .

InAugust 2018, Saudi jets reportedly bombed a bus packed with schoolchildren innorthern Yemen, which killed at least 40 students aged 6 to 11 and left dozens morewoundedAccording to the New York Times, the bombs used in this attack were American
made
Despitethis, the next month, the Trump Administration issued a formal certification
affirming that Saudi Arabia and its coalition partner, the U.A.E., were “ undertaking
appropriate measures to alleviate the humanitarian crisis in Yemen and demonstrable actions to
reduce the risk of harm to civilians.
This certification was legally required to allow
American military aircraft to continue refueling warplanes flown by Saudi Arabia and the
U.A.E.297

What You Need to Know About the Crisis in Yemen , TIME (Nov. 3 , 2016) (online athttps://time.com/4552712/yemen-war-humanitarian-crisis-famine/ ) .

The White House, Press Release: President Trump's Speech to the Arab Islamic American Summit(May 21,2017) (online at https://trumpwhitehouse.archives.gov/briefings-statements/president-trumps-speech-arabislamic-american-summit )292 U.S. BlocksArms Sale to SaudiArabia Amid Concerns Over Yemen War, New York Times (Dec. 13,
2016) (online at www.nytimes.com/2016/12/13/us/politics/saudi-arabia-arms-sale-yemen-warhtml) ; What You Needto KnowAbout the Crisis in Yemen, TIME (Nov. 3 , 2016) (online at https://time.com/4552712/yemen-war
humanitarian-crisis-famine ); Trump To Resume Precision MunitionsDeliveries to Saudis: Officials Reuters (June13, 2017) (online at www.reuters.com/article/us-usa-saudi-arms-congress/trump-to-resume-precision-munitionsdeliveries- to- saudis- officials- idUSKBN1942GG) .

Human Rights Watch World Report 2017: Yemen
report/2017/country - chapters /yemen ) (accessed Dec. 6 , 2023).

Events of 2016 (online at www hrw.org/world(Aug. 17, 2018) (online at
One American's Failed Quest to ProtectCivilians in Yemen, The
www.theatlantic.com/international/archive/2018/08/yemen-saudi-airstrike-school-bus/567799/).
War CrimeRisk Growsfor U.S. Over SaudiStrikes in Yemen, NewYork Times ( Sept. 14, 2020) (onlineat www.nytimes.com/2020/09/14/us/politics/us-war-crimes-yemen-saudi-arabiahtml) .

296 Certification under Section 1290 of the John McCain National Defense Authorization Act for Fiscal
Year 2019 (DIV. A , Pub. L. 115-232) Related to Military Assistance for Saudi Arabia and the United Arab Emirates( Sept. 10, 2018) ( online at www.documentcloud.org/documents/4873723-Pompeo-Certification-Under-NDAA-for
Saudi- Arabia.html ) .
Yemen Civilians Keep Dying, but Pompeo Says Saudis Are Doing Enough, New York Times ( Sept. 12,2018) (online at www.nytimes.com/2018/09/12/world/middleeast/saudi-yemen-pompeo-certify.html
74).

InApril 2019 ,after the killing of Jamal Khashoggi discussed below ,then -President
Trump vetoed a bipartisan resolution demanding the end of U.S. military support for the Saudi
led war.

298

KillingofJamalKhashoggi

October2 , 2018, Saudi agents brutally executedand dismembered journalist, U.S.
resident, and regime- critic Jamal Khashoggi. The CIA quickly determinedthat Crown Prince
M.B.S.orderedthe
Inresponseto Mr. Khashoggi'smurder, then- PresidentTrump
cast doubt publicly on U.S. intelligenceassessmentsregardingthe murder, stating:

RepresentativesofSaudiArabia say that Jamal Khashoggiwas an enemy ofthe state
and a memberofthe MuslimBrotherhood, but my decision is inno way based on that
this is an unacceptableand horrible crime. King Salmanand CrownPrince Mohammad
bin Salman vigorously deny any knowledgeofthe planningor execution ofthe murderof
Mr. Khashoggi. Our intelligenceagencies continue to assess all information, but it could
verywellbe thatthe CrownPrince had knowledgeofthis tragic event maybehe didand maybe he didn't!
At the time, Republican Senator Bob Corker, Chairman of the Senate ForeignRelations
Committee, expressed disbeliefat the President'sdeflections stating, I never thought
see theday a White House would moonlight as a public relations firm for the Crown Princeof Saudi
Arabia and gave his own assessment of the intelligence surroundingMr. Khashoggi's
assassination: Ifthe crown prince went in front of a jury, he would be convicted in 30
minutes 301
According to the Washington Post, then- President Trump's support for M.B.S. helped
302
rehabilitate Mohammed on the world stage .
October 16, 2018 , then- Secretary of State

298 S.J. Res. 7, 116th Cong. (2019) ; Trump Vetoes Measureto Force End to U.S. Involvementin Yemen
War, New York Times (Apr. 6, 2019) (online at www.nytimes.com/2019/04/16/us/politics/trump-veto-yemen.html).
CIA Concludes Saudi Crown Prince OrderedJamal Khashoggi'sAssassination, Washington Post(Nov.
16, 2018) (online at www.washingtonpost.com/world/national-security/cia-concludes-saudi-crown-prince-ordered

jamal -khashoggis -assassination/2018/ 11/ 16/ 98c89fe6 -e9b2-11e8 - a939-9469f1166f9d_story html) ; UN Report Finds
Credible Evidence Linking Saudi Crown Prince to Jamal Khashoggi's Execution, Salon (June 19 , 2019 ) (onlineat www.salon.com/2019/06/19/un-report-finds-credible-evidence-linking-saudi-crown-prince-to-jamal-khashoggis
execution ) .

FullText: PresidentDonald Trump's Statement on SaudiArabia, Khashoggi Killing, Politico (Nov. 20,2018) (online at www.politico.com/story/2018/11/20/donald-trump-statement-saudi-arabia-khashoggi-killing
1008219) .
The Ugly Story ofTrump and Jamal Khashoggi is Confirmed, Washington Post (Feb. 27 , 2021) (onlineat www.washingtonpost.com/politics/2021/02/26/why-intel-report-jamal-khashoggi-is-so-damning-trump/) ; Trump
Signals US Won't PunishSaudi Crown Prince Over Khashoggi Killing, CNN (Dec. 10, 2018) (online atwww.cnn.com/2018/11/20/politics/trump-saudi-arabia/index html) .
302

Jamal Khashoggi's Death Made the Saudi Crown Prince a Pariah. Trump Has Helped Rehabilitate
Him on the World Stage., Washington Post (Sept. 28, 2019) (online at www.washingtonpost.com/national
security /jamal-khashoggis -death-made-the-saudi -crown- prince- a- pariah- trump -has- helped -rehabilitate -him-on-theworld- stage/ 2019/ 09/ 28/ 3365b8be- e13c- 11e9- b199- f638bf2c340f_storyhtml) .

75

Pompeo met with the King of Saudi Arabia and with M.B.S. in Riyadh.303 According to Mr.
Pompeo's memoir, he was the first Western official to see MBS since Khashoggi's murder.
President Trump reportedly expressed an awareness of the Crown Prince's indebtedness to him:
Pompeo's memoir notes that ahead of his meeting with the Crown Prince, President Trump told
him ,Mike, go and have a good time . Tell him he owes us.

EmolumentsPaidby SaudiArabia to Trump- OwnedBusinesses

In2001, Saudi Arabia purchased the entire 45th floor of Trump World Tower in New
York for a reported sale price of $4.5 million.306 Saudi Arabia owned this property for all four
years ofthe Trump Presidency
In 2018 the year covered by the records provided to theCommittee by Mazars the 45th floor units incurred a monthly base charge of $ 11,189.21,
yielding an annual total of $ 134,270 in such charges . Assuming that the monthly base charge
incurred by the 45th floor did not change over the course of the four years ofthe Trump
Administration , Saudi Arabia would have incurred charges totaling $ 537,080 . The Mazars
records for the year 2018 also show that in addition to the monthly base charges , the units
incurred a monthly special assessment of $2,476 for each of the ten months from January
through October 2018

totaling an additional $24,760.308 Because special assessments may

303

Pompeo Meets with King, Crown Prince in Saudi Arabia Amid Khashoggi Disappearance , NBC News
(Oct. 16, 2018) (online at www nbcnews.com/news/world/pompeo-lands-saudi-arabia-talks-king-salman-overkhashoggi - disappearance -n920556).

304 Washington Post Editorial Board, Mike Pompeo's Revolting Embrace ofMBS After the Khashoggi
Murder, Washington Post (Jan. 24, 2023 ) (online at www.washingtonpost.com/opinions/2023/01/24/mike-pompeo
book-mbs-jamal - khashoggi -murder/) .
305

Trump Signals US Won't Punish Saudi CrownPrince Over Khashoggi Killing, CNN (Dec. 10, 2018)(online at www.cnn.com/2018/11/20/politics/trump-saudi-arabia/index.html) ; After Helping Prince's Rise, Trump
and Kushner Benefit from Saudi Funds, Washington Post (Feb. 12, 2023) (online atwww.washingtonpost.com/politics/2023/02/12/after-helping-princes-rise-trump-kushner-benefit-saudi-funds/).

306 EXCLUSIVE: DonaldTrumpMade MillionsfromSaudiArabia, but Trashes Hillary Clintonfor Saudi
Donationsto Clinton Foundation, New York Daily News (Sept. 4, 2016) ( online atwww.nydailynews.com/news/politics/exclusive-donald-trump-made-millions-saudi-government-article-1.2777211).
307New York City Departmentof Finance, DocumentID: 2004072700986001(online at https://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2008090401549001) ( accessed Dec. 6, 2023) ;New York City Departmentof Finance, Notice of Property Value, Borough: Manhattan, Block: 1340, Lot: 1176
(Jan. 15, 2016) ( accessed Dec.6, 2023) ; New York City Departmentof Finance, Final Assessment Roll2017-2018,
Borough: Manhattan, Block: 1340, Lot: 1176 (Jan. 5, 2017) (accessed Dec. 6, 2023) ; New York City Departmentof
Finance, FinalAssessment Roll2018-2019, Borough: Manhattan, Block: 1340, Lot: 1176 (Jan. 5 , 2018) (accessed
Dec.6, 2023) ; New York City Departmentof Finance, Final AssessmentRoll2019-2020, Borough: Manhattan,
Block 1340, Lot: 1176 (Jan. 5, 2019) (accessed Dec. 6, 2023) New York City Departmentof Finance, Final
AssessmentRoll2020-2021, Borough: Manhattan, Block: 1340, Lot: 1176 (Jan. 5, 2020) ( accessed Dec.6, 2023) ;New York City Departmentof Finance, Final Assessment Roll 2021-2022, Borough: Manhattan, Block: 1340, Lot:
1176 (Jan. 5, 2021) ( accessed Dec. 6, 2023) .

-----

-----

-----

308 MAZARS OVERSIGHT COMMITTEE 00027371 ; MAZARS OVERSIGHT COMMITTEE

00027416 ;MAZARS OVERSIGHT_COMMITTEE 00027464 ; MAZARS OVERSIGHT_COMMITTEE
00027512 MAZARS OVERSIGHT_COMMITTEE 00027577 ; MAZARS OVERSIGHT_COMMITTEE
00027628 ;MAZARS OVERSIGHT_COMMITTEE 00027675 ; MAZARS OVERSIGHT_COMMITTEE
00027721;MAZARS OVERSIGHT_COMMITTEE 00027769 ;MAZARS OVERSIGHT_COMMITTEE
00027808 ;MAZARS OVERSIGHT_COMMITTEE 00027853 ; MAZARS OVERSIGHT_COMMITTEE76

vary from year to year, this report does not include them in the estimated total emoluments paid
by Saudi Arabia for the property in Trump World Tower.

Following the imposition of the blockade on Qatar

and just before M.B.S.'s second visit

to the White House to meet with President Trump on March 20 , 2018

the government of Saudi

Arabia booked rooms at the Trump International Hotel in Washington , D.C., from March 7 toMarch 15, 2018. The Saudi Ministry of Defense paid $ 78,342 to the Trump International Hotelfor this one-week stay, including one suite charged at $ 10,500 per night for two nights .
Although the records largely anonymize the identities of the Saudi delegation members whostayed at the hotel, two officials staying at the hotel are referred to as His Excellency
indicating that Saudi Royal family members or senior government ministers were patronizing the
Trump International
The bill included numerous charges for amenities, including a$2,000 charge for Coffee Table Flowers for all suites amenities 2 Gold and Dark Green
Macaroon Towers.

Two pages of the bill for the Royal Saudi Embassy Ministerial visit inMarch 2018 are excerpted below :31200027898.

Afterthe Committee beganreceivingdocumentsfrom Mazars showingemolumentspendingby foreign
nationsat Trump-owned propertieswhile Donald Trump was President, then-ChairwomanCarolynB. Maloneywroteto Debra SteidelWall, the Acting Archivist ofthe UnitedStates, on November 14, 2022, requesting.

presidentialrecords regarding foreign governments attemptsto influencethe Trump Administration The
Committee'sNovember2022 letter cited total spendingby Saudi Arabia of $85,961for that country'sMarch2018
stayat the Trump InternationalHotelin Washington, D.C. A closereview of the receipt providedby Mazarsfor thisstayshowsthat $9,619 in taxes were removedfromthe total due with the notation Missiontax Exempt. The
Trump InternationalHotel'sclassificationof this stay as tax exempt is a clear indicationthat an expenditureby aforeign governmentoccurredin violationofthe Constitution'sForeignEmolumentsClause. Other smallerdebits
andcredits were also added and subtractedfrom the bill, yieldinga total of$ 78,342, which equals the amountofthe
check recorded as paymenton the receipt. As such, this report identifiesthe total amount ofthe expendituremadeby the Saudi governmentfor this stay and thus the total emolumentspending as $78,342. See etter from
ChairwomanCarolynB.Maloney, Committee on Oversightand Reform, to Debra SteidelWall, Acting Archivistof
the UnitedStates, NationalArchives and RecordsAdministration(Nov. 14, 2022) (onlineat
https://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/2022-11
14.CBM% 20to% 20Steidel

20Wall- NARA % 20re

20Mazars

20Docs.pdf) .

310 MAZARS- OVERSIGHT_COMMITTEE- 00008122 to MAZARS- OVERSIGHT_COMMITTEE
00008140.

311 MAZARS- OVERSIGHT_COMMITTEE- 0008139.

312 MAZARS- OVERSIGHT_COMMITTEE- 0008122and MAZARS- OVERSIGHT_COMMITTEE
0008139 .

77

TRUMP

INTERNATIONAL

HOTEL

WASHINGTONVisitRoyalSaudiEmbassyMinisterial
100130th

Confirmation
Number:5504680

NW

RoomNumber:, DC20007
Washington

Room Type:of Guests:

ARRIVALMar 7

DEPARTURE

2018 12:00:00AM

Room
NumberRATE
PLAN

Mar 15, 2018 12:00:00 AM

43128

Confirmation
Number Name

Date CodeDESCRIPTION

Amount ( USD)COMMENTS

45646763-1

03/11/2018491250

CancellationFeeRooms

03/11/2018723207

DCOccupancySalesTax$ 495.00$ 73.26
SUBTOTAL:

809$ 568.26

92935543-1

03/11/2018101000$ 895.00

RoomCharge

03/11/2018723207
03/12/2018853201

DC OccupancySalesTax

03/12/2018851200

Room DiningF& B Tax%
10$ 10.44

03/12/2018851200

Room
DiningF & B Tax
10%( $ 10.44)

03/12/2018 850201
03/12/2018 850210

In Room Dining Lunch

03/12/2018852200

Room Dining Service

RoomDining Lunch$ 132.46
20180312
1116292034242380/ 0104/ 0104/ 2034/ 0000/Lunch

114.84$ 83.00

RoomDining
Miscellaneous$ 4.00$ 17.40

ChargeRoom
DiningF & B Tax

03/12/2018
851200$ 10.44

10%

Room Dining Lunch

03/12/2018 853201
03/12/2018 101450

Porterage

03/12/2018
03/12/2018 723234

Laundry/ Dry Cleaning
Tax

03/12/2018 OFFLAU
03/12/2018 101000

Offset Laundry( $ 5.35)

Room Charge$ 895.00

03/12/2018 723207
03/13/2018 853200

DC Occupancy Sales Tax
Room Dining Breakfast

20180312
1116292034242380/ 0104/0104/ 2034/ 0000/ Lunch(114.84)$ 12.00$ 93.00

3033

$5.35

$

20180313
0923252100$

2423800104/ 0104/2100/ 0000Breakfast
03/13/2018851200

Room Dining F & B Tax
10%

03/13/2018
851200Room
DiningF$ 8.28

B Tax

($

)

10
%

RoomDiningBreakfast

03/13/2018 850200
03/13/2018 850210$65.00

Room Dining
Miscellaneous$ 4.00

Room Dining Service

03/13/2018852200$ 13.80

ChargeRoom
DiningF & B Tax

03/13/2018851200$ 8.28%10
03/13/2018
853200Room
DiningBreakfast

20180313
0923252100( $ 91.08)

2423800104/0104/2100 0000/ Breakfast

03/13/2018

Laundry Dry Cleaning

03/13/2018723234

Sales Tax

$3.39

03/13/2018OFFLAU

Offset Laundry( $ 3.39)$59.003967

SUBTOTAL:
509

45993136-1

03/11/2018853502
03/11/2018850502

Benjamin Dinner

03/11/2018852500

Benjamin's Dinner
Benjamin Gratuities

03/11/2018853502

Benjamin Dinner

03/11/2018
101000

Room Charge

12/19/201819:59

2,424.84

Datt His ExcellencySaudi
20180311
2158111166242377/ 0085/ 0085/ 1166/ 0000/ Dinner$ 452.40$ 377.00$ 75.40
201803112158111166 242377/ 0085/ 0085/ 1166
/ 0000/ Dinner( $ 452.40)$ 10,500.00

1100 Pennsylvania Avenue
Washington, D.C 20004
202 695 1100
TrumpHotels.com

78

Phone

Page 1

Royal Saudi Embassy Ministerial Visit

5504680
03/12/2018 853300

Minibar20180312 110721 992$ 375.00

242370/ 0083/ 0083 / 992 / 0000/ NoMealPeriod

03/12/2018 852300

Minibar Gratuities$ 375.00

03/12/2018 852300

Minibar Gratuities($ 375.00)

03/12/2018 852300

Minibar Gratuities

03/12/2018 853300

Minibar03/15/2018 999100

Miscellaneous$ 375.00
20180312 110721992( $ 375.00)

242370/ 0083/ 0083/ 992/ 0000/ NoMealPeriod

Coffee Table Flowers for all suites

amenities

2 Gold and$ 2,000.00

Dark Green MacaroonTowers

03/20/2018 923900

Rooms Tax Exempt

06/13/2018 CHK

Check

06/13/2018 251599

Mission tax Exempt( $ 9,619.26 )4027-6677-50($ 78,342.00 )($ 375.00)

MinibarFood
TOTAL:( $ 85,961.26)

TOTALDUE:

Duringthe spring of 2018 , Saudi royalty also reportedly patronized other Trump
properties, in addition to the Trump International Hotel in Washington, D.C. In late March,while visiting the United States, the Crown Prince and his entourage traveled to New York City
where they reportedly stayed at the Trump International
The Washington Post reported
314
However, the Committeethat this boosted the hotel's revenue by 13% for the entire quarter.³
did not receive any records related to these stays from Mazars; therefore , they are not included
among the emolument figures presented in this report .
Lobbyist Spending

Inaddition to spending directly by the Saudi government , the Washington Post reported
that [ ] obbyists representing the Saudi government reserved blocks of rooms at President
Trump's Washington , D.C., hotel shortly after Trump's election in 2016

paying for an

estimated 500 nights at the luxury hotel in just three months.
For example , according tofilings with the DOJ pursuant to the Foreign Agents Registration Act (FARA) , for the six- month
period ending March 31, 2017, one lobbying firm spent $270,044 at the Trump International
Hotelfrom October 2016 through March 2017 on behalf of the Saudi government in order tobring veterans to Capitol Hill to lobby Congress against the Justice Against Sponsors ofTerrorism Act

a law permitting victims of the September 11, 2001, attacks to sue Saudi Arabia

for its role in facilitating theInmany cases , the lobbyists organizing the trips

reportedly did not tell the veterans that Saudi Arabia was paying for their travel and lodging.

At President Trump's Hotel in New York, Revenue Went Up This Spring Thanks to A Visit from Big
Spending Saudis , Washington Post (Aug. 3 , 2018 ) (online at www.washingtonpost.com/politics/at-president-trumps
hotel-in-new-york -revenue-went-up-this -spring -- thanks -to -a-visit -from -big-spending -saudis /2018/ 08/ 03 /58755392
313

9112-11e8-bcd5-9d911c784c38_story html). While Committee Democrats and Mazars had engaged in preliminary
discussions regarding documents related to Saudi Arabia in addition to the ones produced to the Committee ,Chairman Comer informed Mazars that he would no longer be enforcing the subpoena before searches related to thisstay could be completed .
314.

315 Saudi- FundedLobbyistPaidFor 500 RoomsatTrump'sHotelAfter2016 Election, WashingtonPost( Dec.5 , 2018) ( onlineat www.washingtonpost.com/politics/saudi-funded-lobbyist-paid-for-500-rooms-at-trumps
hotel- after- 2016 - election/ 2018 / 12/ 05/ 29603a64 - f417-11e8 -bc79-68604ed88993_story.html ) .

316

Department ofJustice, Supplemental Statement Pursuant to the ForeignAgents Registration Actof
1938, As Amended (May 31, 2017) (online at https://efile.fara.gov/docs/5483-Supplemental-Statement-20170531
25.pdf).
79

Veterans reported they were sent to lobby on the Hill even when the issue was largely dormant
and Washington was distracted by a new president's inauguration, raising suspicions amongst
veterans that the purpose of their trips was not to accomplish legislative goals but to funnelmoney from Saudi Arabia to the Trump International Hotel.317
The Mazars ledgers for the Trump International Hotel in Washington , D.C., provided to
the Committee for December 2016 show four advance deposit payments for Veteran Fly ingroups for January 2017 : one $9,000 payment labeled Veteran Fly In January 5 ; one $ 16,000
payment labeled Veteran Fly In January 10 ; one $ 11,000 payment labeled Veteran Fly
The Mazars
January 16 ; and one $ 16,000 payment labeled Veteran Fly In January 23.
ledgers do not identify who made these payments and do not identify any specific veterans who
ultimately stayed at the hotel . For this reason, this report does not include these payments among
the total emoluments paid by Saudi Arabia . However, the timing of and ledger descriptions forthe payments coincide with the Saudi lobbying activity reported in the FARA filing noted above .
Trump'sPost- PresidencyBusinessTies to SaudiArabia

PresidentTrump apparently had no branded businesses in Saudi Arabia while he was
President. Accordingto the WashingtonPost, prior to his election, he had seemedto be
exploringplans to build a hotelinJiddah but the shell companies created for such potential
businesswere dissolved in 2016.319
Since his term ended, however, former President Trump has expanded his business
relationships with Saudi Arabia significantly. He has aligned himself closely with LIV a golf
Publictour that Saudi Arabia's sovereign wealth fund bankrolled with at least $ 2 billion.

reporting indicates that the Saudi Arabia Public Investment Fund ( PIF) , a sovereign wealth fundheaded by the country's Crown Prince, Mohammed bin Salman (MBS) , owns 93 percent ofLIV
Former President Trump has
and pays 100 percent of the costs associated with its events .
repeatedly praised LIV; in October 2022 , he said :It's big time and it's big-time money. It's
The Washington

unlimited money. They love golf and the Saudis have done a fantastic job.

317Saudi-FundedLobbyistPaidFor 500RoomsatTrump'sHotelAfter 2016Election, WashingtonPost( Dec.5 , 2018) ( onlineat www.washingtonpost.com/politics/saudi-funded-lobbyist-paid-for-500-rooms-at-trumps
hotel- after- 2016 - election/ 2018 / 12/ 05 /29603a64 - f417-11e8 -bc79-68604ed88993_story.html ) .

318 MAZARS-OVERSIGHT_COMMITTEE-00010198; MAZARS-OVERSIGHT_COMMITTEE

00010199 MAZARS-OVERSIGHT COMMITTEE-00010200 .

LikeThem Very Much Trump Has Long- Standing Business TieswithSaudis, Who Have Boosted
His HotelsSinceHe TookOffice, WashingtonPost( Oct. 11, 2018) (online at www.washingtonpost.com/politics/i
like-them-very-much-trump-has- long-standing-business-ties-with- saudis-who-have-boosted-his-hotels-since-he
took- office/ 2018/ 10/ 11/ 0870df24- cd67-11e8- a360-85875bac0b1f_storyhtml) .

320 Over 18Holes, Trump PraisesLIV Golf, ItsSaudiBackers, and His Own Courses, WashingtonPost(May25, 2023) (onlineat www.washingtonpost.com/sports/2023/05/25/trump-liv-golf-washington/; WhatIs LIV
Golf ItDependsWhom You Ask., New York Times (May22, 2023) (onlineat www.nytimes.com/article/liv-golfsaudi-arabia-pgahtml).
Donald Trump's Saudi Arabia Payments Spark Calls for Fresh Investigation, Newsweek (Jan. 16, 2023)( online at www.newsweek.com/trump-liv-golf-saudi-payments-dawn-1773996).

Trump Criticizes PGA Tour, Says Saudis Have Done a Fantastic Job with LIV, CNBC (Oct.27, 2022)

322

80

Post reported that as of May 25, 2023 , Trump - owned golf courses had hosted two events lastyear and will host three this season
which is believed to be a lucrative arrangement for
Trump , though neither side has revealed details .

As noted above , on December 15 , 2023 ,former President Trump posted on social media that LIV would stage a tournament in 2024 at the
Trump National Doral golf course .

324

FormerPresident Trump has also boasted about the continued willingness of the Saudis
to do business on terms highly favorable to him. During a deposition in the lawsuit that the New
York State Attorney General brought against him for defrauding banks and insurers by inflating
his net worth by billions of dollars, Trump testified that he could sell one of his golfcourses to
the Saudis for a fortune and at a price far beyond what you would say it's worth by the money
He also testified that he could sell a mansion in suburban New York,it makes, far beyond.
which he described as the best house in the State of New York,to one buyer from Saudi

Arabia for $291 million, the figure at which Trump had valued it. In ruling that Mr. Trump andthe other defendants committed fraud, the judge handling the case observed that the latterstatement may suggest influence buying more than savvy investing.

Former President Trump's son-in-law and Senior Advisor Jared Kushner has also richly
monetized his business ties with Saudi Arabia after leaving government reportedly through thedirect assistance of M.B.S. As discussed, just one day after leaving government service , Mr.
Kushner formed a company that would become a private equity firm.
Within six months, Mr.
Kushner's firm had secured an investment reportedly worth $ 2 billion from the Saudi sovereign
wealth fund, the PIF.328 The panel charged with reviewing investment opportunities for the fundreportedly raised several concerns about the proposed deal, including the inexperience ofthe
Affinity Fund management, the prospect of Saudi Arabia bearing responsibility for the bulk of
the investment and risk, due diligence showing the firm's operations to be unsatisfactory in all
aspects , a proposed management fee that seem[ed] excessive , and public relations risks
stemming from Mr. Kushner's prior White House role. Despite these grave objections to thesoundness ofthe transaction , M.B.S. reportedly overruled the panel and approved the( online at www.cnbc.com/2022/10/27/trump-criticizes-pga-tour-praises-saudis-liv.html).

323 Over 18Holes, Trump Praises LIV Golf, Its SaudiBackers, and His Own Courses, Washington Post
(May 25, 2023) (online at www.washingtonpost.com/sports/2023/05/25/trump-liv-golf-washington/)
324 DonaldJ. Trump ( @RealDonaldTrump), Truth Social (Dec. 15, 2023) (online athttps://truthsocial.com/@realDonaldTrump/posts/ 111584588355405636) .
325

Transcript of Deposition of Donald J. Trump at 60–61, 177–80 ( Apr. 13, 2023 ) (online atwww.documentcloud.org/documents/23932452
452564_2022_people_of_the_state_of_v_people_of_the_state_of_exhibit_s_859
) .

326

People ofthe State ofNew York v. Donald J. Trump , et al., Index No. 452564/2022 at 21 and 21 n.10

(N.Y. Sup . Ct. Sept. 26, 2023 ) (online at www.documentcloud.org/documents/23991872-ny-ruling-on-trumpbusiness-fraud )327
After Helping Prince'sRise, Trump and KushnerBenefitfrom SaudiFunds, Washington Post (Feb. 11,2023) (onlineat www.washingtonpost.com/politics/2023/02/12/after-helping-princes-rise-trump-kushner-benefit
saudi-funds ).
328

BeforeGivingBillionsto JaredKushner, SaudiInvestmentFundHadBigDoubts, NewYork Times( Apr. 10, 2022) ( onlineat www nytimes.com/2022/04/10/us/jared-kushner-saudi-investment-fundhtml) .
81

investment.

329

RepresentativeJames Comer, Chairmanof the Committee on Oversight andDespiteAccountability, has acknowledged that this arrangement crossed the line of ethics.
this admission, however, Chairman Comerhas allowed Mr. Kushner to defy and ignore
Committee Democrats repeated document requests, and ChairmanComer has rejectedrequests
by the Committee's Democratic Members that he issue a subpoena to compel Mr. Kushner's
compliance331
Kushner's fund likewise reportedly received $ 200 million investments from the sovereign
wealth fund ofthe U.A.E. and a Qatari entity shortly after he left the Administration .

332

Because these payments post- dated Donald Trump's presidency , they may not be
emoluments within the meaning of the Constitution unless they were negotiated during thecourse of his presidency . In any event , however, their timing raises profound concerns thatformer President Trump and his family engaged in self- dealing during his Administration bymaking critical U.S. policy decisions regarding Saudi Arabia that were designed to further theirpersonal financial interests rather than the national security interests of the United States.

329.
ComerSaysKushner Crossedthe LineofEthics with SaudiDeal, The Hill( Aug. 11, 2023) ( onlineat

https://thehill.com/blogs/blog-briefing-room/news/4148951-comer-says-kushner-crossed-the-line-of-ethics-withsaudi - deal) .

331 Seee.g. Letter from Ranking Member Jamie Raskin, Committee on Oversight and Accountability , toJared Kushner, Founder and Chief Executive Officer, A Fin Management LLC (Feb. 15, 2023 ) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/2023-02
15.%20JBR %20to% 20Kushner %20re%20Saudi 20Arabia.fnl_.pdf) ; Letter from Ranking Member Jamie Raskin to
Chairman James Comer , Committee on Oversight and Accountability (Aug. 31, 2023 ) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/2023-08
31.JBR 20to% 20Comer 20re%20Kushner 20Subpoena.pdf ).
Kushner Firm Got Hundreds of Millions From 2 Persian Gulf Nations , New York Times (Mar. 30,2023) (online at www.nytimes.com/2023/03/30/us/politics/jared-kushner-qatar-united-arab-emirates.html
82).

The documents provided to the Committee by Mazars show that, in 2018, Qatar paid
more than $ 130,000 in emoluments for units in Trump World Tower in New York .
Prior toPresident Trump's election as President, Qatar already owned three units in Trump World Tower.
InJanuary 2018
monthsafter Saudi Arabia's blockade of Qatar had been underway for more than six

Qatar bought an additional unit in Trump World Tower

Later in 2018 , Qatar soldone ofthe units it already owned which had incurred lower monthly charges than the unit itpurchased earlier that year. As a result of these transactions , the monthly charges Qatar paid to
Trump World Tower increased from $8,592 before its 2018 purchase and subsequent sale tosettle at $ 9,540 in late 2018. Accounting for the country's 2018 purchase and sale, this report
estimates that Qatar paid $465,744 to the Trump World Tower for the properties it owned during
President Trump's term in office.

333 MAZARS-OVERSIGHT_COMMITTEE -00027357 to MAZARS-OVERSIGHT_COMMITTEE

00027885 .

334

Qatarboughtthe unitfromanentity called61-02 81st StreetLLC. The Committee'sDemocraticstaff
doesnotknowwho the beneficialownerofthis entityis. See NewYorkCity Departmentof Finance, DocumentID:
2018012900694001(Jan.17, 2018) ( onlinehttps://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2018012900694001

335) ( accessed Dec. 7, 2023 ) .

Trump Set to Benefit as Qatar Buys $ 6.5m Apartment in New York Tower , The Guardian ( May 4 ,2018) (online at www.theguardian.com/us-news/2018/may/04/trump-qatar-buys-apartment-new-york-tower ) ; NewYork City Department of Finance, Document ID: 2004030501059003 (online at https://a836
acris nyc.gov/DS/DocumentSearch/DocumentImage View ? doc_id = 2004030501059003 ) ( accessed Aug. 23, 2023 ) ;New York City Department of Finance , Document ID : 2012112901543003 ( online at https ://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2012112901543003) ( accessedAug.23, 2023) ;New York CityDepartmentof Finance, DocumentID: 2012120301328001( onlineat https://a836

acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2012120301328001) ( accessed Aug. 23 , 2023) ;New York City Departmentof Finance, Document ID: 2018100500569001( Oct. 3, 2018) (online https://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2018100500569001) ( accessed Dec. 7, 2023) ;New York City Departmentof Finance, Document ID: 2018012900694001( Jan. 17, 2018) (online https://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2018012900694001) ( accessed Dec. 7, 2023) ;New York City Departmentof Finance, Assessment Roll2016-2017, Borough: Manhattan, Block: 1340, Lot: 1214
(Jan. 5, 2016) (accessed Dec. 6, 2023) ; New York City Departmentof Finance, Assessment Roll2017-2018,
Borough: Manhattan, Block: 1340, Lot: 1214 (Jan. 5 , 2017) (accessed Dec. 6, 2023) ; New York City Department of
Finance, Assessment Roll 2018-2019, Borough: Manhattan, Block: 1340, Lot: 1214 (Jan. 5, 2018) ( accessed Dec.6 ,2023) New York City Department of Finance, Final Assessment Roll 2019-2020, Borough: Manhattan, Block:
1340, Lot: 1214 (Jan. 5, 2019) (accessed Dec. 6, 2023) ; New York City Departmentof Finance, Final Assessment
Roll2020-2021, Borough: Manhattan, Block: 1340, Lot: 1214 (Jan. 5, 2020) (accessed Dec. 6, 2023); New York
City Department of Finance, Final Assessment Roll 2021-2022, Borough: Manhattan, Block: 1340, Lot: 1214 (Jan.
5 , 2021) ( accessed Dec. 6, 2023) ; New York City Department of Finance, Assessment Roll 2018-2019, Borough:Manhattan, Block: 1340, Lot: 1217 (Jan. 5, 2018) ( accessed Dec. 6, 2023) ; New York City Department of Finance,
Final Assessment Roll 2019-2020, Borough: Manhattan, Block: 1340, Lot: 1217 (Jan. 5 , 2019) (accessed Dec. 6,2023) New York City Department of Finance, Final Assessment Roll 2020-2021, Borough: Manhattan, Block:
1340, Lot: 1217 (Jan. 5, 2020) ( accessed Dec. 6, 2023) ; New York City Department of Finance, Final Assessment
Roll2021-2022, Borough: Manhattan, Block: 1340, Lot: 1217 (Jan. 5, 2021) ( accessed Dec. 6 , 2023); New York
City Department of Finance, Assessment Roll2016-2017, Borough: Manhattan, Block: 1340, Lot: 1011 (Jan. 5,2016) (accessedDec. 6 , 2023) ; New York City Department of Finance, Assessment Roll2017-2018, Borough:Manhattan, Block: 1340, Lot: 1011 (Jan. 5, 2017) ( accessed Dec. 6 , 2023) ; New York City Department of Finance,
Assessment Roll2016-2017, Borough: Manhattan, Block: 1340, Lot: 1220 (Jan. 5, 2016) (accessed Dec. 6, 2023) ;New York City Departmentof Finance, Assessment Roll 2017-2018, Borough: Manhattan, Block: 1340, Lot: 1220
(Jan. 5 , 2017) (accessed Dec. 6, 2023) ; New York City Departmentof Finance, Assessment Roll 2018-2019,83

The documents provided by Mazars also record an extended stay at the Trump
International Hotel in Washington , D.C., from January through March 2018 that frequently
encompassed multiple rooms booked under the names of the Sheikh Al Thani family or
Khalid Al Thani. Al Thani is the name of Qatar's ruling family. 336 In November 2022, after
then- Committee Chairwoman Maloney sent a letter to the National Archives and Records
Administration (NARA) identifying the Al Thani family stay at the Trump International Hotel as
an expenditure by the government of Qatar , Qatar's Ambassador wrote to the Committee
asserting that this extended stay involved only private citizens .
However, numerous
questions regarding this stay remain unanswered. Notably, on a couple of days , the Al Thani stayat the Trump International Hotel in Washington , D.C., overlapped with a stay by Saudi
government officials at a time when each government sought to curry then-President Trump's
favor in their ongoing dispute. Given the assertions of the Qatari Ambassador, and despite
significant indications that the Al Thani family stay in fact involved members ofQatar's royalfamily, out ofan abundance of caution, this report does not include the stay at the Trump
International Hotel by the Al Thani family in the total sum ofthe emoluments paid by Qatar toformer President Trump through his businesses .
Qatar'sEmolumentSpendingat TrumpProperties

Date

January 2018

December 2018

Location

Expenditure

AmountTrump World Tower
845 United Nations

The Permanent$ 133,634338(2018)

Missionofthe State of

Plaza

Qatar to the United
Nations( NewYork, NY)

EstimatedTotal

Emolument for 4
Years:$ 465,744( 2017-2020)
ESTIMATED EMOLUMENTS PAID BY QATAR$ 465,744( 2017-2020)

Borough: Manhattan, Block: 1340, Lot: 1220 (Jan. 5, 2018) (accessed Dec. 6, 2023) ; New York City Departmentof
Finance, FinalAssessment Roll2019-2020, Borough: Manhattan, Block: 1340, Lot: 1220 (Jan. 5 , 2019) ( accessed
Dec.6, 2023) New York City Departmentof Finance, Final AssessmentRoll2020-2021, Borough: Manhattan,
Block: 1340, Lot: 1220 (Jan. 5, 2020) ( accessed Dec. 6, 2023); New York City Departmentof Finance, Final
AssessmentRoll2021-2022, Borough: Manhattan, Block: 1340, Lot: 1220 (Jan. 5, 2021) ( accessed Dec. 6, 2023) .

336 MAZARS-OVERSIGHT COMMITTEE-00028964to MAZARS-OVERSIGHT COMMITTEE
00029461 CongressionalResearchService,Qatar: Governance, Security, and U.S. Policy, (Apr. 11, 2022)( R44533) ( online at https://crsreports.congress.gov/product/pdf/R/R44533).
337Letter from Meshal Al-Thani, Ambassador of the State ofQatar, to Chairwoman Carolyn B. Maloney,
Committee on Oversight and Reform (Nov. 22 , 2022) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/Embassy%20of%20the%20State%2
20Qatar.221122.NARA

20Letter

20re

20Trump20OPO.pdf) .

338 MAZARS - OVERSIGHT_COMMITTEE - 00027357 to MAZARS- OVERSIGHT_COMMITTEE
00027885 .

84Accordingto the CongressionalResearchService( CRS) , in recentdecades, Qatar has
fostereda close securitypartnershipwith the United States. Qatar hoststhe U.S.military'sAl
UdeidAir Base, whichis the regionalheadquartersfor the U.S.CentralCommand, andthecommandpostfromwhichthe U.S. has overseenair operationsin Iraqand other locations.
The U.S.Air Forcesignificantlyincreasedits forces at the base as part ofthe responseto theterrorist attacks of September11, 2001, and the governmentof Qatar has reportedlyinvested
340
billionsof dollars to buildout the base's infrastructure.³

In May 2017, while he was in Riyadh, Saudi Arabia , for his first overseas trip, thenPresident Trump also met the Emir of Qatar, Tamim bin Hamad Al Thani, among other foreign
Before the meeting with Qatar's leader, President Trump said, One of the things that
we will discuss is the purchase of lots of beautiful military equipment because nobody makes itlike the United States
As previously discussed , in early June 2017 , Saudi Arabia and its allies imposed a
blockade on

Then- President Trump issued statements that favored the Saudi position in
A
few
weeks
later , the Saudi - led coalition demanded that Qatar meet 13
the dispute.344
conditions within ten days to have the blockade lifted.345

Accordingto the New York Times, after Qatar was besieged by a Middle East embargo
and PresidentTrump all but accused Qatar of fomenting terror,

the country began a

charm

339

CongressionalResearchService, Qatar: Governance, Security, and U.S.Policy, (Apr. 11, 2022)(R44533) (online at https://crsreports.congress.gov/product/pdf/R/R44533); Trump Team'sShiftsJoltSome Allies
andSootheOthers, New YorkTimes (June 9 , 2017) (onlineat www nytimes.com/2017/06/09/world/middleeast/rex
tillerson-calls-for-calm-in-middle-east-standoff-with-qatar html) .
Forrest L. Marion, Building USAF Expeditionary Bases for Operation ENDURING FREEDOM
AFGHANISTAN, 2001-2002, Air Force University Chronicles Online Journal, (Nov. 18 , 2005) (online atwww.airuniversity.af.edu/Portals/10/ASPJ/journals/Chronicles/marion.pdf ); US Forces Monitor Mideast Skies at
QatarBase Amid World Cup , Air Force Times/ The Associated Press (Dec. 2, 2022) (online atwww.airforcetimes.com/news/your-air-force/2022/12/02/us-forces-monitor-mideast-skies-at-qatar-base-amid-world).

341U.S.Departmentof State( @StateDept) , X ( formerlyTwitter) ( May21, 2017) ( onlineat
https://twitter.com/State
Dept/ status/ 866267018365812736).
342

Trump Trip: President Meets with Egypt, Qatar, Bahrain, Kuwait , NBC News (May 21, 2017) (onlineat www.nbcnews.com/storyline/trump-s-first-foreign-trip/trump-kicks-day-two-foreign-trip-talks-egypt-qatar
bahrain- n762641) .

SaudiArabia, Egypt and OtherArabNationsCutDiplomaticTies withQatar, NPR (June 5 , 2017)( onlineat www.npr.org/sections/thetwo-way/2017/06/05/531548717/saudi-arabia-egypt-and-other-arab-nations-cut
diplomatic-ties-with-qatar).
Donald J. Trump (@realDonaldTrump), X (formerly Twitter) (June 6, 2017) (online athttps://twitter.com/realDonald Trump/status/872062159789985792 ?s 20); Tweets ofJune 6, 2017, The American
Presidency Project, University of California, Santa Barbara (online at www.presidency.ucsb.edu/documents/tweets
june-6-2017) Trump Appears to Take Creditfor GulfNations Move Against Qatar, CNN (June 6, 2017) (online atwww.cnn.com/2017/06/06/politics/trump-qatar-ideology/index.html ).
345

Qatar Given 10 Days to Meet 13 Sweeping Demands by Saudi Arabia , The Guardian (June 23, 2017)(online at www.theguardian.com/world/2017/jun/23/close-al-jazeera-saudi-arabia-issues-qatar-with-13-demands-to
end - blockade ).

85

offensivewiththe Trump administration.

This charm offensive occurredas Qatar was

payingthe commonchargesand relatedexpenses on its Trump World Tower units.

Inmid- July 2017 , shortly after Saudi Arabia's blockade of Qatar began , then- Secretary ofState Tillerson traveled to Qatar . On July 11, 2017 , Secretary Tillerson and the Qatari Foreign
Minister, Mohammed Al Thani ,signed a memorandum of understanding on fighting terrorism .

Secretary Tillerson stated , I think Qatar has been quite clear in its positions and I think very
reasonable and we want to talk now (about) how do we take things forward . Secretary Tillerson
added , Together , the US and Qatar will do more to track down funding sources , collaborate andshare information and do more to keep the region and our homeland safe .

In addition to signing the agreement on the fight against terrorism , Qatar took other steps
intended to improve its relations with the United States , including agreeing to disclose morefinancial information on its national airline and announcing that it would upgrade living
quarters for United States military personnel stationed at al- Udeid Air Base." It also hired
numerous lobbyists to represent its interests before the U.S. government .

348

Inthe fall of2017 , then -President Trump publicly expressed support for the actions Qatar
had taken against terrorism . According to Saudi Arabia and the U.A.E., Qatar's support for
terrorism had been a central concern prompting the blockade . On September 20 , 2017 , thenPresident Trump met with the Emir of Qatar , Sheikh Al Thani , on the sidelines ofthe United
Nations (U.N.) General Assembly
According to the White House release regarding thismeeting :The President stressed the importance of resolving Qatar's ongoing dispute with its
neighbors , restoring unity in the region with partners of the United States , enabling thosecountries to promote regional stability and counter the threat of Iran together . President
Trump acknowledged the progress displayed by Qatar through the implementation of theUnited States - Qatar bilateral memorandum of understanding on counterterrorism
cooperation , and stressed the importance of taking additional steps to ensure that thecommitments made at the Riyadh Summit in Saudi Arabia to cut off funding forterrorists , discredit extremist ideology, and defeat terrorist groups come to fruition .350

346 In Charm Offensive, Qatar Pushes for a Comeback in Washington, New York Times (Feb. 9 , 2018)( online at www.nytimes.com/2018/02/09/us/politics/trump-qatar-lobbying-embargo.html).

347 US and Qatar Broker Counterterrorism Agreement , CNN (July 11, 2017) (online atwww.cnn.com/2017/07/11/politics/tillerson-qatar-terrorism-memorandum-of-understanding/index.html
348).

InCharm Offensive, Qatar Pushesfor a Comeback in Washington, New York Times (Feb. 9 , 2018).

(online at www.nytimes.com/2018/02/09/us/politics/trump-qatar-lobbying-embargo.html)

SaudiArabia, Egypt and Other Arab Nations Cut Diplomatic Ties with Qatar, NPR (June 5, 2017)(onlineat www.npr.org/sections/thetwo-way/2017/06/05/531548717/saudi-arabia-egypt-and-other-arab-nations-cut
diplomatic-ties-with-qatar ) ; The White House, Press Release: President Trump Meets with Emir Tamim binHamad

AlThaniofQatar (Sept. 20, 2017) (online at https://trumpwhitehouse.archives.gov/articles/president-trump-meets
emir-tamim-bin-hamad-al -thani-qatar ).
The White House: Press Release: President Trump Meets with Emir Tamim bin Hamad Al Thani of
Qatar (Sept. 20, 2017) (online at https://trumpwhitehouse.archives.gov/articles/president-trump-meets-emir-tamim
bin-hamad-al-thani-qatar ).
86

On April 10, 2018

three months after the Qataris purchased an additional unit in Trump

World Tower increasing their total monthly charges and fees due, and after the extended stay by
the Al Thani family at the Trump International Hotel in Washington , D.C. then-President
Trump met the Emir of Qatar at the White House. President Trump again praised Qatar's recordon combatting terrorism and referred to the Emir as a great gentleman . He continued We
have a gentleman on my right who buys a lot of equipment from us, a lot of purchases inthe
United States , and a lot of military airplanes missiles

lots of different things , but they've been

great friends in so many different ways .
Two weeks later, then- Secretary of StatePompeotraveledto SaudiArabia wherehereportedlyurged his Saudi counterpartto terminatethe blockadeofQatar.352 However, as
discussed, the blockaderemainedin effect untilJanuary 5 , 2021, when SaudiArabia, the UAE,
Bahrain, and Egypt agreedto liftthe blockadeand restore ties.
Emoluments Paid by Qatar to Trump- Owned Businesses

Qatar and its ruling family spent heavily at Trump - owned properties during the Trump
presidency When Donald Trump was inaugurated , the Qatari Permanent Mission to the United
Nations owned three units in Trump World Tower at 845 United Nations Plaza. The mission
purchased one unit in 2004 and the remaining two units in 2012.354 On January 17 , 2018 after
President Trump had met with the Emir ofQatar at the U.N. General Assembly in September
2017 and before he met the Emir again at the White House in April 2018 the Qatari Missionbought a fourth unit at Trump World Tower for $ 6.5 million.

Then , as noted, in October 2018 ,Qatar sold a unit in Trump World Tower that incurred a lower monthly base charge than the unit
ithad purchased in January 2018 leaving Qatar with three units that each incurred a monthly
base charge of $ 3,180 in 2018.³356

PresidentTrump Meeting with Emir of Qatar, C-SPAN (Apr. 10, 2018) (online at www.cspan.org/video/?443832-1/president-trump-meets-emir-qatar).
352

Pompeo'sMessageto Saudis? Enoughis Enough: Stop QatarBlockade, New York Times (Apr.28,
2018) (onlineat www.nytimes.com/2018/04/28/world/middleeast/mike-pompeo-saudi-arabia-qatar-blockadehtml).
CongressionalResearch Service, Qatar: Governance, Security, and U.S.Policy, ( Apr. 11, 2022)(R44533) (online at https://crsreports.congress.gov/product/pdf/R/R44533).
354

New York City Department of Finance, Document ID: 2004030501059003 (online at https ://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2004030501059003 ) (accessed Aug. 23, 2023) ;New York City Department of Finance, Document ID: 2018100500569001 (online at https ://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2018100500569001) ( accessed Aug. 23, 2023 ) ;New York City Department of Finance, Document ID : 2012112901543003 ( online at https:// a836
acris nyc.gov/DS/DocumentSearch/DocumentImage View? doc_id 2012112901543003 ) (accessed Aug. 23, 2023 ) ;New York City Department of Finance, Document ID : 2012112901543003 ( online at https://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2012112901543003) ( accessedAug.23, 2023) ;NewYork City Departmentof Finance, DocumentID: 2012120301328001( onlineat https://a836) ( accessed Aug. 23, 2023) .
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2012120301328001
355 TrumpSet to Benefit as Qatar Buys $6.5mApartmentin New York Tower, The Guardian( May4 , 2018)( onlineat www.theguardian.com/us-news/2018/may/04/trump-qatar-buys-apartment-new-york-tower).

New York City Department of Finance, Document ID: 2018100500569001(online at https ://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2018100500569001) (accessed Aug. 23, 2023 ).
356

87

Recordsprovidedto the Committee by Mazars show that, in January 2018, prior to
Qatar's purchase ofthe fourth unit, Qatar had paid $ 8,592 inbase charges for the three properties
it owned. From February2018 throughthe sale in October 2018, Qatar paid $ 11,773 monthly inbase charges for its four units in Trump World Tower. FollowingQatar's sale of its unit in
October2018, the country paid $ 9,540 permonthinbase charges to Trump World Tower for theremainderof2018.

In2018 the only yearfor whichMazars providedrecords for Trump World
Qatar incurredmonthly base charges totaling $ 133,634.357 Assumingthat these chargesdid notchange duringthe four years ofthe Trump presidency, the Qatari-ownedproperties would haveaccrued a totalof$465,744 in base charges after accountingfor Qatar's propertypurchaseandsale. Ofnote, the properties also incurredadditionalcharges abovethe monthlybase charges—
includingutilities, special assessments, and maintenancefees in2018 totaling $20,767.358
While a Qatari representative stated regarding the January 2018 purchase that , [ t ] heseapartments , plus the recent unit, were all purchased due to their location, nothing more thetiming of the purchase in relation to Qatari policy objectives , and the sale of a previously
purchased apartment that had been less costly for the Qatari government , raise numerous
questions regarding the true motivations behind these actions .

One week after purchasing the new Trump World Tower unit, on January 24, 2018, an
unknown individual(s) identified by the name Al Thani —the name of the Qatari royalfamily booked multiple rooms at Trump International Hotel in Washington , D.C., throughMarch 9, 2018. The Al Thani family reportedly dominates Qatari government ministries andreceives a significant share of state revenue. 360 Itis unclear from the Mazars records who stayed
inthe hotelin the rooms booked under the Al Thani name during this period. Though the rooms
were booked at times under the name “ Al -Thani, Khalid, several prominent members ofthefamily appear to have this name. All charges for Al-Thani, Khalid appear to have ultimately
been refunded, and then, subsequently, amounts equal to those refunded were later charged to an
account labeled Sheikh Al Thani Family Extended Stay." The charges incurred by the Al Thanifamily total more than $283,000.361 A page from the records provided to the Committee by
Mazars showing charges associated with this Sheikh Al Thani Family Extended Stay appears
below.362

357 MAZARS-OVERSIGHT_COMMITTEE - 00027357 to MAZARS -OVERSIGHT_COMMITTEE
00027885.
note , in some instances , the Trump World Tower Condominium Status Report refers to Quatar.
358
359

.
Trump Set to Benefit as Qatar Buys $ 6.5m Apartment inNew York Tower, The Guardian (May 4 , 2018)( online at www.theguardian.com/us-news/2018/may/04/trump-qatar-buys-apartment-new-york-tower).

HarvardDivinitySchool, Al- ThaniFamily( online at https://rpl.hdsharvard.edu/faq/al-thani-family)( accessedNov. 1, 2023) .
361 MAZARS- OVERSIGHT_COMMITTEE- 00028964 to MAZARS- OVERSIGHT_COMMITTEE
00029461.

362 MAZARS- OVERSIGHT_COMMITTEE- 00029021.
88

GuestLedger Charges
Guest
Name

Room

Status

Account

RoomType

Folio

Transaction Type CreatedBy

Time

Transaction CodeAmount101000 RoomCharge
Date: 02/01/2018
62865780-1

GUEST

SheikhActive

ROOM

GUEST

101000ThaniFamily Extended Stay

5089279

SheikhThani Family Extended Stay

101000

ActiveROOM5089279

GUEST

101000

Sheikh ThaniFamilyExtended
Stay
5089279

Active

ROOM

GUEST

101000

Sheikh Thani
FamilyExtendedStay

ActiveROOM5089279

GUEST

101000

Sheikh ThaniFamilyExtended
Stay

ActiveROOM5089279

GUEST

101000

Sheikh Thani
FamilyExtendedStay

ActiveROOM5089279

GUEST

101000

Sheikh ThaniFamilyExtendedStay
5089279

Active

ROOM

GUEST

101000

Sheikh ThaniFamilyExtended
Stay

ActiveROOM5089279

GUEST

101000

SheikhThani Family Extended Stay
5089279

Active

ROOM

GUEST

101000

SheikhThani Family Extended Stay
5089279

Active

ROOM

GUEST

101000

SheikhActiveROOM5089279

GUEST

101000

Sheikh ThaniFamilyExtendedStay

ActiveROOM5089279

GUEST

101000

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000

ActiveROOM5089279

GUEST

101000

SheikhThaniFamily Extended Stay
5089279

Active

ROOM

GUEST

101000

SheikhThaniFamilyExtendedStay

Thani Family Extended Stay

5089279

SheikhThani Family Extended Stay

5089279
SheikhThani Family Extended Stay

ActiveROOM5089279

GUEST

101000

Sheikh Thani
FamilyExtendedStay

ActiveROOM5089279

GUEST

101000

SheikhSheikhThani
FamilyExtendedStay

ActiveROOM5089279

GUEST

101000

SheikhActiveROOM5089279

GUEST

101000

Sheikh Thani
FamilyExtendedStay

ActiveROOM5089279

GUEST

101000ThaniFamilyExtendedStay

ThaniFamily Extended Stay

10/29/2018
20:34

15:23

15:23

280.00

15:23

280.00

15:23

280.00

15:23

280.00

15:23

280.00

15:23

280.00

15:23

280.00

15:25

280.00

15:25

280.00280.00

15:25

280.00

15:25

280.00

15:25

280.00

15:25

280.00

15:25

280.0015:27

3,500.00

15:27

3,500.00

15:27

3,500.00

15:27

3,500.00

3,500.00

1100 Pennsylvania
AvenueNW Washington,
20004
TrumpHotels.com

Phone
202
6951100

Page 7

As noted, in a letter dated November 14, 2022 , then- Committee Chairwoman Maloneywrote to NARA to request presidential records [ ] to determine whether former President
Trump distorted U.S. foreign policy to serve his own financial interests at the expense ofthe
In that letter, then -Chairwoman
American people and in violation of his oath of office ."Maloney explained that the records provided to the Committee from Mazars showed that theSheikhThani Family had booked an extended stay at the Trump International Hotel inWashington , D.C.; she identified the expenditures associated with this stay as expenditures by
the Qatari government .

In a letter datedNovember22, 2022, the Ambassadorofthe State of Qatar, MeshalAl
Thani, respondedto then-ChairwomanMaloney: I have investigatedthis matterand confirmed
thatno representativeofthe Embassyof Qatar, and no other governmentofficial ofthe State of
Qatar, was a guest at the Trump InternationalHotelduringthe time periods describedinyour
letter The Ambassador added, With respectto the guest ledger excerptedinyour letter whichrefers tothe SheikhAl Thani Family ExtendedStay, I can further confirm that these guests are
Letter from Chairwoman Carolyn B. Maloney, Committee on Oversight and Reform, to Ms. Debra
Steidel Wall, Acting Archivist ofthe United States, National Archives and Records Administration (Nov. 14, 2022)(online at https://oversightdemocrats house.gov/sites/democrats.oversight.house.gov/files/2022-11
14.CBM% 20to% 20Steidel 20Wall- NARA 20re% 20Mazars 20Docs.pdf
).

364

.
89

privatecitizens who were not engaged in any government business. The Ambassador did not
identify the private citizens who booked the stays identified in the ledgers provided by Mazars to
the Committee, nor did he provide the basis for his statement that private citizens were
responsible forthese stays . He also did not explain whether these individuals were members of
the Qatari royal family.365

Regardlessofwhether the stay labeledas the SheikhAl Thani FamilyExtendedStay
involvedonlyprivatecitizens, it wouldbe reasonableto infer thatthe bookingofa prolonged
hotelstay whichultimately yieldedhundredsofthousands of dollars in payments to a Trump
ownedbusiness usingthe nameofthe Qatari royalfamily was intendedto signal to The Trump
Organizationand to then-PresidentTrump the country'sfinancialsupportofthe President's
businessat a time when Qatar was seekingthen-PresidentTrump's support ina conflictthat
constituteda crisis to Qatar. This is one moreexpenditurehighlightinghow then-President
Trump's continued ownershipofprivatebusinessescreated a magnetfor foreigncountries
seekingto influencethe foreignpolicy of the UnitedStatesthroughpayments to the President
and his businesses. This is preciselythe kind ofself-dealingthat the U.S. Constitutionseeks toprevent by prohibitinga Presidentfrom receivingemoluments ofany kindwhatever fromforeigngovernments absent congressionalconsent. However, despite numerous indicationsthat
this expensive stay involvedmembers ofQatar's royal family, giventhe Ambassador's
representationsto the Committee, this report does not include the expendituresat the Trump
InternationalHotelby the SheikhAl Thani Family amongthe total emolumentspaid by Qatar to
Trump-owned businesses.

It is notable that on a couple of days , the Sheikh al Thani family's stay at the Trump
International Hotel in Washington , D.C., overlapped with a stay by officials from the Royal
Saudi Embassy Misnitry [ sic] of Defence ." Ifthe stay by the Sheikh Al Thani family at the
Trump International Hotel involved any government officials or members of the royal family
then the Trump International Hotel would have been simultaneously receiving emoluments fromboth Qatar and Saudi Arabia two countries that were in conflict and that were both seeking tocurry then -President Trump's support . Further, both stays occurred shortly before leaders fromeach of Qatar and Saudi Arabia met separately with then -President Trump at the White House.
Below is a single page from the Trump International Hotel Guest Ledger for March 9, 2018 ,showing rooms booked to both the Sheikh Al Thani Family Extended Stay and the Royal
Saudi Embassy Misnitry [ sic] of Defence Delegation on the same day.366

365 Letter from Meshal Al-Thani , Ambassador of the State of Qatar, to Chairwoman Carolyn B. Maloney ,Committee on Oversight and Reform (Nov. 22 , 2022) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/Embassy%20of%20the%20State%2
20Qatar.221122.NARA 20Letter 20re% 20Trump 20OPO.pdf).
366 MAZARS- OVERSIGHT_COMMITTEE
00029268.
90

Guest Ledger Charges
GuestName

Room

Account

RoomType

StatusTransactionType Created By
TransactionCode

Time

Amount101000

Room Charge
Date: 03/09/2018843- house
GUEST

ROOM

DATABRIDGEINTERNALUSER 03:17

101000846

In house

ROOM

847

- houseROOMDATABRIDGEINTERNALUSER

03:19

DATABRIDGEINTERNALUSER

03:18

DATABRIDGEINTERNALUSER

03:17

DATABRIDGEINTERNALUSER

03:17

DATABRIDGEINTERNALUSER

03:17

101000

SheikhThani Family Extended Stay
5089279
SheikhThani Family Extended Stay

GUEST

101000

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000

ActiveROOM

FOLIO4

101000

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000

ActiveROOM

FOLIO4

101000

Active

ROOM

GUEST

101000

ActiveROOM5089279

GUEST

101000

Sheikh ThaniFamilyExtended
Stay

ActiveROOM5089279

GUEST

101000

SheikhActiveROOM5089279

GUEST

101000

SheikhThani Family Extended Stay
5089279

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000

Active

ROOM

GUEST

101000Thani Family Extended Stay

RoyalSaudiEmbassy Misnitryof Defence
Delegation

DATABRIDGEINTERNALUSER 03:17

DATABRIDGEINTERNALUSER 03:18

DATABRIDGEINTERNALUSER 03:18

DATABRIDGEINTERNALUSER

03:18

DATABRIDGEINTERNALUSER

03:17

3,500.00

DATABRIDGEINTERNALUSER 03:17

1,500.00

DATABRIDGEINTERNALUSER 03:17

280.00DATABRIDGEINTERNALUSER 03:17

280.00DATABRIDGEINTERNALUSER

03:19

490.00DATABRIDGEINTERNALUSER

03:18

DATABRIDGEINTERNALUSER

03:18

DATABRIDGEINTERNALUSER

03:18

DATABRIDGEINTERNALUSER

03:19

DATABRIDGEINTERNALUSER

03:19

895.00DATABRIDGEINTERNALUSER

03:19

495.005504680

RoyalSaudiEmbassy Misnitryof Defence
Delegation

PotentialConflictsRelatingto Jared Kushnerand the KushnerCompanies

Februaryand February 12, 2018, during the extendedstay at the Trump

InternationalHotelin Washington, D.C., undertheAl Thani family name, a roomatthe hotel
was bookedunderthe name Ivanka& JaredKushner.
Shortlythereafter, on February14,
2018, Jared Kushner'sfather, Charles Kushner, contactedBrookfieldAsset Management a
companyinwhichQatar has investedsignificantfunds

seekinga bailout for his financiallytroubledpropertyat 666 FifthAvenue inNew York. Two monthslater, PresidentTrumpmet
withthe Emirof Qatar at the White House. The KushnerCompaniesand Brookfieldfinalizeda
dealinAugust2018 in which BrookfieldAsset Managementleased666 FifthAvenueand paid
99 years
rent totalingapproximately$ 1.1 billion inadvance.368
367

MAZARS- OVERSIGHT_COMMITTEE - 00029068 ; MAZARS - OVERSIGHT_COMMITTEE

00029080 .

368 Deal Gives Kushners CashInfusion on 666 FifthAvenue, New York Times (Aug. 3 , 2018) (online atwww.nytimes.com/2018/08/03/nyregion/kushners-building-fifth-avenue-brookfield-leasehtml) ; Letter from
ChairmanRon Wyden, Senate Committee on Finance, and Chairwoman Carolyn B. Maloney, House Committee onOversightand Reform, to Secretary LloydJ. Austin, III, Departmentof Defense (Dec. 6 , 2022) ( online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/2022-12
06.CBM

20Wyden % 20to% 20Austin- DOD% 20re % 20Kushner % 20Conflict

91

20of

20Interest

20% 281% 29.pdf) .

Just as he did with Saudi Arabia, former SeniorAdvisor Jared Kushner cultivatedhighly
lucrativebusiness ties with Qatar after President Trump left office. After leavingthe WhiteHousein2021, Mr. Kushner embarked on a tour of Persian Gulfstates, includingQatar and the
U.A.E., to pitchthose countries sovereign wealth funds on investinginhis private equity fund.
Initially, Qatari officials reportedlydeclined to invest based on its view of Mr. Kushner as an
opponent during the Trump Administration, but they also feared retaliation ifthey rejectedMr.
369
Kushner'ssolicitation to invest inthe event that Mr. Trump returned to power.
Accordingto
reports, a Qatari sovereignwealth fund ultimately agreed to invest $200 millionin Mr. Kushner's
fund 370

369

SeekingBackersfor NewFund, JaredKushnerTurns to MiddleEast, NewYork Times ( Nov.26, 2021)( onlineatwww.nytimes.com/2021/11/26/us/politics/kushner-investment-middle-easthtml) .

370 KushnerFirm Got Hundreds ofMillionsfrom 2 Persian GulfNations, New York Times (Mar. 30, 2023)(online at www.nytimes.com/2023/03/30/us/politics/jared-kushner-qatar-united-arab-emirates.html) ; Letter from
Chairwoman CarolynB. Maloney, Committee on Oversight and Reform, to Secretary Lloyd J. Austin III,Departmentof Defense (Dec. 6 , 2022) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversight

06.CBM

house.gov/files/2022-12

20Wyden%20to% 20Austin- DOD% 20re% 20Kushner

20Conflict

20of 20Interest

20% 281% 29.pdf) ;Letter from Ranking Member Jamie Raskin, Committee on Oversight and Accountability , to Jared Kushner,
Founder and Chief Executive Officer, A Fin Management LLC (Feb. 15 , 2023) ( online athttps://oversightdemocrats.house.gov/sites/democrats.oversight house.gov/files/2023-02

15.%20JBR 20to% 20Kushner%20re%20Saudi 20Arabia.fnl_.pdf) ; Letter from RankingMemberJamie Raskinto
ChairmanJames Comer, Committeeon Oversight and Accountability(Aug. 31, 2023) (online athttps://oversightdemocrats.house.gov/sites/democrats.oversighthouse.gov/files/2023-08
31.JBR%20to%20Comer 20re%20Kushner%20Subpoena.pdf) .
92

UNITEDARABEMIRATES

Accordingto the records providedto the Committee by Mazars, on four occasions
betweenOctober 2017 and May 2018, the government of the UnitedArab Emirates ( U.A.E.)
booked rooms at the Trump InternationalHotelin Washington, D.C., at a cost of $ 65,225.371

The first U.A.E. stay occurred in October 2017, just days after Mr. Elliott Broidy, aformer Trump fundraiser who would later plead guilty to violating the Foreign Agents
Registration Act (FARA), reportedly had personally appealed to then-President Trump on
October 6, 2017, on behalf of the U.A.E.372 In addition to other issues of concern to the country,
Broidy reportedly urged President Trump to fire then-Secretary of State Tillerson, who hadpressed Saudi Arabia and the U.A.E. to ease their blockade of Qatar

Mr. Broidy himself had

stayed at the Trump International Hotel in Washington , D.C., from October 1, 2017, throughOctober 6, 2017 one of his many stays at the hotel.374 President Trump pardoned Mr. Broidy
shortly before leaving office.375
AdditionalU.A.E.stays occurredin November2017, March2018, and May2018. The
U.A.E.delegation'sstay at the Trump InternationalHotelin March2018 overlappedwith a stayby a delegationfrom SaudiArabia, a closeally ofthe U.A.E. Delegationsofbothcountrieswere
stayingat the hotelon March13, 2018, the day on which then- PresidentTrump madepublichis
376

decisionto fire SecretaryofState Tillerson.³

----

-

----

---

371 MAZARS OVERSIGHT COMMITTEE 00018630 ;MAZARS OVERSIGHT_COMMITTEE

00018642 ;MAZARS OVERSIGHT COMMITTEE 00018649 ; MAZARS OVERSIGHT COMMITTEE
00018805 MAZARS OVERSIGHT COMMITTEE 00018806 ; MAZARS OVERSIGHT COMMITTEE
00014770 ;MAZARS OVERSIGHT_COMMITTEE 00008096 to MAZARS OVERSIGHT_COMMITTEE
00008119 MAZARS OVERSIGHT_COMMITTEE 00008120.

372 How 2 GulfMonarchies Sought to Influence the White House, New York Times (Mar. 21, 2018 ) ( onlineat www.nytimes.com/2018/03/21/us/politics/george-nader-elliott-broidy-uae-saudi-arabia-white-house
influence.html ) .

373 Saudi Arabia Planned to Invade Qatar Last Summer . Rex Tillerson's Efforts to Stop It May Have Cost
Him His Job, The Intercept (Aug. 1, 2018 ) (online at https://theintercept.com/2018/08/01/rex-tillerson-qatar-saudi) Trump Seems to Undercut Tillerson's Remarks on Qatar, Washington Post (June 9, 2017 ) ( online atwww.washingtonpost.com/world/arab-countries-place-dozens-on-new-qatar-terror-list-deepening
dispute/ 2017/ 06/ 09/ fd727fab- e750-4fdd - ac23-26256e8e0493_story html) .

-

,

,

374 Emails Show UAE Linked Effort Against Tillerson BBC News (Mar. 5 2018) (online atwww.bbc.com/news/world-us-canada-43281519 ); MAZARS OVERSIGHT_COMMITTEE 00018457 ;MAZARSOVERSIGHT_COMMITTEE 00018466 ;MAZARS OVERSIGHT_COMMITTEE 00018478 ; MAZARSOVERSIGHT_COMMITTEE 00018487;MAZARS OVERSIGHT_COMMITTEE 00018494 ; MAZARSOVERSIGHT_COMMITTEE 00018501

.

-

-

-

-

375 With Hours Left in Office, Trump Grants Clemency to Bannon and Other Allies , New York Times (May5 2021) ( online at www.nytimes.com/2021/01/20/us/politics/trump-pardonshtml) .

376 Donald J. Trump (@realDonald Trump ) , X (formerly Twitter ) (Mar. 13 , 2018) (online athttps://twitter.com/realDonald Trump / status/ 973540316656623616 ).
93

U.A.E.'sEmolumentSpendingat TrumpProperties

Date

Location

Expenditures

AmountOctober 21-23, 2017

Trump International Hotel$ 2,625377(Washington, D.C.)

Embassy, United ArabEmirates hotel stay

Trump International Hotel

E -UnitedArab$ 33,512³(Washington, D.C.)

Emirates hotelstay ( 37

November10, 2017378

rooms)March8-16, 2018

Trump InternationalHotel( Washington, D.C.)

May 1-3, 2018

Trump InternationalHotel(Washington, D.C.)

Embassy of the UAE
Military Delegation
hotelstay
Embassy ofthe UAE
Military Delegation
May hotel stay

EMOLUMENTSPAID BY U.A.E.

379$ 26,1683

380$ 2,920$ 65,225( 2017-2018 )The U.A.E. is a federation of seven principalities or emirates ,including Abu Dhabi( the capital) and Dubai ( a commercial center ) . Sheikh Mohamed bin Zayed Al Nahyan( commonly known as M.B.Z.) , the Crown Prince of Abu Dhabi, has effectively been ruling theEmirates since 2014.

U.A.E.and Saudi Arabia have maintained closely aligned foreign policies. The twocountries have cooperated on various regional endeavors, such as the blockade ofQatar (20172021), the ongoing war in Yemen (2015 present), and support to counter MuslimBrotherhood
and Islamist- affiliatedmovements

377 MAZARS-OVERSIGHT -COMMITTEE-00018630 ; MAZARS-OVERSIGHT_COMMITTEE

00018642 MAZARS-OVERSIGHT_COMMITTEE -00018649.
378 MAZARS-OVERSIGHT_COMMITTEE -00018805 ; MAZARS-OVERSIGHT_COMMITTEE
00018806 MAZARS-OVERSIGHT_COMMITTEE -00014770 .
379 MAZARS- OVERSIGHT_COMMITTEE- 00008096 to MAZARS- OVERSIGHT_COMMITTEE
00008119 .

380 MAZARS- OVERSIGHT COMMITTEE - 00008120 .

381 Congressional Research Service , The United Arab Emirates (UAE) : Issues for U.S. Policy (Jan. 30,2023) (online at www.crs.gov/Reports/RS21852 ) ; Embassy of the United Arab Emirates , About UAE President
Sheikh Mohamed Bin Zayed ( accessed Nov. 1, 2023) ( online at www.uae-embassy.org/discoveruae/governance /about-uae-president -sheikh -mohamed -bin-zayed ); Mohammed bin Zayed, an Ambitious U.S.
Partner, Rises to Lead the U.A.E., New York Times (May 16, 2022) (online atwww.nytimes.com/2022/05/14/world/middleeast/mohammed-bin-zayed-elected-uae-leader.html).
Congressional Research Service , The United Arab Emirates (UAE) : Issues for U.S. Policy (Jan. 30,2023) (online at www.crs.gov/Reports/RS21852 ) .
94

U.A.E. Cultivation of Trump Administration and Qatar Blockade

Accordingto the New York Times, M.B.Z. worked assiduously before the presidential
election to crack Mr. Trump's inner circle, and secured a secret meeting during the transition
periodwiththe president's son- in- law, Jared Kushner.
Then- President Trump met with M.B.Z. at the White House on May 15, 2017. During an
OvalOfficephoto opportunity, President Trump said that M.B.Z. was ahighly respected and noted,
important.

very special person,

I think [ he] loves the United States, which to us is very

This visit occurred less than a week before President Trump traveled to Saudi

Arabia for the first overseas trip of his presidency 385

As discussedpreviously, in early June 2017, U.A.E.joined Saudi Arabia and other allied
nations in blockadingQatar.386 On June 8 , 2017, then- Secretary of State Tillerson statedTheemir of Qatar has made progress in haltingfinancial support and expellingterrorist elementsfrom his country, but he must do more and he must do it more quickly "Secretary Tillerson

called on the U.A.E., Saudi Arabia, and their regional allies to ease the blockade against Qatar.
That same day, however, then- PresidentTrump took a harsher stance than his Secretary of State,stating:

The nation of Qatar unfortunatelyhas historicallybeen a funder of terrorism at a very

high level

The Ambassador of the U.A.E. to the United States commentedapprovingly:

The UAEwelcomes PresidentTrump's leadershipin challengingQatar's troubling supportfor
extremism. The next step is for Qatar to acknowledge these concerns and commit to re- examine
its regionalpolicies. 388

March 13 , 2018 , then- President Trump made public his decision to fire Secretary
Tillerson by tweeting that Mike Pompeo , Director ofthe CIA , will become our new Secretary ofState.
The New York Times called Tillerson's dismissal the end of a rocky tenure for aformer oil executive who never meshed with the president, and noted that Secretary Tillerson
repeatedly disagreed with the White House and broke publicly with Mr. Trump on issues
The Most Powerful Arab Ruler Isn't M.B.S. It's M.B.Z., New York Times (June 2 , 2019) (online at
www nytimes.com/2019/06/02/world/middleeast/crown-prince-mohammed-bin-zayedhtml).

Trump Meets with Crown Prince ofAbu Dhabi as He Looks to Muslim World, USA Today (May 15,2017) (online at www.usatoday.com/story/news/politics/2017/05/15/trump-meets-crown-prince-abu-dhabi-he-looks
muslim-world/101721138
384

385 Saudis Welcome Trump's RebuffofObama's Mideast Views , New York Times (May 20, 2017) (onlineat www.nytimes.com/2017/05/20/world/middleeast/donald-trump-saudi-arabia.html).

386 SaudiArabia, Egypt and Other
NationsCutDiplomatic Ties withQatar, NPR (June 5 , 2017)(onlineat www.npr.org/sections/thetwo-way/2017/06/05/531548717/saudi-arabia-egypt-and-other-arab-nations-cut
diplomatic-ties-with-qatar).
387

Trump Scolds Qatar as Tillerson Seeks to Ease Crisis, Reuters (June 8 , 2017) (online atwww.reuters.com/article/us-gulf-qatar-sanctions/trump-scolds-qatar-as-tillerson-seeks-to-ease-crisis
idUSKBN18Z2ZU) .

388 GulfCrisis: Trump Escalates Row by Accusing Qatar ofSponsoring Terror, The Guardian (June 9,2017) (online at www.theguardian.com/us-news/2017/jun/09/trump-qatar-sponsor-terrorism-middle-east ).
389DonaldJ. Trump (@realDonaldTrump), X (formerly Twitter) (Mar. 13 , 2018) (online athttps://twitter.com/realDonaldTrump/status/973540316656623616 ).
95

rangingfrom the dispute between SaudiArabia and Qatar to the American responseto Russia's
cyber aggression
During the Trump Administration , the U.A.E. reportedly continued

to exploit thevulnerabilities in American governance , including its reliance on campaign contributions ,susceptibility to powerful lobbying firms and lax enforcement of disclosure laws in order tosteer U.S. foreign policy in ways favorable to the Arab autocracy . 391 These efforts were soconcerning to the U.S. intelligence community that U.S. agencies reportedly compiled aclassified report detailing the U.A.E. government's systematic efforts to manipulate U.S. foreign
policy in its favor 392

The U.A.E. reportedly engaged George Nader
President Trump , anda businessman , informal adviser tomediator and back- channel diplomat in Middle Eastern affairs

the country influence U.S. foreign policy

to help

According to Special Counsel Robert Mueller's

report into foreign interference in the 2016 election , Mr. Nader worked for the U.A.E. as anadvisor to

According to the New York Times,

Mr. Nader also held himself out asintermediary for Saudi Arabia's crown prince , Mohammed bin Salman .

The New York Times

reported:

Mr. Nader, 58, made frequent trips to the White House during the early months of the
Trump administration , meeting with Stephen K. Bannon and Jared Kushner to discuss
American policy toward the Persian Gulf states in advance of Mr. Trump's trip to Saudi
396

Arabia in May 2017 , according to people familiar with the meetings .

During the early days of the Trump Administration , Mr. Nader reportedly connected Mr.
Broidy with M.B.Z. , and eventually , Mr. Broidy's company entered into contracts with the
U.A.E. worth several hundred million dollars.397 Mr. Broidy took numerous actions intended toadvance the U.A.E.'s policy objectives

and oppose Qatar's interests

such as lobbying

Trump Fires Rex Tillerson and Will Replace Him with C.I.A. ChiefPompeo , New York Times (Mar. 13 ,2018) (online at www.nytimes.com/2018/03/13/us/politics/trump-tillerson-pompeo.html).

U.S. Intelligence Report Says Key Gulf Ally Meddled in American Politics, Washington Post (Nov. 12 ,2022) (online at www.washingtonpost.com/national-security/2022/11/12/uae-meddled-us-politics-intel-report/

392

).

.

George Nader, One ofthe Trump-RussiaInvestigation'sMostMysterious Figures, Explained,Vox(Mar.28, 2018) (onlineat www.vox.com/policy-and-politics/2018/3/28/17165410/george-nader-trump-mueller
immunity-russia).
394

Special Counsel Robert S. Mueller, III, Report on The Investigation into Russian Interference in the2016 Presidential Election (Mar. 2019 ) ( online at www.justice.gov/archives/sco/file/1373816/download ).
395 How 2 Gulf Monarchies Sought to Influence the White House, New York Times (Mar. 21, 2018 ) ( onlineat www.nytimes.com/2018/03/21/us/politics/george-nader-elliott-broidy-uae-saudi-arabia-white-house
influence.html) .

396 Mueller's Focus on Adviser to Emirates Suggests Broader Investigation ,New York Times (Mar. 3 ,2018) (online at www.nytimes.com/2018/03/03/us/politics/george-nader-mueller-investigation-united-arabemirates html).
397

.
96

Members of Congress and persuad[ ing] an American think tank, Foundation for Defense of
Democracies, to stage an anti-Qatar conference,

among other actions.

Public reporting also indicates that Mr. Broidy met with then- President Trump at theWhite House on October 6, 2017. According to the New York Times , in advance of Mr. Broidy's
meeting with President Trump , Mr. Nader conveyed to Mr. Broidy the policy positions the
U.A.E. wanted him to advocate.399

After meeting with then-President Trump , Mr. Broidy reported back to Mr. Nader" recounting his advocacy on the U.A.E.'s behalf during the meeting with Mr. Trump in the Oval
Office amid an afternoon of stops throughout the White House

Inaddition to raising otherissues ofpriority to the U.A.E. , Mr. Broidy reportedly lobbied the president to meet privately
in an informal setting with the Emirates military commander and de facto ruler, Crown Prince
Mohammed bin Zayed al- Nahyan; to back the U.A.E.'s hawkish policies in the region; and to
fire Secretary of State Rex W. Tillerson

In2019, the DOJ indicted Mr. Nader, Mr.Ahmad Andy Khawaja, and other coconspirators for illegally funneling Emirati money to the inaugural committee of President-electTrump, among other political action committees and party organizations, as well as to thepresidential campaign of Hillary Clinton prior to Mr. Trump's electoral
Mr. Nader,
who was already serving a sentence for a prior conviction, was given an additional year andeight months in prison for his role in funneling at least $3.5 million in unlawful contributions
from the UnitedArab Emirates ( UAE) to unwitting political committees in the United States.
InOctober 2020 , Elliott Broidy pled guilty to acting as an unregistered foreign agent for
Malaysian interests . Mr. Broidy also admitted to lobbying the U.S. government

to deport a

ThePrinces, thePresidentandthe FortuneSeekers, AssociatedPress (May 21, 2018) (onlineat).
https://apnews.com/article/a3521859cf8d4c199cb9a8567abd2b71
399

How 2 Gulf Monarchies Sought to Influence the White House, New York Times (Mar. 21, 2018 ) ( onlineat www.nytimes.com/2018/03/21/us/politics/george-nader-elliott-broidy-uae-saudi-arabia-white-house
influence.html) .

Mueller's Focus onAdviser to Emirates Suggests Broader Investigation, New York Times (Mar. 3,2018) (online at www.nytimes.com/2018/03/03/us/politics/george-nader-mueller-investigation-united-arabemirates html).
401.

402 United States v . Khawaja, et al. , No. 1: 19-cr -374 (D.D.C.) (online at.

https://cdn.cnn.com/cnn/2019/images/12/04/khawaja.et.al_indictment_unsealed 12.3.19.pdf) ; Indictment Details
How Emirates Sought Influence in 2016 Campaign, New York Times (Dec. 5 , 2019) ( online at
nytimes.com/2019/12/05/us/politics/indictment-uae-influence.html

).

403

Departmentof Justice, Press Release: ManPleads Guilty to Child Exploitation Crimes (Jan. 13, 2020)(onlineat www.justice.gov/usao-edva/pr/man-pleads-guilty-child-exploitation-crimes) ; Mueller Probe Witness Gets
10-year Sentence on Child Porn, Abuse Charges, Politico(June 26, 2020) (online atwww.politico.com/news/2020/06/26/george-nader-mueller-probe-sentence-341624) ; DepartmentofJustice, Press
Release: Businessman Sentencedfor $ 3.5MForeignConduit ContributionScheme (July 18, 2023) (online atwww.justice.gov/opa/pr/businessman-sentenced-35m-foreign-conduit-contribution-scheme).
97

critic ofthe Chinese Communist Party
offenses shortly before leaving office.405

President Trump pardoned Mr. Broidy for these

Emoluments
Paidby U.A.E.to Trump- OwnedBusinesses

As noted above , the U.A.E. spent more than $ 65,000 on stays at the Trump International
Hotel in Washington , D.C., from October 2017 through May 2018. On the nights of October 21406

to October 23, 2017 , the Embassy of the U.A.E. paid $2,625 for rooms rented at the hotel.4
This was the first of four stays by the Embassy of the U.A.E. recorded in the documents
produced by Mazars to the Committee .

The guest ledgerfor the Trump InternationalHotelinWashington, D.C., shows that on
the nightofNovember10, 2017, the E [ mbassy of the] -UnitedArab Emirates rented37 rooms.
Accordingto the hotelledgerdated July 29, 2018, its organizationaccount for the nightof
407

November10, 2017, was marked Closed with total charges of $ 33,512.4

In March 2018 , an

Embassy of the UAE Military Delegation rented 11 rooms at the

Trump International Hotel in Washington , D.C. , paying $ 26,168 . The bill for this stay states thatthe delegation arrived on March 8 , 2018 , and departed on March 16, 2018 ( with some food andbeverage charges incurred on March 17 and additional charges apparently applied to the bill afterthat date ) . However , based on the records , charges do not appear to have begun accruing until
408
March 10, 2018.4
Notably, both the U.A.E. and Saudi delegations were staying at the Trump
International Hotel in Washington , D.C., the day that Secretary of State Tillerson was fired .

Officials from the Embassy ofthe U.A.E. stayed at the Trump International Hotel inWashington, D.C. , again in May 2018, paying $2,920.40

404 Elliott Broidy Pleads Guilty in Foreign Lobbying Case, New York Times (Oct. 20, 2020) (online atwww.nytimes.com/2020/10/20/us/politics/elliott-broidy-foreign-lobbying.html ); Department of Justice, Press
Release: Elliott Broidy Pleads Guiltyfor Back-Channel Lobbying Campaign to Drop IMDBInvestigation andRemove a Chinese ForeignNational (Oct.20, 2020) (online at www.justice.gov/opa/pr/elliott-broidy-pleads-guilty
back-channel-lobbying-campaign-drop - 1mdb-investigation-and).
405 With Hours Left in Office, Trump Grants Clemency to Bannon and Other Allies , New York Times ( May
5 , 2021) ( online at www.nytimes.com/2021/01/20/us/politics/trump-pardonshtml) .

406 MAZARS-OVERSIGHT- COMMITTEE-00018630; MAZARS-OVERSIGHT_COMMITTEE
00018642; MAZARS-OVERSIGHT_COMMITTEE-00018649.

407 MAZARS-OVERSIGHT_COMMITTEE -00018805 ; MAZARS -OVERSIGHT_COMMITTEE

00018806 MAZARS-OVERSIGHT_COMMITTEE -00014770 .
408

MAZARS- OVERSIGHT_COMMITTEE- 00008096to MAZARS- OVERSIGHT_COMMITTEE

00008119 .

409 MAZARS- OVERSIGHT_COMMITTEE-00008120. The bill states that the arrivaldate was May 1,
2018, andthe departure date was May31, 2018; however, charges were incurredonly on May 1, May 2 , and May 3,
2018, by four individuals.
98

LobbyistSpending

Elliott Broidy , who would later plead guilty to violating FARA, stayed at the Trump
International Hotel in Washington , D.C., on October 6 , 2017 the same day he reportedly
lobbied President Trump on behalf of the
For his stay that night and the five preceding
411
at
least
$2,970.4
From
October22
to 24, 2017 , Mr. Broidy stayed at the Trumpnights, he spent
International Hotel in Washington , D.C., spending at least $2,820 during that period.4¹2 This staypartially overlapped with a stay by the U.A.E. Embassy.413 It is unclear whether Mr. Broidy
stayed at the hotel as part of lobbying efforts on behalf of the U.A.E. or whether his stays were
paid for by the U.A.E. As a result, these sums are not included in the emolument totals in thisreport .
Trump Business Interests in U.A.E.

Former President Trump has had extensive business interests in Dubai for many years .
According to the New York Times , in 2013 and again in 2014 , Trump agreed to work with
Hussain Sajwani, a developer who was reportedly known as the Donald of Dubai, to develop
two golf courses.
In February 2017, shortly after Donald Trump took office, both Donald
Trump Jr. and Eric Trump attended the opening of one of those golf courses .
May 16, 2017415

just one day before then- President Trump met with M.B.Z.

DonaldTrump Jr. appears to have met with Mr. Sajwani in the U.A.E.4¹6 On August 5 , 2017 , The Trump
Organization tweeted the launch of The Trump Estates Park Residences, a collection luxury
villas [ sic] with exclusive access to @TrumpGolfDubai.
410

This venture was undertaken by The

Departmentof Justice, Press Release: ElliottBroidyPleads Guilty for Back- Channel Lobbying

Campaignto Drop IMDBInvestigationand Remove a Chinese Foreign National( Oct. 20, 2020) (online atwww.justice.gov/opa/pr/elliott-broidy-pleads-guilty-back-channel-lobbying-campaign-drop-1mdb-investigation

-- -

and
).

-- -

-- -

411 MAZARS OVERSIGHT COMMITTEE 00018457 ; MAZARS OVERSIGHT COMMITTEE
00018466 ;MAZARS OVERSIGHT COMMITTEE 00018478 ; MAZARS OVERSIGHT COMMITTEE
00018487 ;MAZARS OVERSIGHT_COMMITTEE 00018494 ; MAZARS OVERSIGHT_COMMITTEE
00018501---

412 MAZARS OVERSIGHT_COMMITTEE 00018642 ;MAZARS OVERSIGHT_COMMITTEE
00018643 MAZARS OVERSIGHT_COMMITTEE 00018649 ; MAZARS OVERSIGHT_COMMITTEE
00018657

.

-

-

-

413 MAZARS- OVERSIGHT_COMMITTEE- 00018642; MAZARS- OVERSIGHT_COMMITTEE
00018649.

414

Trump's Business Ties in the GulfRaise Questions About His Allegiances , New York Times (June 17,2017) (online at www.nytimes.com/2017/06/17/world/middleeast/trumps-business-ties-in-persian-gulf-raisequestions -about-his- allegiances.html ).
415

Trump Sons Open Dubai Golf Club as Namesake Now USPresident Seattle Times (Feb. 18, 2017)(online at www.seattletimes.com/business/trumps-sons-eric-and-donald-jr-in-dubai-to-open-golf-club/).
416

Trump's Business Ties in the GulfRaise Questions About His Allegiances , New York Times (June 17,2017) (online at www.nytimes.com/2017/06/17/world/middleeast/trumps-business-ties-in-persian-gulf-raisequestions -about -his-allegiances.html); Hussain Sajwani, Instagram (May 16, 2017) (online atwww.instagram.com/p/BUJwB2HlnMB/ ) .
The Trump Organization (@Trump), X (formerly Twitter) (Aug. 5, 2017) (online at99

Trump Organization in partnership with Hussain Sajwani's DAMAC firm.418 President Trump's
ethics disclosure covering his finances for 2017 show that he claimed $ 141,433 in income fromDT DUBAI GOLF MANAGER LLC

an entity through which former President Trump

conducted business for the Trump International Golf Club, Dubai.419 The company generated
even more income for then- President Trump during the rest of his time in office. He reported
earning over $300,000 in income from the company in 2018 and 2019, and $ 458,000 from it in
420
2020.4The Trump family's significant business activities in the U.A.E. during Mr. Trump's
presidency raise the persistent question of whether he conducted American foreign policy inthe
Middle East to further his business interests rather than U.S. interests .

U.A.E.Investmentin Kushner FundShortly after leaving the White House , during his 2021 fundraising tour of Gulf States forhis private equity firm , Affinity Partners , Jared Kushner solicited an investment from the U.A.E.
Despite reported concerns by Emirati rulers about Mr. Kushner's lack of business experience , anEmirati fund ultimately agreed to invest $ 200 million in the fund.421).
https://twitter.com/trump/status/893841118328172544

418

Trump's Interests vs. America's, Dubai Edition, The Atlantic ( Aug. 9 , 2017) (online atwww.theatlantic.com/business/archive/2017/08/donald-trump-conflicts-of-interests/508382/).

Office of Government Ethics, Executive Branch Personnel Public FinancialDisclosures (OGE Form278e) (Donald J. Trump) (Filed May 15, 2018) (online at https://s3.documentcloud.org/documents/21154685/trumpoge-2018.pdf); ProPublica, Trump's 10 Troubling Deals with Foreign Power-Players (Jan. 19, 2017) (online athttps://projects.propublica.org/trump-conflicts/); DAMAC Properties, Press Release : DAMAC Properties toDevelop Championship Trump International GolfCourse in Dubai (May 5, 2013) (accessed via Nexis).

Officeof Government Ethics, Executive Branch PersonnelPublic FinancialDisclosures (OGE Form278e) (Donald J. Trump ) (Filed May 15, 2018) (online at https://s3.documentcloud.org/documents/21154685/trumpoge-2018.pdf); Office of Government Ethics, Executive Branch Personnel Public Financial Disclosures (OGE Form278e) (Donald J. Trump) (Filed May 15, 2019) (online at https://s3.documentcloud.org/documents/21154683/trumpoge-2019.pdf) ; Office of Government Ethics, Executive Branch PersonnelPublicFinancialDisclosures (OGE Form278e) (Donald J. Trump ) (Filed July 31, 2020) (online athttps://s3.documentcloud.org/documents/7012257/President-Donald-Trump-2020-financial-disclosure.pdf); OfficeofGovernmentEthics, ExecutiveBranchPersonnelPublicFinancialDisclosures(OGE Form278e) ( Donald J.
Trump) (FiledJan. 15, 2021) (onlineat
https://extapps2.oge.gov/201/Presiden
nsf/ PAS+Index/ 6E78B163F816EF6A852586630075291D/ $FILE/ Trump, 2
20J 202021Termination 20278.pdf) ; ProPublica, Trump's 10 TroublingDeals with ForeignPower
Players(Jan. 19, 2017) (online at https://projects.propublica.org/trump-conflicts/) ; DAMAC Properties, Press
Release: DAMACPropertiesto DevelopChampionship Trump InternationalGolfCourse inDubai(May5 , 2013)(accessedvia Nexis).
Kushner Firm Got Hundreds ofMillions From 2 Persian GulfNations, New York Times (Mar. 30,2023) (online at www.nytimes.com/2023/03/30/us/politics/jared-kushner-qatar-united-arab-emirates.html) ; Seeking
Backersfor New Fund, Jared Kushner Turns to Middle East, New York Times (Nov. 26, 2021) (online atwww.nytimes.com/2021/11/26/us/politics/kushner-investment-middle-east.html).
100

KUWAITThe records produced to the Committee by Mazars reveal that the State of Kuwait paid
emoluments to then-President Trump's businesses totaling $303,372 . Just over $ 150,000 of thisamount was paid by the Embassy of Kuwait to the Trump International Hotel in Washington ,D.C., for banquets held in 2017 and 2018. According to public reporting, Kuwait also held abanquet at the hotel in
However , because Mazars did not produce any records
associated with the 2019 banquet, the Committee is unable to determine the amount that the
Embassy paid for the event . The remainder of the emoluments that Kuwait paid to thenPresident Trump's businesses consists of charges for a property at the Trump World Tower in423
New York, which was owned by Kuwait throughout President Trump's term.
Kuwait'sEmolumentSpendingat TrumpProperties

Location

Expenditure

AmountFebruary22, 2017

Trump International Hotel(Washington, D.C.)

EmbassyofKuwait
NationalDay-2017$ 77,45642

February 26, 2018

Trump InternationalHotel(Washington, D.C.)

Embassyof Kuwait
Banquet(2018)$73,252425

January 2018

Trump World Tower
845 United Nations PlazaThe Missionofthe

426$38,16642

State of Kuwait( 2018)Date

December 2018

(New York, NY)424

422 Embassy ofthe State ofKuwaitin Washington,PressRelease: KuwaitEmbassyin Washington Marks
Nat'lCelebrations (Feb.27 , 2019) (online at www kuwaitembassy.us/i he-news/kuwait-embassy-in-washington
marks-natl- celebrations#slideshow-2) .
New York City Department of Finance, Document ID: 2012112001019004 (Nov. 16, 2012) (online athttps://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2012112001019004) (accessed Dec.
7, 2023) New York City Department of Finance, Assessment Roll 2016-2017, Borough: Manhattan, Block: 1340,
Lot: 1201(Jan. 5, 2016) ( accessed Dec. 6, 2023) ; New York City Department of Finance, Assessment Roll2017
2018, Borough: Manhattan, Block: 1340, Lot: 1201 ( Jan. 5, 2017) (accessed Dec. 6, 2023) ; New York City
Departmentof Finance, Assessment Roll 2018-2019, Borough: Manhattan, Block: 1340, Lot: 1201 (Jan. 5, 2018)( accessed Dec. 6, 2023) ; New York City Department of Finance, Final Assessment Roll 2019-2020, Borough:Manhattan, Block: 1340, Lot: 1201 (Jan. 5, 2019) (accessed Dec. 6, 2023) ; New York City Department of Finance,
FinalAssessment Roll2020-2021, Borough: Manhattan, Block: 1340, Lot: 1201 (Jan. 5, 2020) (accessed Dec.6 ,2023) ; New York City Department of Finance, Final Assessment Roll 2021-2022, Borough: Manhattan, Block:. 6 , 2023)
1340, Lot: 1201 (Jan. 5, 2021) ( accessed.
425 MAZARS -OVERSIGHT_COMMITTEE -00027271 .
426 MAZARS -OVERSIGHT_COMMITTEE - 00027355 ;
00027401 ;MAZARS - OVERSIGHT COMMITTEE -00027448 ; MAZARS -OVERSIGHT COMMITTEE
00027496 ;MAZARS -OVERSIGHT_COMMITTEE -00027554 ; MAZARS -OVERSIGHT_COMMITTEE
00027612 ;MAZARS - OVERSIGHT COMMITTEE -00027706 ; MAZARS -OVERSIGHT COMMITTEE
00027660 ;MAZARS - OVERSIGHT_COMMITTEE - 00027752 ; MAZARS -OVERSIGHT_COMMITTEE
00027795 MAZARS -OVERSIGHT_COMMITTEE - 00027838 ; MAZARS -OVERSIGHT_COMMITTEE
00027883 .
424

MAZARS OVERSIGHT_COMMITTEE 00027307

MAZARS- OVERSIGHT_COMMITTEE

101

Estimated Total
Emolument for
4

Years
:

$ 152,664( 2017-2020)

ESTIMATED EMOLUMENTS PAID BY KUWAIT$ 303,372( 2017-2020)

November 18, 2016

just days after Donald Trump was declared the winner of the2016 presidential election the then-Kuwaiti Ambassador to the United States, H.E. Salem Al
Sabah, reportedly and abruptly switched the venue for the Embassy of Kuwait National Day
event from the Four Seasons Hotel in Washington, D.C., to the Trump International Hotel inWashington, D.C.427 The Ambassador signed a Catering Event Agreement with the Trump
International Hotel, in Washington, D.C., for the event at a cost of $ 82,713 . Among the items
that the Embassy ordered for the occasion were a Sushi Station" for $ 12,000 and a Little Italy
Display for $ 10,800.428 The records provided by Mazars to the Committee include a copy of a
March 1, 2017, checkout to the Trump
he Embassy of the State of Kuwait maInternational Hotel Washington, D.C. in the amount of $ 77,456; written in the memo section
ofthe check is Event Date : 02/22/2017 .
The check is reproduced below.
30930

EMBASSYOF THE STATE OF KUWAIT

back

2940 TILDEN ST
WASHINGTON

3/1/2017

20008-1149

PAYTO THEORDEROF

TrumpInternational
Hotel Washington, D.C.

$

77,456.00-Six Only
Seventy- SevenThousandFour HundredFifty
DOLLARSfeatures
Security

Trump International Hotel

Washington , D.C.
1100 Pennsylvania Avenue , NW

Washington, D.C.20004
MEMO

EventDate: 02/22/2017

The former Ambassador's sudden change of plan was particularly notable in light of a
December 2016 Politico article , which reported that he had a tentative save -the - dateunderstanding with the Four Seasons " for the National Day event , butnever signed aformal contract with that hotel. Politico further reported that Al- Sabah acknowledged that
he'd decided to hold the gathering at Trump's hotel after the Republican won the presidency on
Nov. 8.

According to a release on the Kuwaiti Embassy's website , Kuwait's 2017 National Day
Kuwait Envoy: Trump Aides Didn't Push Me to Book His Hotel, Politico (Dec. 20, 2016) (online atwww.politico.com/story/2016/12/kuwait-donald-trump-hotel-232866).

428 MAZARS- OVERSIGHT_COMMITTEE- 00027303 to MAZARS- OVERSIGHT_COMMITTEE
00027306.

429 MAZARS- OVERSIGHT_COMMITTEE- 00027307.
102

celebrationwas attendedby Secretaryofthe TreasurySteven Mnuchin, amongother luminary
430
guests.
In2018 and 2019, the Embassy returned to the Trump International Hotel for its national431

day event.

Mazars produced to the Committee an email from a member of Mazars Real

Estate Group to Michael Levchuck, the Area Director of Finance for the Trump International
Hotels in New York and Washington, D.C., indicating that Kuwait paid $ 73,252 for the 2018
event.432 Mazars did not produce any financial records to the Committee for Kuwait's 2019
nationalday event, but the Embassy of Kuwait issued a press release reporting that it drew anumber of senior Trump Administration officials back to its favorite venue:

The Kuwaiti Embassy in Washington DC held Tuesday evening a reception at the Trump
InternationalHotel to mark the country's 58th NationalDay and 28th Liberation Day.

The receptionwas attendedby top senior officials, includingSecretaryof Commerce
WilburRoss, Secretaryof Housingand UrbanDevelopmentBenCarson, Administrator
ofthe UnitedStates EnvironmentalProtectionAgencyAndrewR. Wheeler andCounselorto the PresidentKellyanneConway

The Permanent Mission of the State of Kuwait to the United Nations also owned a unit in
Trump World Tower in New York City that was purchased in 2012 for $4.15 million.434 Kuwait
paid $38,166 in base charges to Trump World Tower for the unit for 2018 the only year forwhich Mazars produced records . Assuming that these charges were unchanged throughout
President Trump's time in office, this report estimates that Kuwait paid President Trump's
435
business $ 152,664 for this property over those four years .

Embassy of the State of Kuwait in Washington , Press Release: The Embassy Celebrates Kuwait's
National Day (Feb. 23 , 2017) (online at www.kuwaitembassy.us/in-the-news/the-embassy-celebrates-kuwaits
national- day).
430

Critics Question Undisclosed Flow of Money from Foreign Governments to Trump Properties ,ABCNews (Feb. 28, 2018 ) (online at https://abcnews.go.com/Politics/critics-question-undisclosed-flow-money-foreign
governments -trump / story ?id 53413228)
432 MAZARS- OVERSIGHT_COMMITTEE- 00027271.

Embassy ofthe State of Kuwait in Washington, Press Release: Kuwait Embassy in Washington Marks
Nat'l Celebrations (Feb. 27 , 2019) (online at www kuwaitembassy.us/in-the-news/kuwait-embassy-in-washington
marks-natl- celebrations#slideshow-2 ) .

---.

-----

-----

New York City Department of Finance , Document ID: 2012112001019003 (online at https ://a836

acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2012112001019003 ) (accessed Aug. 29, 2023 ).
435 MAZARS OVERSIGHT_COMMITTEE 00027355 ; MAZARS OVERSIGHT_COMMITTEE
00027401 ;MAZARS OVERSIGHT COMMITTEE 00027448 ; MAZARS OVERSIGHT COMMITTEE
00027496 ;MAZARS OVERSIGHT_COMMITTEE
00027612 MAZARS OVERSIGHT_COMMITTEE
00027660 ;MAZARS OVERSIGHT_COMMITTEE
00027795 MAZARS OVERSIGHT_COMMITTEE
00027883

00027554 ; MAZARS OVERSIGHT_COMMITTEE
00027706 ; MAZARS OVERSIGHT_COMMITTEE
00027752 ; MAZARS OVERSIGHT_COMMITTEE
00027838 ; MAZARS OVERSIGHT_COMMITTEE103

INDIA

India is home to the largest number of Trump- owned business projects outside of theUnited States this was the case when Mr. Trump first took office and appears to remain so as of
the writing of this report .436 Former President Trump's numerous foreign businessentanglements in India and his direction of U.S. foreign policy during his presidency repeatedlyintersected , creating conspicuous conflicts of interest . Indeed, Politico observed in February2020 that nowhere are the lines more blurred between Trump the statesman and Trump thesalesman than in India. 437
Itwas throughhis businessventuresthat Mr.Trump laidthe groundworkfor hisuniquely
warm relationshipwith IndianPrimeMinisterNarendraModi. Infact, whilevisitingthe WhiteHouseduringPresidentTrump'sAdministration, PrimeMinisterModiexplicitlyremarkedthat
Mr.Trumphadbeen full ofverywarmremarksandobservationsfor me when Mr. Trumphad
438

previouslybeeninIndiapromotinghis businessinterestsprior to his presidency.

During the Trump Administration , the Indian government spent at least $ 282,764 at
Trump properties in New York City and Washington , D.C. This spending encompassed the costs
incurred by the Indian government for two units in Trump World Tower , which they owned
throughout the Trump presidency , as well as multiple stays at the Trump International Hotel inWashington , D.C., by officials from the Indian Embassy in the United

Potential Conflicts Around the Globe for Trump, the Businessman President , New York Times (Nov.
26, 2016) (online at www.nytimes.com/2016/11/26/us/politics/donald-trump-international-business.html ); Half-A
Dozen Trump Towers Are Set to Come Up in India , Business Today (Dec. 13, 2022 ) (online atwww.businesstoday.in/latest/economy/story/half-a-dozen-trump-towers-are-set-to-come-up-in-india-356222-2022

12-13 ) Proud to be the Largest Developer of Trump Properties in the World : Kalpesh Mehta, Tribeca Developers,
Financial Express (Sept. 5, 2023 ) (online at www financialexpress.com/money/proud-to-be-the-largest-developerof-trump -properties -in- the -world -kalpesh -mehta-tribeca -developers -3233478 ) .
Trump Visits a Big Foreign Market for the U.S. andfor Trump Org, Politico (Feb. 22, 2020 ) (online atwww.politico.com/news/2020/02/22/trump-india-business-116322).

The American Presidency Project , Donald J. Trump, Remarks Prior to a Meeting with Prime Minister
Narendra Modi ofIndia (June 26, 2017) (online at www.presidency.ucsb.edu/documents/remarks-prior-meeting
with-prime -minister-narendra -modi-india).
439

New York City Departmentof Finance, DocumentID: 2004030900483001 (Mar. 5, 2004) ( online athttps://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2004030900483001) (accessed Dec.
7, 2023) New York City Department of Finance, Document ID: 2004030900469001 (Mar. 5, 2004) (online athttps://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2004030900469001) (accessed Dec.
7, 2023 ) New York City Departmentof Finance, Assessment Roll 2016-2017 , Borough: Manhattan, Block: 1340,
Lot: 1199 (Jan. 5, 2016) ( accessed Dec. 6, 2023) ; New York City Department of Finance, Assessment Roll2017
2018, Borough: Manhattan, Block: 1340, Lot: 1199 (Jan. 5, 2017) (accessed Dec. 6, 2023) ; New York City
Departmentof Finance, Assessment Roll 2018-2019, Borough: Manhattan, Block: 1340, Lot: 1199 (Jan. 5, 2018)( accessedDec. 6, 2023) ; New York City Department of Finance, Final Assessment Roll 2019-2020, Borough:Manhattan, Block: 1340, Lot: 1199 (Jan. 5, 2019) (accessed Dec. 6, 2023) ; New York City Department of Finance,
Final Assessment Roll 2020-2021, Borough: Manhattan, Block: 1340, Lot: 1199 (Jan. 5 , 2020) (accessed Dec. 6,2023) New York City Department of Finance, Final Assessment Roll 2021-2022, Borough: Manhattan, Block:
1340, Lot: 1199 (Jan. 5 , 2021) (accessed Dec. 6, 2023) ; New York City Departmentof Finance, Assessment Roll
2016-2017, Borough: Manhattan, Block: 1340, Lot: 1233 (Jan. 5 , 2016) (accessed Dec. 6, 2023) ; New York City
Departmentof Finance, Assessment Roll 2017-2018 , Borough: Manhattan, Block: 1340, Lot: 1233 (Jan. 5, 2017)( accessedDec. 6, 2023) ; New York City Department of Finance, Assessment Roll2018-2019 , Borough: Manhattan,
104

At the same time , The Trump Organization , led by Donald Trump Jr. and Eric Trump ,was moving ahead on multiple projects in India while their father was President . In 2019 ,OpenSecrets described the importance ofthe Indian market for Mr. Trump's business , noting,
The Trump Organization covets perhaps no other foreign country more than India.
Together , India's emolument spending at Trump properties and Mr. Trump's deep business ties to
India enriched Donald Trump by potentially millions of dollars while he was in office.441
India's Emolument Spending at Trump Properties
Date
2017-2020

Location

Expenditure

Trump World Tower
845 UnitedNationsPlaza

Permanent
Mission ofIndia(NewYork, NY)

Amount442$ 66,0464( 2018)Estimated Total
Emolument
for 4

Years
:

$ 264,184( 2017-2020)
February 18-19,
2017

Trump InternationalHotel

Stays by Indian443$18,5804

Diplomats( Washington, D.C.)

21-24, 2017;
March5-18, 2017
ESTIMATED EMOLUMENTSPAID BY INDIA$ 282,764( 2017-2020)

Block: 1340, Lot: 1233 (Jan. 5, 2018) (accessed Dec. 6, 2023); New York City Department of Finance, Final
Assessment Roll 2019-2020 , Borough: Manhattan, Block: 1340 , Lot: 1233 (Jan. 5, 2019) (accessed Dec. 6, 2023);
New York City Department of Finance, Final Assessment Roll 2020-2021, Borough: Manhattan, Block: 1340, Lot:
1233 (Jan. 5, 2020) (accessed Dec. 6 , 2023); New York City Department of Finance, Final Assessment Roll 2021
2022, Borough: Manhattan, Block: 1340, Lot: 1233 (Jan. 5 , 2021) (accessed Dec. 6, 2023 ) .
440

OpenSecrets, World ofInfluence: A Guide to Trump's Foreign Business Interests (June 4 , 2019) (online).
atwww.opensecrets.org/news/2019/06/trump-foreign-business-interests/

441 MAZARS-OVERSIGHT COMMITTEE-00027355 to MAZARS-OVERSIGHT COMMITTEE
00027886; Trump's D.C. HotelHosted Diplomats from These 33 Countries, Forbes (Oct. 10, 2021) (online at
www forbes.com/sites/zacheverson/2021/10/10/trumps-dc-hotel-hosted-foreign-officials-from-these-33-countries
while-he-was-in-office ) ; Aroon Deep @AroonDeep , X (formerly Twitter) (Feb. 18, 2018) (online athttps://twitter.com/AroonDeep/status/966853259041308673) . Mr. Deep's post on X states that the total amount of
the stays by the Indian diplomats at the Trump International Hotel was $ 18,650; however, the document provided in
the X post records expenditures totaling only $ 18,580 and that isthe figure provided inthis report. MAZARSOVERSIGHT COMMITTEE-00008041; OpenSecrets, WorldofInfluence: A Guideto Trump's Foreign Business
Interests (June 4, 2019) (online at www.opensecrets.org/news/2019/06/trump-foreign-business-interests/).
442 MAZARS -OVERSIGHT_COMMITTEE - 00027355 to MAZARS -OVERSIGHT_COMMITTEE
00027886.

Trump's D.C. HotelHosted Diplomats from These 33 Countries, Forbes ( Oct. 10, 2021) (online at
www forbes.com/sites/zacheverson/2021/10/10/trumps-dc-hotel-hosted-foreign-officials-from-these-33-countries
while-he-was-in-office ) ; Aroon Deep @AroonDeep , X (formerly Twitter) (Feb. 18, 2018) (online athttps://twitter.com/AroonDeep/status/966853259041308673 ) . Mr. Deep's post on X states that the total amount of
the stay by the Indian diplomats at the Trump International Hotelwas $18,650; however, the document provided in
the X post records expenditures totaling only $ 18,580, which is the figure provided in this report. MAZARSOVERSIGHT_COMMITTEE- 00008041.
443

105

Mr. Trump had been conducting business in India for over a decade before he took officeand had five projects underway at various stages of development when he was sworn in as
He partnered with influential businesspeople in the country , many of whom were
President
well-connected politically, but whose business practices have been called into question. For
example, Mr. Trump entered into business with several individuals implicated in investigations
by Indian authorities involving accusations of fraud and other financial misconduct.445 Some ofthose companies continued to face investigations during Mr. Trump's presidency.

446

Mr. Trump reportedly made a positive first impression on Mr. Modi years before he waselected president. In August 2014 , shortly after Mr. Modi was elected as India's Prime Minister,Mr. Trump traveled to Mumbai to promote a Trump -branded project. Duringthat business trip,
Trump praised Prime Minister Modi, who was a political ally ofMr. Trump's business partner on
the Mumbai project, Mangal Prabhat Lodha. Inaddition to being one of India's wealthiest
businessmen, Mr. Lodha is also reportedly a powerful, long-serving state legislator and leader
447
In2013 , when Trump's
inthe Bharatiya Janata Party (BJP), Mr. Modi's political party.
Mumbai Tower deal was announced, several of Mr. Lodha's companies had reportedly been
under investigation by Indian officials for corrupt practices and tax evasion, and the Mumbai
development was not a sure thing.

The project's prospects improved, however, after Mr. Modi

took office. Under the Modi government , the investigations into Mr. Lodha's companies began
to wind down, with several investigators alleging that they were forced to end their cases
prematurely at the urging of loyalists to Prime Minister Modi, according to reporting from the448
New Republic
Duringhis 2014 visit to India, Mr. Trump saidthat he was lookingforwardto doing
businessunderthe ModiAdministration, stating:think the electionmadethat evenbetter

I do see India as a great place to invest, and I

Mr.Trump also commented, Peopleare cominginto

Indianow that maybe would not have prior to the election. Hepromised, We willmake
investmentsinIndia, substantialinvestments in India. It's a great placeto invest.
Mr. Trump
Potential Conflicts Around the Globe for Trump, the Businessman President, New York Times (Nov. 26,
2016) (online at www.nytimes.com/2016/11/26/us/politics/donald-trump-international-business.html).

The Many Red FlagsofTrump's Partners in India Trump, Inc. Podcast, ProPublica (Mar. 28,2018) (online atwww.propublica.org/article/trump-inc-podcast-trumps-partners-in-india-many-red-flags).
Political Corruption and the Art ofthe Deal, New Republic (Mar. 21, 2018) (online athttps://newrepublic.com/article/147351/political-corruption-art-deal) ; Trump's 10 Troubling Deals with Foreign
Power-Players, ProPublica (Jan. 19, 2017) ( online at https://projects.propublica.org/trump-conflicts/) .
447

Trumps Set to Launch Two RealEstate Projects in India, Despite Conflict- Of-Interest Concerns,

WashingtonPost (Oct. 28 , 2017) (online at www.washingtonpost.com/world/asia_pacific/trumps-set-to-launch-two

real-estate-projects-in-india-despite-conflict-of-interest-concerns/2017/ 10/27/f7de887c-a2d9-11e7-b573
8ec86cdfeled_storyhtml); PoliticalCorruptionand theArt oftheDeal, New Republic (Mar.21, 2018) (online athttps://newrepublic.com/article/147351/political-corruption-art-deal).

DonaldTrump Back in Mumbai, This Timewith Lodha Group, Business Standard (Sept. 17, 2013)(online at www.business-standard.com/article/companies/donald-trump-back-in-mumbai-this-time-with-lodhagroup-113091700640_1.html); Political Corruption and the Art ofthe Deal, New Republic (Mar.21,2018) (online
at https://newrepublic.com/article/147351/political-corruption-art-deal); OpenSecrets, World ofInfluence: A Guide
to Trump's Foreign Business Interests (June 4, 2019) (online at www.opensecrets.org/news/2019/06/trump-foreignbusiness-interests/).
DonaldTrump PlansInvestmentin India, CNBC ( Aug. 12, 2014) (online at106

reportedly gave more than a dozen interviews to the local media, repeatedly praising Modi fordoing a spectacular job and improving the country's image around the world
Ahead of Mr.Trump's presidential inauguration, public reporting observed that his
significant business ventures in India created apotentially serious ethical hazard for a UnitedStates president who is also a real estate mogul.
November 2016 :As the New York Times explained in

Several ofMr. Trump's real estate ventures in India

where he has more projects

underway than in any location outside North America

are being built throughcompanies with family ties to India's most important political party . This makes it more
likely that Indian government officials will do special favors benefiting Mr. Trump's
projects , including pressuring state - owned banks to extend favorable loans.452
Even as he was preparing to take office , Mr. Trump made time to meet with several of his
Indian business partners . The week after his election , President- elect Trump met at Trump Tower
in New York with three ofthe Indian businessmen with whom he worked on a real estatedevelopment project in the country. Mr. Trump reportedly discussed both his business venturesin India as well as politics

including his affinity for Prime Minister Modi

at this meeting.453

Also in November 2016 , India's foreign secretary, S. Jaishankar , reportedly met withvery senior members of President - elect Trump's transition team during a visit to the UnitedStates , doing so [ a] midst reports that efforts are on to fix an early meeting between Prime
Minister Narendra Modi and Donald Trump
Mr.Modiwould not forget Mr. Trump's kindwords, nor his recordas businessman.
Accordingto OpenSecrets, during his official visitto the White Housein June 2017, the Prime
Minister reminiscedover Trump's kind commentsmade duringhis 2014 trip to India.
translatedcommentsofthe Prime Ministerincludedthe followingstatement:www.cnbc.com/2014/08/12/donald-trump-plans-investment-in-india

The

I dorememberhtml) .

Political Corruption and the Art ofthe Deal, New Republic (Mar. 21, 2018) (online athttps://newrepublic.com/article/147351/political-corruption-art-deal).

451 Potential Conflicts Around the Globe for Trump, the Businessman President, New York Times (Nov. 26,
2016) (online at www.nytimes.com/2016/11/26/us/politics/donald-trump-international-business.html
452

).

.

Donald Trump Meeting Suggests He Is Keeping Up His Business Ties, New York Times (Nov. 19, 2016)(online at www nytimes.com/2016/11/20/us/politics/donald-trump-pauses-transition-work-to-meet-with-indianbusiness-partners.html ).
FS Jaishankar Meets Trump's Transition Team During US Visit , Economic Times (Nov. 24, 2016)(online at https://economictimes.indiatimes.com/news/politics-and-nation/fs-jaishankar-meets-trumps-transition
team- during- us- visit/ articleshow/ 55605894.cms
) .

455

OpenSecrets, World ofInfluence: A Guide to Trump's ForeignBusinessInterests(June 4, 2019) ( onlineat www.opensecrets.org/news/2019/06/trump-foreign-business-interests/) ; Trump Meets India's Leader, A Fellow
NationalistBattling Chinafor His Favor, New York Times (June 26 , 2017) ( online atwww.nytimes.com/2017/06/26/us/politics/donald-trump-narendra-modi-indiahtml) .
107

very well that when President Trump, when he was not even President, visited India. And whenin a media interview, he was asked about me . He was full ofvery warm remarks andobservations for me. I still remember them today 456

Prime Minister Modi also lauded Mr. Trump's vast and successful business experience,
which the Prime Minister predicted would galvanize relations between the United States andIndia, according to the New York Times
The Wall Street Journal reported that Prime Minister
Modi's visit to the White House came amid differences between Messrs. Modi and Trump on
issues such as trade, climate change and immigration but that the two men papered over theirdifferences as they worked to establish a rapport in discussions set over approximately fourhours, including a private dinner at the White House. They hugged after their publicstatements 458
Continued
PromotionofTrump BusinessesDuringthe Trump Presidency

Just one month after the June 2017 visit of Prime Minister Modi to the White House , theWall Street Journal reported that [p] romotional material for the Trump Tower in Mumbai
improperly featured a reference to President Donald Trump , showing how difficult it is toseparate the president from a brand whose value is based on his name . The material reportedly
stated : The world's glitterati have always chosen a unique landmark : Trump , and included thewords
Donald Trump . The Man. The Icon . In addition , an accompanying email did refer to
Mr. Trump as POTUS short for President of the United States and cited a tweet in which hecalled the project incredible
After being contacted by the press , the Trump Organization andan Indian development firm marketing the project said the materials had been sent out by a
The invocation of thenbroker without their authorization , and won't be used again .
President Trump in this marketing campaign nevertheless reflects both how active Mr. Trump's
business in India remained during his presidency as well as how President Trump and his Indianbusiness stood to profit from his presidency .
Inthe months that followed Prime Minister Modi's visit to the White House, Ivanka
Trump, as a White House official, and Donald Trump Jr., as the head of The Trump Organization,
460 In November 2017, Ms. Trump ledthe U.S.
would each make working trips to India.4

456 The American Presidency Project, DonaldJ. Trump,RemarksPrior to a Meetingwith PrimeMinister
NarendraModiofIndia (June26, 2017) (online at www.presidency.ucsb.edu/documents/remarks-prior-meeting
with-prime-minister-narendra-modi-india).
457

Trump MeetsIndia's Leader, a Fellow NationalistBattling China for His Favor, New York Times (June26, 2017) ( online at www.nytimes.com/2017/06/26/us/politics/donald-trump-narendra-modi-india.html).

Trump and Indian Prime MinisterModi Move to Bridge Divisions, Wall Street Journal (June 26,2017)(online at www.wsj.com/articles/president-trump-greets-indian-prime-minister-modi-at-the-white-house
458

1498511769).

Pitchfor Trump Tower Mumbai Plays Up Connection to Donald Trump , Wall Street Journal (July 26,2017) (online at www.wsj.com/articles/pitch-for-trump-tower-mumbai-plays-up-connection-to-donald-trump
1501061401)
460

LuxuryPropertyAd BlitzHeralds Trump Son's Visit to India, Washington Post(Feb. 20 , 2018) (online atwww.washingtonpost.com/business/donald-trump-jr-arrives-in-india-to-help-sell-apartments/2018/02/20/c91141d2
1602-11e8-930c- 45838ad0d77a_storyhtml) .
108

delegation to the Global Entrepreneurship Summit in Hyderabad, India, at the invitation of Prime
Minister Modi, who accompanied her at the event.461

Weeks before Ms. Trump's visit, the Washington Post reported that Donald Trump Jr. wasexpected to travel to India to launch Trump Organization residential projects planned for
Kolkata, in the Indian state of West Bengal, and in Gurgaon , a suburb of New Delhi. Bothprojects had been inked prior to Mr. Trump's election and continued the family's promotion
ofthe Trump empire despite concerns over the president's potential conflicts of interest withforeign governments
The NewRepublicreportedthat clearancesfor the GurgaonTrump Towers wentthroughin no time, based on directivesfrom BJPpartyleaders in New Delhi shortlyafter Ms. Trump's
November2017 visit to the country for the Global EntrepreneurshipSummit.463

Mr. Trump Jr. eventually flew to India in February 2018, where he promoted The Trump
Organization's real estate projects on a multi-city tour that alarmed ethics experts. While in New
Delhi to publicize the Trump-branded residential building in Gurgaon, major Indian newspapers
carried front-page ads featuring photos of Mr. Trump Jr., asking, TRUMP HAS ARRIVED .
HAVE YOU and TRUMP IS HERE . ARE YOU INVITED? According to Politico, His
trip net[ ted] $ 15 million in real estate sales for the Trump Towers in Gurgaon. Notably, Mr.
Trump Jr. also had a closed-door meeting with Prime Minister Modi while on this businesstrip 464
Donald Trump Jr. continued to personally promote the Trump- branded projects in India
throughout his father's presidency. In 2019, he reportedly met with the buyers of residences inTrump Towers Delhi who had been flown to New York City as part of a promotional effort
intended to generate interest in the properties in India.

They stayed at Trump Tower anddined with Trump Jr. at Trump Ferry Point." Politico reported that at least one buyer gushed
about meeting the son of the president.
One attendee told the Telegraph India, It's a dreamcome true , shaking hands with the son of the U.S. president . I am ready to buy one more flat if
they give itme [ sic] at the old price. I am ready to make a single shot payment right now.

The White House, IvankaTrump Advisor to thePresident(accessedSept. 7, 2023) (onlineat
https://trumpwhitehouse.archives.gov/people/ivanka-trump/); IvankaTrump'sIndia VisitRaisesQuestionsAbout
HerBrand, CNBC(Nov.28, 2017) (onlineat www.cnbc.com/2017/11/28/ivanka-trumps-india-visit-raises
questions-about-her-brand.html).
461

462

Trumps Set to Launch Two RealEstate Projects in India, Despite Conflict- of- Interest Concerns,

Washington Post( Oct. 28, 2017) (online at online at www.washingtonpost.com/world/asia_pacific/trumps-set-to
launch- two- real- estate - projects - in- india- despite - conflict- of- interest- concerns / 2017/ 10/ 27/ f7de887c - a2d9-11e7 - b573

8ec86cdfeled_storyhtml) .
Political Corruption and the Art ofthe Deal, New Republic (Mar. 21, 2018) (online athttps://newrepublic.com/article/147351/political-corruption-art-deal ) .
464

Trump Visits a Big Foreign Market for the U.S. andfor Trump Org, Politico (Feb. 22, 2020 ) (online atwww.politico.com/news/2020/02/22/trump-india-business-116322).

465
Brand Trumps Downturn Blues, Telegraph India (Sept. 19 , 2022 ) ( online atwww.telegraphindia.com/business/brand-trumps-downturn-blues/cid/1706834
109).

OpenSecrets reported that , The Trump Organization's successes in India have coincided
largely with Trump's November 2016 election win, and these projects were indeed lucrative for
Mr. Trump during his time in office . Trump Towers Mumbai earned then- President Trump
between $ 1 million and $ 5 million in licensing fees in 2017 alone even before occupants had
been able to move into the building 467 Then - President Trump disclosed that he earned between$ 100,001 to $ 1 million from the project during each of the remaining years of his presidency .
Similarly, he disclosed earning between $ 100,001 and $ 1 million in annual income from DT

468

Tower Kolkata LLC, his licensing entity for Trump Tower Kolkata , on his financial disclosurescovering the first three years of his presidency . Mr. Trump disclosed that during his last year in
office , he earned between $ 50,001 and $ 100,000 from that venture .469
WithMr.Trump's businessesrunningsmoothly in India during his presidency, Mr. Trump
and Mr. Modicontinuedto publiclysupportone anotherand maintaina strong personal
relationship. In September2019, then- PresidentTrump again hostedMr. Modiinthe UnitedStates this time in Houston, Texas, at Howdy, Modi -a mega- rallyattendedby some50,000
IndianAmericans

Monthslater, inFebruary2020, PrimeMinisterModihosted a Namaste,

Trump! rallyinthe city of Ahmedabad at the openingof the world's largestcricket
stadium. 471 Atthis rally, which occurredduringPresidentTrump's first and only visit as

Presidentto India, Modiand Trump who was accompaniedby FirstLady Melania Trump, hisdaughterand AdvisorIvankaTrump, and his son-in- law and SeniorAdvisorJaredKushner—
spoketocheeringcrowd ofmorethan 100,000.

467

OpenSecrets WorldofInfluence: A Guideto Trump's ForeignBusinessInterests(June4 , 2019) ( online).
at www.opensecrets.org/news/2019/06/trump-foreign-business-interests/

468 Office of Government Ethics, Executive Branch PersonnelPublic FinancialDisclosures (OGE Form278e) (Donald J. Trump) (Filed May 15, 2018) (online at https://s3.documentcloud.org/documents/21154685/trumpoge-2018.pdf); Office of Government Ethics, Executive Branch PersonnelPublicFinancialDisclosures (OGE Form278e) (Donald J. Trump ) (Filed May 15, 2019) (online at https://s3.documentcloud.org/documents/21154683/trumpoge-2019.pdf) ; Office of Government Ethics, Executive Branch PersonnelPublicFinancial Disclosures (OGE Form278e) (Donald J. Trump) (Filed July 31, 2020) (online https://s3.documentcloud.org/documents/7012257/President
Donald-Trump-2020-financial-disclosure.pdf) ; Office of Government Ethics, Executive BranchPersonnelPublic
FinancialDisclosures ( OGE Form 278e) (Donald J. Trump ) (Filed Jan. 15, 2021) (online athttps://extapps2.oge.gov/201/Presidennsf/PAS+Index/ 6E78B163F816EF6A852586630075291D/ $FILE/ Trump, 20
Donald 20J 202021Termination 20278.pdf); What We Know About Trump's Business Empire Trump Tower
MumbaiWorli, CNN (2018) ( online at www.cnn.com/interactive/2018/politics/trump-business-empire/?asset=56) .

Id What We Know About Trump's Business Empire Trump DT Tower Kolkata LLC, CNN (2018) (onlineat www.cnn.com/interactive/2018/politics/trump-business-empire/?asset-124 ) ; Trump Visits a Big Foreign Market
for the U.S. and for Trump Org, Politico (Feb. 22 , 2020 ) (online at www.politico.com/news/2020/02/22/trump-india
business - 116322).
470

League ofNationalists ; How Trump and Modi Refashioned the U.S.-Indian Relationship , Foreign
Affairs (Aug. 2020) (online at www foreignaffairs.com/articles/united-states/2020-08-11/modi-india-league
nationalists ).
Namaste Trump : Modi Holds Huge Rallyfor President's Visit, Reuters (Feb. 23, 2020) (online atwww.reuters.com/article/us-india-usa-trump/namaste-trump-modi-holds-huge-rally-for-presidents-visit
idUSKCN2010B6 ) .

IndiaSetto Welcome Trump Whose 1stStop WillBe in Modi's Home State OfGujarat, NPR (Feb.23,
2020) (online at www.npr.org/2020/02/23/807481509/india-set-to-welcome-trump-whose-first-stop-will-be-inmodis-home-state-of-gujar); NamasteTrump India's Modi Welcomes U.S.Leader With anEpic Party, NPR (Feb.
24, 2020) (online at www.npr.org/2020/02/24/808096104/namaste-trump-india-greets-u-s-leader-with-epic-party
110Before becoming Prime Minister , Modi had been chief minister of the state of Gujarat ,where Ahmedabad is located . In 2002 , during Modi's tenure as Gujarat's chief minister , a train
carrying Hindu pilgrims from a religious site was set on fire near Ahmedabad , unleashingsectarian violence in which, reportedly , the official death toll was more than 1,000, including
790 Muslims and 254 Hindus , although the real numbers are believed to be much higher. 473
Atthe2020 rallyin India, then- PresidentTrumppraisedthe specialrelationship that
the UnitedStateshad with India, stating, We think we're at a pointwhere ourrelationshipis so
specialwithIndia. Ithas never beenas good as it is rightnow, and I think that's becauseofthe
two leadersofeachcountry

really we feel very stronglyabouteach other.

Elsewhere during his visit to India, then-President Trump defended Prime Minister Modi
as a proponent of religious freedom, even as violent protests broke out over a controversial
citizenship law championed by the Prime Minister that was widely perceived as anti-Muslim.475
At a news conference during his visit , President Trump said, We did talk about religious
freedom , and I will say that the prime minister was incredible in what he told me. He wants
people to have religious freedom and very strongly
After leaving office, Mr. Trump spoke again ofthe importance of the special relationshiphe developed with India as President . He stated in a 2023 interview,

I think India has never had

a better friend than me . [] And that's one of the relationships that, you know, I've formed.
But India has never had a better friend as President than me. 477

and-modest-policy-aims) ; Departmentof State Office of the Historian, PresidentialTrips to India (online athttps://history.state.gov/departmenthistory/travels/president/india) (accessed Oct. 3, 2023) ; Trump ToursIndiaon
36-hourVisit, USA Today (Feb.24 , 2020) (online at www.usatoday.com/picture
gallery/news/world/2020/02/24/trump-tours-india- 36-hour-visit/4856153002/) .
473.

TheWhite House,Remarksby PresidentTrump and PrimeMinisterModiofIndiain JointPress
Statement(Feb.25, 2020) (online at https://trumpwhitehouse.archives.gov/briefings-statements/remarks-president
trump-prime-minister-modi-india-joint-press-statement-2/) .
ProtestsinNewDelhiAgainstIndia's CitizenshipLawAheadofTrump Visit, Reuters(Feb.23, 2020)(onlineatwww reuters.com/article/us-india-citizenship-protests/protests-in-new-delhi-against-indias-citizenshiplaw-ahead-of-trump-visit-idUSKCN20H0M2) ; Trump PraisesModi'sRecordon ReligiousToleranceas Violence
EruptsOver India's TreatmentofMuslims, WashingtonPost (Feb.25, 2020) (onlineat
www.washingtonpost.com/politics/trump-india-modi-citizenship-law-muslims/2020/02/25/9358aef8-57b5-11ea

ab68-101ecfec2532_story.html). The citizenship law which grants citizenship for refugees of every major South
Asian religion except Muslims
seen by opponents as discriminating against Muslims and undermining
India's secular traditions. DelhiRocked by Deadly Protests During Donald Trump's India Visit, The Guardian(Feb. 25, 2020) (online at www.theguardian.com/world/2020/feb/25/delhi-rocked-by-deadly-protests-during-donald
trumps -india-visit).
476

Trump Praises Modi's Record on Religious Tolerance as Violence Erupts Over India's Treatment of
Muslims, Washington Post (Feb. 25, 2020) (online at www.washingtonpost.com/politics/trump-india-modi
citizenship -law-muslims/2020/02/25/9358aef8-57b5-11ea -ab68-101ecfec2532_story.html ).
PM Narendra Modi Doing A Terrific Job , Says Former US president Donald Trump , Economic Times( Sept. 8 , 2022) ( online at https://economictimes.indiatimes.com/news/india/pm-narendra-modi-doing-a-terrific-job
says - former- us- president- donald - trump/ articleshow / 94081255.cms )EmolumentsPaidby Indiato Trump- OwnedBusinesses

According to documents produced by Mazars to the Committee , the Permanent MissionofIndia to the United Nations owned two units in Trump World Tower in New York which
incurred combined common charges in 2018 of $ 66,046 . Assuming that these charges did notchange over the course of the Trump presidency , this report estimates that India paid at least$264,184 to Trump World Tower during the Trump Administration for these units. Thisestimated total does not include additional charges paid by India in 2018 beyond the baselinecommon fees such as charges for electricity as well as special assessments
and is therefore
almost certainly an underestimate . In 2018the only year for which Mazars provided records

pertaining to these units in addition to the $ 66,046 in common charges , India also paid $ 13,983
in additional charges and fees.478
Inadditionto the emolumentsrecorded in the Mazars records, accordingto a public
disclosuremade by the Indiangovernmentfollowinga records request from a journalist, eight
Indiandiplomats spent $ 18,580 at Trump InternationalHotelin Washington, D.C., inFebruary
479
and March2017.4
Mr.Modi's first and only visit to the White HouseduringTrump's
presidency occurred in June 2017.4
480 A documentprovided to the Committee by Mazars shows
the Embassyof India had an account at a Trump- ownedproperty with a start date of
03/07/2017 but the documentdoes not show the dates or charges for stay( s) associated with
481
Giventhat documentation
this account ( or even the propertywhere the stay(s) occurred) .
from the Indiangovernmentconfirmingexpenditures byIndiaat the Trump InternationalHotelin Washington, D.C., is publicly available and that an account for the Embassyof India is noted
in a documentproduced to the Committeeby Mazars this report includesthe sum disclosedby
the Indian governmentinthe total amount of the emoluments paid by Indiato then- President
Trump.

478 MAZARS-OVERSIGHT_COMMITTEE -00027355 to MAZARS -OVERSIGHT_COMMITTEE

00027886 ;New York City Department of Finance, Document ID: 2003010601397001 (online at https://a836
acris nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2003010601397001 ) (accessed Oct. 2, 2023).
479
Trump's D.C. Hotel Hosted Diplomats from These 33 Countries , Forbes (Oct. 10,2021) (online atwww.forbes.com/sites/zacheverson/2021/10/10/trumps-dc-hotel-hosted-foreign-officials-from-these-33-countries

while -he-was-in-office ); Aroon Deep @AroonDeep , X (Feb. 18 , 2018) (online athttps://twitter.com/AroonDeep/status/966853259041308673) . Mr. Deep's post on X states that the total amount of

the stay by the Indian diplomats at the Trump International Hotel was $ 18,650 ; however , the document provided in
the X post records expenditures totaling only $ 18,580 and that is the figure provided in this report.
480

Trump and Modi Reaffirm Indian- US Relations with a Hug, CNN (June 27, 2017) (online atwww.cnn.com/2017/06/27/politics/modi-trump-india-us/index.html ) ; Department of State Office of the Historian,
Visits by Foreign Leaders ofIndia ( online at https://history.state.gov/departmenthistory/visits/india ) (accessed Oct.
3 , 2023) .

481 MAZARS- OVERSIGHT_COMMITTEE- 00008041.

112

PHILIPPINESInJune 2018, while the President of the Philippines was seeking a free-trade deal with theUnited States, the country's Embassy held its National Day Reception at the Trump International
Hotel in Washington , D.C. The Embassy of the Philippines paid nearly $ 75,000 for the
reception a move that the Philippine Ambassador to the United States acknowledged hadpolitical undertones . 482
At the time , then -President Trump showed his eagerness to foster a friendly relationshipwith the then- President of the Philippines , Rodrigo Duterte. President Trump repeatedly praised
Duterte , even as the authoritarian ruler was accused of orchestrating the extrajudicial killings ofthousands of Filipino citizens.483

In addition , Mr. Trump maintained a financial stake in a Trump - branded apartmentcomplex in Manila that earned him millions of dollars while he was President
Philippines EmolumentSpendingat TrumpProperties

Date

Location

Expenditure

AmountJune 12, 2018

Trump InternationalHotel(Washington, D.C.)

Embassy ofthe
Philippines National Day
Reception$ 74,81048

485

Trade Negotiations with the Philippines

In the days before Mr. Trump's election in November 2016 , then -Philippine President
real estate

Duterte selected an individual with close ties to Mr. Trump , Jose E.B. Antonio-

developer and Trump's business partner in Manila —as his trade envoy to Washington . At thetime , Mr. Antonio's company was building a Trump - branded apartment complex in Manila ,which would generate significant income for Mr. Trump during his time in office.486
Then- President Duterte hoped to negotiate a free- trade agreement with the United Statesthat would have allowed the Philippines to expand the markets for its exports. This proposed

482 MAZARS- OVERSIGHT_COMMITTEE-00008504; Jose Manuel Romualdez, Our Special 120th
IndependenceDay DC Celebration, Philippine Star (Apr. 22, 2018) (online atwww.philstar.com/opinion/2018/04/22/1808198/our-special-120th-independence-day-dc-celebration).

Trump Praises Duterte for Philippine Drug Crackdown in Call Transcript , New York Times (May 23,2017) (online at www.nytimes.com/2017/05/23/us/politics/trump-duterte-phone-transcript-philippine-drugcrackdown html).
483

484

Long- Concealed Records Show Trump's Chronic Losses and Years ofTax Avoidance, New York Times(Sept. 27, 2020) ( online at www.nytimes.com/interactive/2020/09/27/us/donald-trump-taxes.html).

485 MAZARS-OVERSIGHT_COMMITTEE -00008504 ; MAZARS-OVERSIGHT_COMMITTEE

00027271.

486

Trump Business Partner is Philippines New Trade Envoy to U.S., New York Times (Nov. 9 , 2016)( online at www.nytimes.com/2016/11/10/world/asia/donald-trump-philippines-jose-antonio
113html) .

deal was intended to build on the existing trade relationship between the countries ,whose two
way trade totaled $ 27 billion in 2016. At the time, approximately 75% of exports from thePhilippines already entered the United States duty-free.
487

InNovember 2017, then-President Duterte spoke directly with then-President Trump
about a potential free-trade agreement during a private meeting in Manila while Mr. Trump wasin the Philippines for the Association of Southeast Asian Nations summit.488 A spokesperson forthen-President Duterte said : The Philippine side expressed their hope that an FTA or free trade
A joint
agreement must be concluded between the Philippines and the United States.
statement from Mr. Trump and Mr. Duterte confirmed that both leaders discussed their interests
in a possible free-trade agreement: The United States welcomed the Philippines interest in abilateral free trade agreement and both sides agreed to discuss the matter further through theUnited States-Philippines [ Trade and Investment Framework Agreement
Mr. Antonio was.491
discussion
duringthispresentalso
Human Rights Violations

While then- President Trump was discussing a possible trade deal with the Philippines ,then- President Duterte was being widely condemned on the world stage for human rights
violations, particularly his violent crackdown on illegal drugs that involved the extrajudicial andarbitrary killings of thousands of alleged drug suspects . Mr. Trump not only failed to condemn
the authoritarian ruler for his brutal practices , but actually congratulat [ ed] Mr. Duterte for thegovernment - sanctioned attacks on drug suspects .
During an April 2017 phone call, Mr.
492

Trump told Mr. Duterte that he was doing an unbelievable job on the drug problem and invited
him to the White House making a powerful gesture to the authoritarian ruler that reportedly
stunned even Mr. Trump's own aides.

Following his November 2017 meeting with Mr.

Duterte in Manila, during which the leaders discussed trade policy, then- President Trump told

487

Philippines, U.S. to Start FreeTrade Talks in September, Reuters (July 12, 2018) (online atwww.reuters.com/article/uk-philippines-usa-trade/philippines-u-s-to-start-free-trade-talks-in-september
idUKKBN1K20XW
) .
488

.

Officeofthe President ofthe Philippines PresidentialCommunications Office, Press Release: Duterte,
Trump TalkAbout Free Trade, IllegalDrugs, Marawi Aid (Nov. 13, 2017) ( online athttps://pco.gov.ph/news_releases/duterte-trump-talk-free-trade-illegal-drugs-marawi-aid/).

The American Presidency Project,Joint Statement by President Trump and President Rodrigo Duterteofthe Philippines (Nov. 13, 2017) (online at www.presidency.ucsb.edu/documents/joint-statement-president-trump
and- president - rodrigo -duterte -the-philippines ).
491

Trump Lauds Great Relationship' with Duterte in Manila, New York Times (Nov. 13, 2017) (online atwww.nytimes.com/2017/11/13/world/asia/trump-duterte-philippineshtml) .

Trump Praises Duterte for Philippine Drug Crackdown in Call Transcript , New York Times (May 23,2017) (online at www.nytimes.com/2017/05/23/us/politics/trump-duterte-phone-transcript-philippine-drugcrackdown html).
492

Id Trump's

Very Friendly Talk with Duterte Stuns Aides and Critics Alike, New York Times (Apr.

30, 2017) ( online at www.nytimes.com/2017/04/30/us/politics/trump-duterte
114html) .

reporters that he and the Philippine president had agreat relationship, while avoiding questions

from the press about Mr.Duterte's record of human rights abuses.494
EmolumentsPaidby the Philippinesto Trump- OwnedBusinesses

InApril2018, amidthen-PresidentDuterte'scontinuedpushfor a free-trade agreement,
the Philippinesannouncedthat it would hold its IndependenceDayreceptionat the Trump
495
InternationalHotelin Washington, D.C., in June ofthat year.
Accordingto a receiptproduced
496

tothe Committeeby Mazars, the Embassyofthe Philippinespaid $ 74,810 for the reception.
The PhilippineAmbassadorto the United States, Jose ManuelRomualdez, explicitly

acknowledgedthat then- PresidentTrump's ownershipofthe hotelfactored into his decisionto
holdthe event at the hotel:

The Trump hotel may have some political undertones because it is associated with the
U.S. president, but since several other embassies have also held their national day
celebrations at the Trump hotel which were well attended
decided why not do it
there, too.497
OnJuly 12, 2018, one monthto the day after the Philippines June 12, 2018, receptionat
Trump InternationalHotelin Washington, D.C., Mr. Romualdezannouncedthat the Philippines
wouldbeginnegotiatinga proposedfree trade deal with the UnitedStates in September2018,
which he said couldtake years to complete.4

The Trump Administrationultimatelydid not499

enter into a free- trade agreementwith the Philippines.

494

Trump Lauds Great Relationship' with Duterte in Manila, New York Times ( Nov. 13, 2017) (online atwww.nytimes.com/2017/11/13/world/asia/trump-duterte-philippineshtml) .
495

Philippines Latest Foreign Country to Book Trump's DCHotel, Associated Press (Apr. 18, 2018)(online at https://apnews.com/article/philippines-north-america-donald-trump-turkey-politics
9d68161fe26f44638cd74cbla943501e ). While Democratic criticism was aimed at the Generalized System ofPreference governing U.S. trade with the Philippines, rather than the FTA sought by Duterte, it was nonethelessapplicable to consideration of liberalizing trade with the Philippines given the country's human rights record at thetime.
496 MAZARS- OVERSIGHT_COMMITTEE - 00008504 .

Jose ManuelRomualdez, OurSpecial120thIndependenceDayDCCelebration, PhilippineStar(Apr.
22, 2018) (onlineat www.philstar.com/opinion/2018/04/22/1808198/our-special-120th-independence-day-dc
celebration); CheckingInatTrump Hotels, forKinship(andMaybeSome Sway), New YorkTimes (Sept.7, 2019)(onlineatwww.nytimes.com/2019/09/07/us/politics/trump-hotel.html).
Philippines, U.S. to Start Free Trade Talks in September , Reuters (July 12, 2018 ) (online atwww.reuters.com/article/uk-philippines-usa-trade/philippines-u-s-to-start-free-trade-talks-in-september).
idUKKBN1K20XW
499

See Free Trade Agreements , Office of the U.S. Trade Representative ( accessed Sept. 18, 2023 ) (online

at https://ustr.gov/trade-agreements/free-trade-agreements ) .
115

Trump Business Entanglements in the Philippines

Inaddition to the emolument from the Philippines government for its Independence Day
event, then-President Trump received millions of dollars during his presidency from the Trump
500
Tower Manila apartment building, which opened in 2017.5
Precisely how much Mr. Trump earned from the project while he was President is notclear As the New York Times found in 2020 , it appears that then- President Trump underreported
his income from the Manila apartment complex in his financial disclosures . The low end offormer President Trump's disclosed income for the project was $ 4.1 million, but this was lessthan half ofthe $ 9.3 million he actually made, according to the publication's analysis of tax
documents it had obtained exclusively . The New York Times also reported that in 2017 and 2018
501
alone, he earned $3 million from the development .

Another troubling aspect of the project was when then-President Trump's image wasused to promote the Manila tower project after he took office despite assurances from The
Trump Organization that such overseas marketing campaigns would be halted during his
presidency . According to the Washington Post, a video advertisement that included images of
the President playing golf and also featured Ivanka Trump , then a White House Advisor
promising that residents would live and breathe luxury at the Manila Tower remained available
on a YouTube account tied to the project's developer as of May 2017. Promotional materials
that featured pictures of and a quote from Trump , as well as photographs of Ivanka Trumpwere on hand at the development company's sales center in Manila at this time . As the
Washington Post observed , The Trump Tower Manila shows why Trump can never truly
separate himself from his brand .
This disturbing episode followed a similar marketing
campaign for a Trump project in India. Both demonstrated Donald Trump's unabashedwillingness to do business as president .

500

Long- Concealed Records Show Trump's Chronic Losses and Years ofTax Avoidance, New York Times( Sept.27, 2020) (online at www.nytimes.com/interactive/2020/09/27/us/donald-trump-taxes.html) ; Trump's 10
TroublingDealswith Foreign Power- Players, ProPublica and USA Today (Jan. 19, 2017) (online athttps://projects.propublica.org/trump-conflicts/
).

501

.
The Trump Tower Manila Shows Why Trump Can Never Truly Separate Himselffrom His Brand,

Washington Post (June 13, 2017) (online at www.washingtonpost.com/world/asia_pacific/the-trump-tower-manila

shows-why-trump-can-never-truly-separate-himself-from-his-brand/2017/06/12/28701dfe -3a46-11e7-a59b

26e0451a96fd_story.html); Pitchfor Trump Tower Mumbai Plays Up Connection to Donald Trump,Wall Street

Journal (July 26, 2017) (online at www.wsj.com/articles/pitch-for-trump-tower-mumbai-plays-up-connection-to
donald-trump-1501061401).
116

MALAYSIAInSeptember 2017, then- President Trump hosted then-Prime Minister of Malaysia, Najib
Razak, for an official visit at the White House.
At the time, the DOJ was seeking to recover
more than $ 1 billion in assets that had been stolen from a Malaysian government investment
fund co- founded and managed by Mr. Razak in one ofthe largest global corruption scandals to
date
The Prime Minister and numerous Malaysian officials stayed at the Trump International
Hotel in Washington, D.C., during the official visit . Officials would return to the hotel for an
additional stay later that month . Their room charges and amenities totaled $248,962 for themonth of September
505 Itwas widely reported that, as part of a broader corruption
investigation , Prime Minister Razak was under scrutiny by the DOJ at the time he was invited to
the White House.506 Commentators noted that then-President Trump's decision to welcome
Prime Minister Razak anyway could have been seen as lending credibility to Mr. Razak, who
was required to call a general election no later than mid-2018 and was expected to run for reelection.507
Malaysia'sEmolumentSpendingat TrumpProperties

Location

Date

September7-15,

Expenditure

Trump InternationalHotel

2017(Washington, D.C.)

Stay by former Prime

Amount$247,352508

MinisterNajib Razak andother senior government
officials

September 27, 2017

Trump InternationalHotel( Washington, D.C.)

Embassy of Malaysia$1,610509

Delegation

EMOLUMENTS PAID BY MALAYSIA$ 248,962( 2017-2020 )Trump Welcomes Najib Razak, the Malaysian Leader, as President, and Owner ofa Fine Hotel,New
York Times (Sept. 12, 2017) (online at www nytimes.com/2017/09/12/world/asia/trump-najib-razak-malaysia
white -house html).
503

504

MalaysianLeader, UnderCorruptionCloud, Will Meetwith Trump, NewYork Times ( Sept.9 , 2017)( onlineatwww.nytimes.com/2017/09/09/world/asia/malaysia-najib-razak-1mdb
html) .
505 MAZARS- OVERSIGHT_COMMITTEE - 00008052 to MAZARS- OVERSIGHT_COMMITTEE
00008094 .

506

Trump Welcomes Najib Razak, the Malaysian Leader, as President, and Owner ofa Fine Hotel, NewYork Times ( Sept. 12, 2017 ) (online at www nytimes.com/2017/09/12/world/asia/trump-najib-razak-malaysia
white -house html); Trump To Meet Malaysia's Leader As Probe Against Him Deepens , NPR (Sept. 12, 2017)(online at www.npr.org/2017/09/12/550352981/trump-to-meet-malaysias-leader-as-probe-against-him-deepens).
507

Trump Meeting with Malaysian Prime Minister Comes Under Scrutiny , PBS News Hour (Sept. 12,2017) (online at www.pbs.org/newshour/world/trump-meeting-malaysian-prime-minister-comes-scrutiny ) ; Trump
Meets with Malaysia's Prime Minister, NBC News ( Sept. 12, 2017) (online at www.nbcnews.com/news/us
news/ trump-meet- malaysia -s- prime -minister-n800601) .

508 MAZARS-OVERSIGHT_COMMITTEE -00008052 to MAZARS-OVERSIGHT_COMMITTEE
00008094 ; MAZARS-OVERSIGHT_COMMITTEE -00008012 .
509 MAZARS- OVERSIGHT_COMMITTEE- 00018425.
117

1MalaysiaDevelopmentBerhad CorruptionScandal

September 12, 2017, then- Prime Minister Razak visited then- President Trump at theWhite House. At the time of the meeting, it was publicly known that Mr. Razak and members of
his family were under investigationby the DOJ in connection with the now notorious corruption
scandal involvingthe misappropriationof billions of dollars from a Malaysian sovereign wealthfund called 1Malaysia Development Berhad ( 1MDB) . 510 Mr. Razak had been under unrelentingpressure at home ahead of his anticipated re- election campaign, according to the New York
511 The Center forTimes, which described the White House visit as a major victory for him.5
Strategic and International Studies similarly noted that no Malaysian Prime Minister had visitedthe White House since 2004 and explained that :] he Malaysian prime minister will likely be happy ifhis visit demonstrates back in
Malaysia where he faces elections before August 2018 that the U.S. investigation isreally a relatively minor issue and that he can still be welcomed into Trump's Oval Office
as an important Southeast Asian leader 512

Bythe time thetwo leadersmet, theinvestigationinto 1MDB which would
become its largestever kleptocracy case had beenunderwayfor more than a year.513 The
allegedthat Mr. Razakand others associated with the fund had illegally siphoned offmore
than $3.5 billion from 1MDB beginningnot longafter it was createdin2009 shortly after Mr.
Razak, a co-founder of the fund, took office.514 Itwould later be found that morethan $4.5
billionhad beenstolen from 1MDB, which the DOJdetermined to have been launderedthroughshell companies and financial institutionsworldwide, many of which were inthe United
515
States510

Trump MeetsMalaysia Leader UnderInvestigationby His Justice Department, CNN (Sept. 12, 2017)(online at www.cnn.com/2017/09/12/politics/trump-malaysia-prime-minister/indexhtml) .
511

Trump Welcomes Najib Razak, the Malaysian Leader, as President, and Owner ofa Fine Hotel, NewYork Times (Sept. 12 , 2017) (online at www nytimes.com/2017/09/12/world/asia/trump-najib-razak-malaysia
white -house html) ; Malaysian Leader, Under Corruption Cloud, Will Meet with Trump , New York Times (Sept. 9,2017) (online at www.nytimes.com/2017/09/09/world/asia/malaysia-najib-razak-1mdb.html ).

Centerfor Strategic and InternationalStudies, Trump-Najib Meeting Gives Malaysia-U.S. RelationsShot
ofAdrenaline(Sept. 14, 2017) (online at www.csis.org/analysis/trump-najib-meeting-gives-malaysia-us-relations
shot-adrenaline).
513

Explainer: Malaysia's Ex-PM Najib And the Multi-Billion Dollar
Scandal, Reuters (Aug. 23,2022) (online at www.reuters.com/world/asia-pacific/malaysias-ex-pm-najib-multi-billion-dollar-1mdb-scandal
2022-08-23 ; Malaysian Leader, Under Corruption Cloud, Will Meet with Trump , New York Times ( Sept. 9, 2017)( online at www.nytimes.com/2017/09/09/world/asia/malaysia-najib-razak-1mdb.html ) .
514

Complaint, UnitedStatesofAmericav. The Wolfof WallStreet MotionPictureetc., No.CV 16-16
5362 (C.D.Cal. July 20, 2016) (online at www.justice.gov/archives/opa/page/file/877166/download); Former
MalaysianLeaderto ServePrison Term After FinalAppealIs ThrownOut, CNN(Aug.23, 2022) (onlineat
www.cnn.com/2022/08/23/asia/malaysia-najib-razak-prison-intl/indexhtml) .
515

Department of Justice, Press Release: Over $ 1Billion in MisappropriatedFundsNow
Repatriated to Malaysia (Aug. 5, 2021) (online at www.justice.gov/opa/pr/over-1-billion-misappropriated-1mdb
funds-now-repatriated-malaysia) ; IMDB Scandal Explained: A Tale of Malaysia's Missing Billions, The Guardian(July 28,2020 ) (online at www.theguardian.com/world/2018/oct/25/1mdb-scandal-explained-a-tale-of-malaysias
missing-billions ).

118

Beginning in 2016, the DOJ filed 41 civil forfeiture actions in an effort to recoverthe
more than $ 1 billion in stolen 1MDB assets that were known to have been launderedin violation
ofU.S.law.

the assets the DOJ identified as having been laundered at the time , more than

$ 730 millionhad allegedly been deposited into accountsthat belonged to Mr. Razak, who was
not named in the DOJ's case but was referencedas Malaysian Official 1

in its complaints. The

billions in stolen funds were allegedly used to purchase fine art, a yacht, and luxuryAmerican
properties, and even to invest in the film The Wolf of Wall Street." This was quite plainly far
from the intended purpose ofthe sovereign wealth fund, which the DOJpointed out wasostensiblycreated
for the economic benefit ofthe Malaysianpeople. 517 The DOJalso
brought several highly-publicized criminal actions against individuals and a financial institution
based on their participation in the scheme.518

Against the backdrop of the 1MDB scandal , then-Prime Minister Razak used his
September 2017 meeting with President Trump to paint a positive picture of the country's
investments inthe United States, which garnered praise from Mr. Trump . Mr. Razak braggedthat a Malaysian pension fund and a sovereign wealth fundseparate from the one he was

accused oflooting were investing billions of dollars in the U.S. economy. Then-President
Trump , in turn, said it was a great honor to host Mr. Razak and his very distinguisheddelegation as Malaysia is a massive investor inthe United States in the form of stocks andbonds.

The pair avoided any mention of the then-pending DOJ investigation.519
Malaysian Human Rights Violations

Atthe time ofthe September 2017 meetingwith then-PresidentTrump, then-Prime
Minister Razak's human rights record was also under scrutiny. By 2017, Mr. Razak had become
an increasinglyautocratic ruler, with HumanRights Watch decryingthe increasedarrests of516

Department of Justice, Press Release: Over $ 1Billion in MisappropriatedFundsNow
Repatriated to Malaysia (Aug. 5, 2021) (online at www.justice.gov/opa/pr/over-1-billion-misappropriated-1mdb
funds-now-repatriated-malaysia ).
517
Complaint, United States ofAmerica v. The Wolfof Wall Street Motion Picture etc., No. CV 16-16
5362 (C.D. Cal. July 20, 2016) (online at www.justice.gov/archives/opa/page/file/877166/download ); Malaysian
Leader, Under Corruption Cloud, Will Meet with Trump , New York Times (Sept. 9, 2017) (online atwww.nytimes.com/2017/09/09/world/asia/malaysia-najib-razak-1mdb.html ); Explainer : Malaysia's Ex-PM Najib
and the Multi-Billion Dollar
Scandal, Reuters (Aug. 23 , 2022) (online at www.reuters.com/world/asia
pacific/ malaysias -ex- pm- najib - multi-billion-dollar- 1mdb-scandal-2022-08-23/).
518

Department of Justice, Press Release: Former Goldman Sachs InvestmentBanker Convictedin Massive
BriberyandMoney Laundering Scheme (Apr. 8, 2022) (online at www.justice.gov/usao-edny/pr/former-goldman
sachs-investment- banker-convicted-massive-bribery-and-money-laundering); Department ofJustice, Press Release:
Goldman Sachs Charged in Foreign Bribery Case andAgrees to Pay Over $2.9 Billion (Oct. 22, 2020) (online atwww.justice.gov/opa/pr/goldman-sachs-charged-foreign-bribery-case-and-agrees-pay-over-29-billion).

Trump Welcomes Najib Razak, the Malaysian Leader, as President, and Owner ofa Fine Hotel, NewYork Times (Sept. 12, 2017) (online at www nytimes.com/2017/09/12/world/asia/trump-najib-razak-malaysia
white-house html); From Trump HotelLobby to White House, Malaysian Prime Minister Gets VIPTreatment,
Washington Post (Sept. 12, 2017) (online at www.washingtonpost.com/politics/from-trump-hotel-lobby-to-whitehouse-malaysian-prime-minister-gets-vip-treatment/2017/09/12/1b296f54-97d1-11e7-87fc
519

c3f7ee4035c9_story.html).

119government critics, expanded restrictions on peaceful assembly, and continued impunity forpolice abuses in Malaysia.³
520 Inparticular, then- Prime Minister Razak was jailing individuals
who commentedon the 1MDBscandal. Human Rights Watch found:Throughout 2016 , Malaysian authorities used the Communications and Multimedia Act( CMA) and the Sedition Act to arrest those criticizing the administration of Prime
Minister Najib Razak , commenting on the government's handling of the 1 Malaysia
Development Berhad ( 1MDB ) corruption scandal, or making comments on social media
deemed insulting to Najib or to Malaysia's royalty.521

Experts and human rights groups warned that then-Prime Minister Razak's visit to theWhite House was a public relations coup for him, with one commentator noting that Mr. Razak
can tell Malaysians that the 1MDB is a non-issue and that the opposition's message that he isunwelcome by world leaders is not true, while another predicted that Najib will use this WhiteHouse visit to burnish his credentials going into next year's election in Malaysia, and redouble
his repression ofcritics using the stamp of approval from this visit . 522
Emoluments
Paidby Malaysiato Trump- OwnedBusinesses

Inthe days before and after the White House meeting , from September 7 , 2017 , toSeptember 15, 2017 , a Malaysian delegation including then -Prime Minister Razak stayed at the
Trump International Hotel in Washington , D.C. , and were charged a direct bill of $ 247,352 .
Mr. Razak stayed in the hotel's presidential suite , which was billed at $ 10,000 per night. Costs
accrued by then -Prime Minister Razak alone totaled $44,562 over three nights and four days.5

523Part ofthe bill for Mr. Razak's stay is excerpted below 524
509

80965866-1

Razak , Mr. Najib Tun Abdul

09/12/2017 101000

Room Charge

09/12/2017 723207

DC Occupancy Sales Tax

09/12/2017 101800

MiscellaneousRooms$ 10,000.00
1,450.00

Furniture Movement (Dressing Room ) for embassy of Malaysia$ 750.00

201709121328075278 227104/ 0024/ 0024/ 5278
/ 0000/ Lunch1,027.40

charge per
09/12/2017 723207

OccupancySales Tax

09/12/2017 853201

In RoomDining Lunch

09/12/2017 851200

In RoomDiningF & B Tax
10%

09/12/2017 851200

In RoomDiningF & B Tax
10%

09/12/2017 853201

In Room Dining Lunch$ 108.75

93.40(

201709121329555288 227104/ 0024/ 0024/ 5288
/ 0000/ Lunch93.40

1,375.00

520 HumanRights Watch, Malaysia: RightsDeclineUnderNajib (Jan. 12, 2017) ( online atwww.hrw.org/news/2017/01/12/malaysia-rights-decline-under-najib
) .

521

.

522

Trump Meeting with Malaysian Prime Minister Comes Under Scrutiny , PBS News Hour ( Sept. 12,2017) (online at www.pbs.org/newshour/world/trump-meeting-malaysian-prime-minister-comes-scrutiny ) ; Trump
Meets with Malaysia's Prime Minister, NBC News ( Sept. 12, 2017) (online at www.nbcnews.com/news/us
news/trump -meet- malaysia -s- prime-minister-n800601) .
523 MAZARS- OVERSIGHT_COMMITTEE- 00008052 to MAZARS- OVERSIGHT_COMMITTEE
00008094

524 MAZARS- OVERSIGHT - COMMITTEE - 00008081 .

120

Among the numerous charges for amenities Mr. Razak accruedduring his stay atthe
Trump InternationalHotelwere a $ 750 charge for Furniture Movement(Dressing Room) and acharge of$ 1,500 for a PersonalTrainer. Mr. Razak also spent thousands of dollars to have abutler assistin servingmultiplemeals.525 The Malaysiandelegation's lavish spending inmid
September2017 at the Trump InternationalHotelcaused a 70% jump inthe hotel's averagenightly roomrevenue increasingto $97,193 for the nights of September7 through September
14 comparedto $56,635 for other nights in September2017.526
Later that same month, on September 27, 2017, theEmbassy of Malaysia Delegation

would return to the hotel and rent an additional four rooms at a cost of $ 1,610.527

Adding to the hotel's revenue during the Malaysian delegation's mid- September stay was$9,272 that was spent by the U.S. Secret Service on rooms for the detail assigned to protect thedelegation . The Secret Service's room block included multiple rooms that were booked at $ 650
per night more than double the government's $ 231 per diem lodging rate for Washington ,528
Lobbyist Spending

Inaddition to Malaysian government officials , Elliott Broidy, a former top fundraiser for
Mr. Trump who was lobbying the Trump Administration on behalf of Malaysian interests as an
unregistered foreign agent, also stayed at the Trump International Hotel four times during
September 2017, including four nights during a Malaysian delegation's visit in mid-September,and again on the night of September 27, when a Malaysian delegation again stayed at theproperty . Intotal, Mr. Broidy was charged $5,345 for rooms at the Trump International Hotelduring September 2017.529 His associate, Nickie Lum Davis, who was working with him on
behalfof Malaysia, also stayed at the hotel during part of the Malaysian delegation's mid
September stay and was charged $ 1,155 for her stay.5
530

525

.

526 MAZARS- OVERSIGHT_COMMITTEE- 00018254 to MAZARS- OVERSIGHT_COMMITTEE
00018452

527 MAZARS- OVERSIGHT_COMMITTEE - 00018425

528

MAZARS-OVERSIGHT COMMITTEE-00018309; MAZAR-OVERSIGHT COMMITTEE
00018318 MAZARS-OVERSIGHT_COMMITTEE-00018337; General Services Administration, FY17Per Diem
Rates (online at www.gsa.gov/travel/plan-book/per-diem-rates/per-diem-files) . Expendituresby the U.S. Secret
Servicehavebeenredactedfrom the documents madepublic with this report out of an abundance of caution given
the sensitivity of such information.
Elliott Broidy Pleads Guilty in Foreign Lobbying Case, New York Times, Oct. 20, 2020 (online atwww.nytimes.com/2020/10/20/us/politics/elliott-broidy-foreign-lobbying.html ); Department of Justice, Press
Release: Elliott Broidy Pleads Guiltyfor Back-Channel Lobbying Campaign to Drop
Investigation andRemove a Chinese ForeignNational (Oct. 20, 2020) (online at www.justice.gov/opa/pr/elliott-broidy-pleads-guilty
back-channel-lobbying-campaign-drop- 1mdb-investigation-and); MAZARS -OVERSIGHT_COMMITTEE
00018254
to MAZARS- OVERSIGHT_COMMITTEE- 00018452.

MAZARS - OVERSIGHT_COMMITTEE - 00018303 ; MAZARS - OVERSIGHT_COMMITTEE

00018311 MAZARS-OVERSIGHT_COMMITTEE-00018320; Department of Justice, PressRelease: Hawaii
BusinesswomanPleads Guilty to FacilitatingBack-Channel LobbyingCampaign to Drop
Investigationand
Removea ForeignNationalto China (Aug. 31, 2020) (online at www.justice.gov/opa/pr/hawaii-businesswoman
121

Mr. Broidy was also being paid millions by Malaysian financier Low Taek Jho, a fugitive
whom the DOJ has charged with orchestrating the 1MDB scheme , to lobby the Trump
Administration to close the investigation into 1MDBarrangement Mr. Broidy concealed
from authorities.531 In October 2020, Mr. Broidy pled guilty to conspiring to violate FARA inconnection with his undisclosed lobbying work for Malaysia.
As ofthe date of this report, Mr.
Low remains a fugitive after being charged in Malaysia and the United States for his alleged rolein the 1MDB scheme.533
Thepress release announcing Mr. Broidy's guilty plea detailed his efforts topersuade the Trump Administration to end its 1MDB investigation, noting that Mr. Broidy had,among other actions , provided talking points to the Secretary of State referencing the 1MDB
investigation in advance of a meeting between the Secretary of State and the Malaysian Prime
Minister in August 2017 , the month before Mr. Razak's visit with President Trump . The press
release further explained that Mr. Broidy had pushed the White House Chief of Staff for a golf
game between the President and the Malaysian Prime Minister to allow the Malaysian Prime
Minister to raise [ a] resolution of the 1MDB investigation .
InAugust2020, Ms. Lum Davisalso pled guilty for her roleinfacilitatingthe
unregisteredlobbyingcampaignto end the 1MDBinvestigation, for whichshe too was paid
millions of dollars.

The effort by Mr. Broidy and his Malaysian co-conspirators to end the DOJ's pursuit of
the 1MDB funds ultimately failed . As ofAugust 2021, the DOJ had successfully repatriatedmore than $ 1.2 billion to the Malaysian people .
The Malaysian government prosecuted Mr.

pleads - guilty- facilitating- back - channel - lobbying - campaign- drop - 1mdb) .

lineatElliottBroidyPleadsGuiltyin ForeignLobbyingCase, NewYork Times (Oct.20, 2020)www.nytimes.com/2020/10/20/us/politics/elliott-broidy-foreign-lobbying.html); Malaysiain Talks to BringBack-LinkedFugitiveJhoLow, Reuters (May 5 , 2023) (onlineat www reuters.com/world/asia-pacific/malaysia
talks-bring-back- 1mdb- linked-fugitive-jho-low-pm-2023-05-05 .
Department of Justice, PressRelease: Elliott BroidyPleads Guilty for Back- ChannelLobbying
Campaignto Drop IMDBInvestigationand Remove a Chinese Foreign National (Oct. 20 , 2020) (online atwww.justice.gov/opa/pr/elliott-broidy-pleads-guilty-back-channel-lobbying-campaign-drop-1mdb-investigation
and) .

MalaysiainTalks to BringBack 1MDB-LinkedFugitiveJho Low, Reuters (May 5, 2023) (online atwww.reuters.com/world/asia-pacific/malaysia-talks-bring-back-1mdb-linked-fugitive-jho-low-pm-2023-05-05/);
ElliottBroidyPleads Guilty in ForeignLobbying Case, New York Times ( Oct. 20, 2020) (onlineat
www.nytimes.com/2020/10/20/us/politics/elliott-broidy-foreign-lobbying.html).
534

DepartmentofJustice, Press Release: ElliottBroidy Pleads Guilty for Back- Channel Lobbying

Campaignto Drop IMDBInvestigationandRemove a Chinese Foreign National (Oct. 20, 2020) (online atwww.justice.gov/opa/pr/elliott-broidy-pleads-guilty-back-channel-lobbying-campaign-drop-1mdb-investigation
and) .

DepartmentofJustice, Press Release: HawaiiBusinesswoman Pleads Guilty to FacilitatingBack
ChannelLobbying Campaignto Drop
Investigation and Remove a Foreign National to China (Aug. 31,
2020) (online at www.justice.gov/opa/pr/hawaii-businesswoman-pleads-guilty-facilitating-back-channel-lobbying
535

-

-

campaign drop 1mdb)
536.

Department of Justice , Press Release : Over $ 1 Billion inMisappropriatedFunds Now

Repatriated to Malaysia ( Aug. 5 , 2021) ( online at www.justice.gov/opa/pr/over-1-billion-misappropriated-1mdb
122

Razak for his role in the 1MDBscandal, and in August 2022, he was ordered to begin servinga
12-year prison sentence for his convictionon criminalcharges related to 1MDB. Accordingto
Reuters, officials in Malaysia found that Razak ultimately receivedmore than $ 1 billion
traceable to 1MDB.

PresidentTrump pardonedMr. Broidyshortly beforeleavingoffice.
Ms.

He did not pardon

Davis, who was sentencedto two years in prisoninJanuary2023.539

funds - now - repatriated - malaysia) .

537

Explainer: Malaysia's Ex-PMNajib and the Multi-BillionDollar
Scandal, Reuters (Aug.23,2022) (onlineat www.reuters.com/world/asia-pacific/malaysias-ex-pm-najib-multi-billion-dollar-1mdb-scandal
2022-08-23
With HoursLeftinOffice, TrumpGrantsClemencyto Bannonand OtherAllies, NewYork Times( May2021) ( onlineat www.nytimes.com/2021/01/20/us/politics/trump-pardonshtml) .
539

DepartmentofJustice, Press Release: BusinesswomanSentencedfor FacilitatingUnregistered

LobbyingCampaign in Exchangefor Approximately $ 3 Million (Jan. 19, 2023) (online atwww.justice.gov/opa/pr/businesswoman-sentenced-facilitating-unregistered-lobbying-campaign-exchange
approximately - 3 ) .

123

TURKEY

Donald Trump entered the presidency with significant and lucrative existing businessinterests in Turkey . Moreover , the records produced to the Committee by Mazars indicate thatafter the Trump presidency began, the Turkish government repeatedly patronized Trump- owned
properties in the United States . For two expenditures made by Turkey

both in May 2017

records provided by Mazars fail to show the specific dates , purposes , or amounts of theexpenditures . Notably, these expenditures coincided with a visit by the Turkish President , Recep
Tayyip Erdo an, to the White House to meet with President Trump . Separately , the Mazars
records show that the Governor ofthe Central Bank of Turkey stayed at the Trump International
Hotel in Washington , D.C. in October 2017 , spending $ 1,894.

As President, Donald Trump and senior officials in his Administration took several
official actions and positions favorable to the Turkish government. For example, in 2018, thenPresident Trump reportedly assured President Erdo an that the DOJ would terminate an
investigation into the Turkish state-owned financial institution Türkiye Halk Bankasi, also
known as Halkbank, over allegations of money laundering and evasion of U.S. sanctions on Iran.
Trump Administration officials pressured the U.S. Attorney leading the investigation andprosecution to drop the charges .
In addition, President Trump remained silent when President
Erdo an's bodyguards assaulted U.S. citizens who were protesting the policies of the Turkish
government during President Erdo an's May 2017 visit to the United States.541
540

Turkey'sEmolumentSpendingat TrumpProperties

Date

Location

Event

October 11-14, 2017

Trump International Hotel( Washington , D.C.)

Amount$1,894542

Stay by Murat
Cetinkaya , Governor ,Central Bank of Turkey

InDecember2015, DonaldTrump stated the followingabout his relationshipwith
havea little conflictof
Turkeyduringan appearanceon SteveBannon'sradio program:interestbecauseI have a major, major buildinginIstanbul.
Towers two towers, insteadof one.

He explained, It's calledTrump

And I'vegotten to know Turkeyvery well. They'reamazingpeople. They're incrediblepeople. They have a strongleader

2012, Mr.

Turkish Bank Case Showed Erdogan's Influence with Trump , New York Times (Oct. 29, 2020) (onlineat www.nytimes.com/2020/10/29/us/politics/trump-erdogan-halkbankhtml) .

Presidential Silence After an Attack on American Soil, The Atlantic (Jan. 13 , 2019) (online atwww.theatlantic.com/politics/archive/2019/01/trump-stands-by-while-erdogan-orders-attack-protesters/580093/ ;Erdogan Security Forces Launch BrutalAttack on Washington Protesters, Officials Say, New York Times (May17, 2017) (online at www.nytimes.com/2017/05/17/us/turkish-embassy-protest-dc html) .

542 MAZARS- OVERSIGHT_COMMITTEE-00018548; MAZARS-OVERSIGHT_COMMITTEE
00018559 MAZARS-OVERSIGHT_COMMITTEE-00018568 ; MAZARS-OVERSIGHT_COMMITTEE
00018576.

Donald Trump

December 1, 2015, Breitbart News Daily (Dec. 1, 2015) (online athttps://soundcloud.com/breitbart/breitbart-news-daily-donald-trump-december-1-2015 ) ; The Daily 202: Trump's
Little Conflict ofInterest in Turkey Draws Scrutiny as He Offers Erdogan a Generous Deal, Washington Post
124

Erdo an, then Turkey's Prime Minister, cut the ribbon opening Trump Towers Istanbul . Donald
Trump attended this ribbon cutting, as did his daughter , Ivanka Trump , and her husband , Jared
Kushner
April 20, 2012, Ivanka Trump thanked Mr. Erdo an for his support, posting onsocial media:

Thank you Prime Minister Erdogan for joining us yesterday to celebrate thelaunch of #TrumpTowers Istanbul!

Years later, as Donald Trump prepared to take office, it was Mr. Erdo an who sought
access to Mr.Trump and his confidantes, with Turkey investing heavily in lobbyingthe Trump
Administration from its outset. Reportedly, the day before Donald Trump's inauguration,
Turkey's foreign minister, Mevlüt Çavu o lu, met with Trump fundraiser and D.C. lobbyist,
Brian Ballard, in Washington, D.C. According to NBC, this meeting marked the start ofTurkey's ambitious lobbying ofthe Trump administration
Mr. Ballard entered into a
profitable lobbying agreement with the Turkish Government that took effect on May 15, 2017
the day before President Erdo an visited President Trump at the White House (as discussed in
more detailbelow) 547

Mr.Ballard, a RepublicanNationalCommitteefinance vice chair and Trump super-donor,
had built his firm around his personalconnections to President Trump 548 Hewas reportedly
closerto the presidentthan perhapsany other lobbyistintown and parlayedthat relationshipMr.
into a boomingbusiness helping clients get their way with the Trump administration.
Ballardwas a frequent patron ofMr.Trump's Mar- a- Lago Club, reportedlyhavingjoined Mar-a
LagomidwaythroughMr. Trump's term after Mr. Trump noticedhe was not a member.550(Nov. 13, 2019 ) ( online at www.washingtonpost.com/news/powerpost/paloma/daily-202/2019/11/13/daily-202
trump- s - little- conflict- of- interest- in- turkey- draws- scrutiny- as- he- offers -erdogan- a - generous

deal/ 5dcb903288e0fa10ffd20dcb
/) .
544

.

545 Ivanka Trump ( @IvankaTrump) , X ( formerly Twitter) (Apr. 20, 2012 ) (online athttps://twitter.com/Ivanka Trump/ status / 193337302066540545 ) .

Behind Trump's Turkish Bromance : LevParnas, Oligarchs and a Lucrative LobbyingDeal, NBC
News (Sept. 19,2020) (online at www.nbcnews.com/politics/donald-trump/behind-trump-s-turkish-bromance-lev
parnas-oligarchs-lucrative-lobbying-n1240374) .
Departmentof Justice, SupplementalStatementPursuantto the ForeignAgents RegistrationActof
1938, as Amended( May 19, 2017) (online at https://efile.fara.gov/docs/6415-Exhibit-AB-20170519-3.pdf) . Behind
Trump's Turkish Bromance" : Lev Parnas, OligarchsAndA LucrativeLobbyingDeal, NBC News (Sept. 19, 2020)( onlineat www.nbcnews.com/politics/donald-trump/behind-trump-s-turkish-bromance-lev-parnas-oligarchs
lucrative- lobbying-n1240374); Turkish Bank Case ShowedErdogan'sInfluenceWithTrump, New York Times (Oct.
29, 2020) (online at www.nytimes.com/2020/10/29/us/politics/trump-erdogan-halkbankhtml) ; TheWhite House,
Press Release: Remarksby PresidentTrump andPresidentErdoganofTurkey in JointStatement(May 16, 2017)(online at https://tr.usembassy.gov/remarks-president-trump-president-erdogan-turkey-joint-statement/).
548 Ballard Partners, BrianD.Ballard (online at https://ballardpartners.com/the-team/brian-d-ballard/) ; TheCenterfor Public Integrity, Florida Lobbyist Turning Trump Ties into Mega-Millions (July 5 , 2017) (online athttps://publicintegrity.org/politics/florida-lobbyist-turning-trump-ties-into-mega-millions/).

The MostPowerful Lobbyist in Trump's Washington, Politico , (Apr. 2 , 2018) (online atwww.politico.com/magazine/story/2018/04/02/most-powerful-lobbyist-in-trump-washington-217759 ) .
The Swamp That Trump Built, New York Times ( Oct. 10 , 2020) ( online atwww.nytimes.com/interactive/2020/10/10/us/trump-properties-swamp html).
125

Moreover, the activities of Mr. Ballard's clients financially benefited the President, as officials
from client governments such as Turkey and Kosovo made payments to then-President Trump's
businesses as detailed in this report, in violation of the Constitution's Foreign Emoluments
Clause 551
As noted, on May 16, 2017, then-PresidentTrump hosted PresidentErdo an at the WhiteHousefor their first face-to- face encounter since Trump took office. PresidentErdo an
expressed optimismabout Mr. Trump's presidency.552 Inpublic remarks with PresidentTrump,
PresidentErdo an stated, as translated: Ofcourse, PresidentTrump's recent election victoryhas ledto the awakeningof a new set of aspirations and expectationsand hopes in our region.
And we know that, by the help of the new U.S. administration, these hopes will not be lost in
vain 553
After meeting with President Trump , President Erdo an went to the Turkish
Ambassador's residence in Washington , D.C., where his security detail violently charged a groupof human rights protesters outside the residence. The Turkish security detail injured 11
protesters and assaulted two Secret Service agents in what police described as a brutal
attackRepublican lawmakers called the security forces actions an affront to the UnitedStates,and the House of Representatives voted

in favor of a resolution calling for any

Turkish security official who directed or participated in efforts by Turkish security forces tosuppress peaceful protests outside of the Turkish Ambassador's residence to be charged andprosecuted under U.S. law.555 The State Department , moreover, called in the Ambassador of
Turkey to discuss the incident.556 Then-President Trump, however , made no public statements
condemning the attack .5
557

The MostPowerfulLobbyist in Trump's Washington, Politico( Apr. 2 , 2018) (online atwww.politico.com/magazine/story/2018/04/02/most-powerful-lobbyist-in-trump-washington-217759).
552 A New Era' in U.S.- Turkish Relations, The Atlantic (May 16, 2017) ( online atwww.theatlantic.com/news/archive/2017/05/trump-erdogan/526851/).

The White House, Press Release: Remarks by President Trump andPresident Erdogan of Turkey in
JointStatement (May 16, 2017 ) (online at https://tr.usembassy.gov/remarks-president-trump-president-erdogan
turkey-joint-statement/) .
Erdogan Security Forces Launch

Brutal Attack

on Washington Protesters , Officials Say, New YorkTimes (May 17, 2017) (online at wwwnytimes.com/2017/05/17/us/turkish-embassy-protest-dc.html

).

555

H.Res 354 ( 115th Cong.) (2017 ) ; See also Presidential Silence After an Attack on American Soil, The
Atlantic (Jan. 13, 2019 ) (online at www.theatlantic.com/politics/archive/2019/01/trump-stands-by-while-erdoganorders-attack -protesters / 580093/) ; See also Trump Says Turkish President Gets Very High Marks , Politico (Sept.
21, 2017 ) (online at www.politico.com/story/2017/09/21/trump-erdogan-turkey-praise-242986 ) .

556State Department Summons Turkish Ambassador After Bloody Brawlin D.C., NBC News (May 18,2017) (online at www.nbcnews.com/news/us-news/state-department-summons-turkish-ambassador-after-bloody
brawl-d-c-n761911) .
557

Trump Says Turkish President Gets Very High Marks, Politico ( Sept. 21, 2017) (online atwww.politico.com/story/2017/09/21/trump-erdogan-turkey-praise-242986 ); Presidential Silence After an Attack on
American Soil, The Atlantic (Jan. 13, 2019) (online at www.theatlantic.com/politics/archive/2019/01/trump-stands
by-while-erdogan -orders -attack -protesters /580093 ).
126

Interferencein Halkbank Prosecution

During former President Trump's Administration , Turkey found a receptive audience on
an issue that had for years been one of that country's key priorities ending the federal criminal
investigation of a Turkish state- run financial institution . Reportedly , before Donald Trump was
elected President , President Erdo an had attempted to pressure the Obama Administration tointervene in an ongoing DOJ investigation of Turkey's state- owned Halkbank for allegedly
violating U.S. sanctions laws and sending billions of dollars worth of gold and cash to Iran.
President Erdo an reportedly asked then -Vice President Biden to remove both then-U.S .
Attorney, Preet Bharara , who was leading the investigation in the Southern District of New York( SDNY) , as well as the judge overseeing the prosecution of Turkish - Iranian gold trader Reza
Zarrab . The Obama Administration did not take any action to interfere with, or in any way alter,the course of the investigation and prosecution .558
Following Donald Trump's election, the Turkish government and Halkbank initiatedexpensive lobbying efforts to try to persuade the Trump Administration to intervene . In August
2017 , while the investigation into Halkbank by the SDNY was still underway , Halkbank hired
Ballard Partners to represent it

Public reporting on lobbying records indicates that together ,the Government of Turkey which , as noted above had a separate contract with Ballard
Partners and Halkbank paid Mr. Ballard's lobbying firm $4.6 million over two years . Mr.
Ballard's firm lobbied officials at the Trump White House and the State Department, Members
560

of Congress , and then- President Trump's personal lawyer , Jay Sekulow.5

Incontrast to the Obama Administration, the Trump Administration signaled an openness
to intervening in the Halkbank prosecution, consistent with President Erdo an's wishes . In
2018, Trump Administration officials reportedly began questioning then-Attorney General Jeff
Sessions and President Trump's then-United States Attorney for the SDNY, and Mr. Bharara's
successor, Geoffrey Berman, about aspects of the case. One such official was then-Treasury
Secretary Steven Mnuchin, who, after having been approached himself by Turkish officials,
including President Erdo an's son-in-law, Berat Albayrak , reportedly raised questions with Mr.
Mr. Berman
Sessions about the size of any potential fine that the prosecutors might seek.561

Turkish Bank Case Showed Erdogan's Influence with Trump , New York Times (Oct. 29, 2020 ) ( online atwww.nytimes.com/2020/10/29/us/politics/trump-erdogan-halkbank.html

).

559

Department of Justice , Supplemental Statement Pursuant to the Foreign Agents Registration Act of1938, as Amended (Aug. 28 , 2017) (online at https ://efile fara.gov/docs/6415-Exhibit-AB-20170828-5.pdf ) ; Turkish
Bank Hires Lobby Firm with Trump Ties , The Hill (Sept. 1, 2017 ) (online at https://thehill.com/business-a
lobbying/ business -a- lobbying /348930 -turkish-bank -hires - lobby -firm -with- trump -ties/) .
560. Ballard Partners represented Turkey through November 2018 , and Halkbank until its indictment in
SDNY in October 2019. Behind Trump's Turkish Bromance : Lev Parnas, Oligarchs and a Lucrative Lobbying
Deal, NBC News (Sept. 19, 2020) (online at www.nbcnews.com/politics/donald-trump/behind-trump-s-turkishbromance-lev-parnas - oligarchs -lucrative -lobbying-n1240374 ); Turkish Bank Case Showed Erdogan's Influence with
Trump , New York Times (Oct. 29, 2020) (online at www.nytimes.com/2020/10/29/us/politics/trump-erdogan
halkbank html).
Turkish Bank Case Showed Erdogan's Influence with Trump , New York Times (Oct. 29, 2020) (online atwww.nytimes.com/2020/10/29/us/politics/trump-erdogan-halkbank.html
127).

described it, Halkbank acted as ifit had an ace in the hole, or two aces : a friend in the WhiteHouse and a back channel to Main Justice [i.e. the DOJ's leadership] .

December 14, 2018, then- President Trump reportedly promisedPresident Erdo anthat a resolution in the Halkbank investigationwas forthcoming a statement that suggested
President Trump was interferingin an ongoing investigationand violating the independenceof
the DOJ. According to the account of former National Security Advisor John Bolton, President
Erdo anpresented President Trump with a memo from the law firm representingHalkbank.
President Trump quickly flipped through the pages and then said that he believed Halkbank was
innocent

According to Mr. Bolton,

Trump [

] told Erdoganhe would take care of things,

explainingthat the Southern District prosecutors were not his people, but were Obama people, aproblemthat would be fixed when they were replacedby his people. 564 On the same day, theDOJreportedly notified SDNY that Secretary Mnuchin, Secretary of State Pompeo, and the U.S.
565
Attorney General's office would become more involved in the Halkbank case .

According to the New York Times , in December 2018 , then- Acting Attorney General
Matthew Whitaker told then- Deputy Attorney General Rod Rosenstein that he did not want the
Halkbank case to proceed , despite Mr. Rosenstein's support for the prosecution . JusticeDepartment officials ultimately disregarded Mr. Whitaker's instruction .
566

Attorney General Barr, who succeeded Acting Attorney General Whitaker in February
2019 , reportedly continued the effort to pressure SDNY to drop the charges .567 In his memoir,
Mr. Geoffrey Berman

who had been appointed by the Trump Administration in January

2018 noted his belief that in pushing to drop the Halkbank case , former Attorney General Barr,As Mr. Berman put it:" appeared to be doing Trump's bidding.
Donald Trump was close with the Turkish President, Recep Tayyip Erdo an. Trump had
a property in Turkey
2012 .

562

563

Trump Towers Istanbul. Erdo an attended the official opening in

Geoffrey Berman, Holding the Line (2022) at 261.
Trump'sInexplicableCrusadeto Help IranEvadeSanctions, ForeignPolicy( Jan. 9 , 2021) ( onlineat

https://foreignpolicy.com/2021/01/09/trump-help-iran-evade-sanctions-turkey-halkbank/).

564 Clash Over U.S. Attorney Who InvestigatedTrump Associates Sets OffCrisis, New York Times (June 19,
2020 ( online at www.nytimes.com/2020/06/19/nyregion/us-attorney-manhattan-trumphtml) ; Turkish Bank Case
ShowedErdogan'sInfluencewith Trump, New York Times (Oct. 29, 2020) (online atwww.nytimes.com/2020/10/29/us/politics/trump-erdogan-halkbank.html
).

565

.

566 Turkish Bank Case Showed Erdogan's Influence with Trump , New York Times (Oct. 29, 2020) (onlineat www.nytimes.com/2020/10/29/us/politics/trump-erdogan-halkbank

567html) .

.

568 GeoffreyBerman's Big Claims About Trump's Justice Department, Washington Post (Sept. 8, 2022)(online at www.washingtonpost.com/politics/2022/09/08/berman-trump-department-justice-organized/); UnitedStates Attorney's Office, Southern DistrictofNew York, Press Release: Attorney GeneralJeffSessions Appoints
Geoffrey S.BermanAs Interim UnitedStates Attorney (Jan. 3, 2018) (online at www.justice.gov/usaosdny/pr/attorney-general-jeff-sessions-appoints-geoffrey-s-berman-interim-united-states).
128

The Turkish President adamantly objected to all aspects of our probe and did not want thebank charged.
He made the case directly to Trump .

Barr, always eager to please his boss, appeared to be doing Trump's bidding.56

Inreporting on this matter , the New York Times observed : Mr. Trump's sympathetic
response to Mr. Erdogan was especially jarring because it involved accusations that the bank had
undercut Mr. Trump's policy of economically isolating Iran, a centerpiece of his Middle East
plan 570
Former National Security Advisor Bolton provided additional context regarding Mr.
Trump's relationship with Erdo an and Halkbank : It was so idiosyncratic , so personal to
Trump in the pursuit of personal relationships , that it was very dangerous . And it does look likeobstruction ofjustice .

Mr. Bolton further noted that former President Trump

wouldinterfere in the regular government process to do something for a foreign leader, adding, “ Inanticipation of what? In anticipation of another favor from that person down the road.
Despite the Trump Administration's apparent campaign to get the Justice Department to
end the investigation into Halkbank , SDNY filed an indictment against Halkbank in October
Mr. Berman described it:

Thensomethingunexpected, and, in light of all that occurredpreviously, bizarre,
occurredon October 15. Barr called me and saidthe team shouldput the Halkbankcase
inthe grandjury that day so we could be in a positionto indict.

Apparently, Trump had fallen out with Erdo an.574

InJune 2020, President Trump fired Mr. Berman. Trump DOJ officials reportedly cited
his handling ofthe Halkbank matter, including his blocking ofthe proposed global settlement, asa key reason for his removal 575

569 Berman, HoldingtheLineat 258.

Turkish Bank Case Showed Erdogan's Influence with Trump , New York Times (Oct. 29, 2020) (onlineat www.nytimes.com/2020/10/29/us/politics/trump-erdogan-halkbankhtml) .

571Id.

572
573.
Departmentof Justice, Press Release: Turkish Bank Charged in Manhattan Federal Courtforits

Participationina Multibillion-DollarIranianSanctions Evasion Scheme (Oct. 15, 2019) (online atwww.justice.gov/usao-sdny/pr/turkish-bank-charged-manhattan-federal-court-its-participation-multibillion-dollar).
574 Berman , Holding the Line at 276 .

Turkish Bank Case Showed Erdogan s Influence with Trump , New York Times (Oct. 29, 2020) (online atwww.nytimes.com/2020/10/29/us/politics/trump-erdogan-halkbank.html
129).

After charges were brought in October 2019 , Halkbank unsuccessfully sought to have thecase dismissed , arguing that the bank could not be subject to prosecution under the Foreign
Sovereign Immunities Act ( FSIA) , which limits the United States ability to bring civil cases
against foreign nations . The bank's appeal was ultimately reviewed by the U.S. Supreme Court,
which ruled in April 2023 that Halkbank was not immune from criminal prosecution under FSIA
because the law applied only to civil cases .576 The Supreme Court also remanded the case to the
U.S. Court of Appeals for the Second Circuit for further consideration of whether Halkbank isentitled to immunity under common law.577
Separately , SDNY charged nine individuals , including several employees of Halkbank ,with crimes related to Halkbank's scheme . Reza Zarrab ultimately pled guilty to seven counts .
The former Deputy General Manager of Halkbank was convicted on five counts in January 2018 .
578
Other defendants became fugitives.5
Spendingat Trump Propertiesby the Turkish Government

A document provided to the Committee by Mazars indicates that the Embassy of Turkey
made two expenditures at Trump -owned properties in May 2017

the same month President

Erdo an made his first visit to then- President Trump at the White House and the same monththat President Erdo an's security detail attacked U.S. protesters and Secret Service agents
outside the Turkish Embassy . The document shows an account for the Embassy of Turkey
Delegation with a Start Date of May 9, 2017 , and an account for the Embassy of Turkey
with a Start Date of May 23, 2017. Both accounts were identified as Closed.

The Mazars

records produced to the Committee do not specify the purposes or amounts of the Turkish
Embassy's expenditures , and Chairman Comer's release of Mazars from its obligation to
produce responsive documents has prevented the Committee from obtaining further information .
Records produced to the Committee by Mazars show that Murat Cetinkaya , the Governorof the Central Bank of Turkey , stayed at the Trump International Hotel in Washington , D.C.,
from October 11 through October 14, 2017 , spending $ 1,894.580 Mr. Cetinkaya's name appears
among the Accredited Members of the Delegations at the 2017 Annual Meetings

included in

576

InProsecution ofTurkish Bank, the Supreme Court Issues a Mixed Ruling, New York Times (Apr. 19,
2023 ) (online at www.nytimes.com/2023/04/19/us/supreme-court-turkish-bank-halkbank.html ); Supreme Court says
Halkbank Not Immune From U.S. Prosecution for Iran Sanctions Violations Under FSIA, CNBC (Apr. 19, 2023)( online at www.cnbc.com/2023/04/19/supreme-court-says-turkey-owned-bank-can-be-prosecuted-for-iransanctions-violations html) .
577

Turkiye Halk Bankasi A.S. v . United States , 143 S.Ct. 940 ( 2023 ) .

578

Departmentof Justice, Press Release: Turkish Bank Charged in Manhattan FederalCourtfor its
Participationin a Multibillion-DollarIranianSanctions Evasion Scheme (Oct. 15, 2019) (online atwww.justice.gov/usao-sdny/pr/turkish-bank-charged-manhattan-federal-court-its-participation-multibillion-dollar).
579 MAZARS- OVERSIGHT_COMMITTEE- 00008041.

580 MAZARS-OVERSIGHT COMMITTEE-00018548 ; MAZARS-OVERSIGHT COMMITTEE

00018559; MAZARS-OVERSIGHT_COMMITTEE-00018568; MAZARS-OVERSIGHT_COMMITTEE
00018576;Turkey's PresidentRemovesHead ofCentral Bank, New York Times (July 6, 2019) (online at.

www.nytimes.com/2019/07/06/business/erdogan-removes-turkey-governor-central-bank.html)
130the Summary Proceedings
by the World Bank.

of the 2017 Annual Meetings of the Boards of Governors issued

581

Trump'sBusinessInterestsin Turkey

Significantly , the payments made to the Trump International Hotel in Washington , D.C.,
by Turkish officials were in addition to the approximately $2.6 million in net income the former
President reportedly received from 2015 through 2018 from his business operations in Turkey .582
Inhis personal financial disclosures during his time in office, Mr. Trump reported receiving
royalties worth between $ 100,001 and $ 1 million annually on his Trump Marks Istanbul IILLC
venture.583 As discussed above , Mr. Trump himself stated that he had a little conflict ofinterest with respect to Turkish affairs because of his major, major building in Istanbul.

The World Bank, 2017 Annual Meetings of the Board of Governors Summary Proceedings ( Oct.

,2017) (online at https://documents1.worldbank.org/curated/es/400001527620999731/pdf/2017-Summary
Proceedings- cleared - by - YT - 05232018.pdf) .

Turkish Bank Case Showed Erdogan's Influence with Trump , New York Times (Oct. 29, 2020) ( online atwww.nytimes.com/2020/10/29/us/politics/trump-erdogan-halkbank.html).

583 Office of Government Ethics, Executive Branch PersonnelPublic FinancialDisclosures (OGE Form278e) (Donald J. Trump) (Filed May 15, 2018) (online at https://s3.documentcloud.org/documents/21154685/trumpoge-2018.pdf) ; Office of Government Ethics, Executive Branch PersonnelPublicFinancial Disclosures (OGE Form278e) (Donald J. Trump) (Filed May 15, 2019) (online at https://s3.documentcloud.org/documents/21154683/trumpoge-2019.pdf) ; Office of Government Ethics, Executive Branch PersonnelPublic Financial Disclosures (OGE Form278e) (Donald J. Trump) (Filed July 31, 2020) (online https://s3.documentcloud.org/documents/7012257/President
Donald-Trump-2020-financial-disclosure.pdf) ; Office of Government Ethics, ExecutiveBranchPersonnelPublic
FinancialDisclosures ( OGE Form 278e) (Donald J. Trump ) (Filed Jan. 15, 2021) ( online athttps://extapps2.oge.gov/201/Presiden nsf/PAS+Index/6E78B163F816EF6A852586630075291D/ FILE/Trump, 20
Donald 20J 202021Termination 20278.pdf); What We Know About Trump's Business Empire Trump Towers
Istanbul, CNN (2018) ( online at www.cnn.com/interactive/2018/politics/trump-business-empire/?asset=59).
President Trump Said in 2015 That He Has a Little Conflict ofInterest inTurkey , TIME (Apr. 19,2017) (online at https://time.com/4746348/donald-trump-turkey-conflict-interest/ ) .
131

DEMOCRATICREPUBLICOF THE CONGO

The records produced to the Committee by Mazars show that during the six -month period
between September 2017 and March 2018, representatives of the government of the Democratic
Republic ofthe Congo (D.R.C.) and a chairman of a D.R.C. state agency spent $25,171 at the
Trump International Hotel in Washington, D.C., over six separate stays . Duringthe same period,
D.R.C.government officials were engaged in an extensive influence campaign in the U.S.while
then-D.R.C. President Joseph Kabila_whose term was supposed to have ended in late 2016—585
refusedto cede power
As experts and policymakers withinthe international community
condemnedMr. Kabila for his refusalto hold free and fair electionsand for his administration's
violentrepressionofpoliticaldissent, the Kabila governmentspent tens of thousandsofdollars
on hotelstays presumablyaimed at securingthen- PresidentDonaldTrump's support.
D.R.C.'s Emolument Spending at Trump Properties

Date

Location

Expenditure

AmountSeptember 10-16 ,2017

Trump International Hotel

RaymondTshibanda,
Special Envoyofthe$6,43958( Washington, D.C.)

586

D.R.C. to the United States

September25 ,Trump International Hotel

RaymondTshibanda,

2017( Washington, D.C.)

Special Envoy of the$1,356587

D.R.C. to the United States

Trump International Hotel

Francois Balumuene,( Washington, D.C.)

Congolese Ambassador to
the UnitedStates

November26,

Trump International Hotel

RaymondTshibanda,

2017 December( Washington, D.C.)

October 12, 2017

4 , 2017$ 1,600

588$8,638 589

Special Envoy of the
D.R.C. to the United States

The Postponed DRCElections: BehindtheTumultuous Politics, Brookings Institution (Nov. 18,2016)(online at www.brookings.edu/blog/africa-in-focus/2016/11/18/the-postponed-drc-elections-behind-the-tumultuous
politics ; No DRCLeader Gives Up Power Peacefully, So Why Would Joseph Kabila?, The Guardian (Sept. 23,
2016) (onlineat www.theguardian.com/world/2016/sep/23/joseph-kabila-democratic-republic-of-the-congo

elections-transfer-power).

---

---

---

MAZARS OVERSIGHT_COMMITTEE 00018306 ; MAZARS OVERSIGHT_COMMITTEE
586
00018315 MAZARS OVERSIGHT_COMMITTEE 00018324 ; MAZARS OVERSIGHT_COMMITTEE
00018334 ;MAZARS OVERSIGHT_COMMITTEE 00018343 ; MAZARS OVERSIGHT_COMMITTEE
00018349 ;MAZAR OVERSIGHT_COMMITTEE 00018353 ; MAZARS OVERSIGHT_COMMITTEE
00018451

587 MAZARS- OVERSIGHT_COMMITTEE- 00018400.
588

00018555

----

----

---

MAZARS- OVERSIGHT_COMMITTEE- 00018553; MAZARS- OVERSIGHT_COMMITTEE

589 MAZARS OVERSIGHT COMMITTEE 00018914 ; MAZARS OVERSIGHT COMMITTEE
00018916 ;MAZARS OVERSIGHT_COMMITTEE 00018919 ;MAZARS OVERSIGHT_COMMITTEE
00018924 MAZARS OVERSIGHT_COMMITTEE 00018929 ; MAZARS OVERSIGHT_COMMITTEE
00018937 MAZARS OVERSIGHT_COMMITTEE 00018942 ; MAZARS OVERSIGHT_COMMITTEE
00018947 ;MAZARS OVERSIGHT_COMMITTEE 00018956.

132

December

Raymond Tshibanda,, | Trump International Hotel

2017

$

Special Envoy ofthe( Washington, D.C.
)

D.R.C.to the United States

Trump International Hotel( Washington , D.C.)

March13-16,
2018

AlbertYuma, Chairman,$5,642591

Gécamines

EMOLUMENTSPAID BY D.R.C.

$ 25,171( 2017-2018 )In October 2016, as then-President Joseph Kabila was nearing the constitutionallymandated end of his final term, he announced that 2016 presidential elections originally expected
to be held that fall would be postponed until April 2018.

This announcement appeared toensure that President Kabila would remain in power for at least another 15 months and raised
concerns that he might seek to change the D.R.C.'s constitution so that he could retain thepresidency indefinitely .

Then-President Kabila was accused of using force against those who
opposed his regime and of looting millions in public funds.594
The D.R.C.'s shift away from democracy and its repression of dissent provoked alarm in

the international community

In June 2016 , the Obama Administration had already imposed

590 MAZARS- OVERSIGHT_COMMITTEE - 00019049 ; MAZARS - OVERSIGHT_COMMITTEE
00019052 .

-

-

-

591 MAZARS OVERSIGHT COMMITTEE 00016648 ; MAZARS OVERSIGHT COMMITTEE
00016659 ;MAZARS OVERSIGHT_COMMITTEE 00016671 ; MAZARS OVERSIGHT_COMMITTEE
00016678.

592 The Postponed DRC Elections: Behind the Tumultuous Politics, Brookings Institution (Nov. 18, 2016)(online at www.brookings.edu/blog/africa-in-focus/2016/11/18/the-postponed-drc-elections-behind-the-tumultuous

No DRC Leader Gives Up Power Peacefully So Why Would Joseph Kabila ?, The Guardian (Sept. 23,
2016) (online at www.theguardian.com/world/2016/sep/23/joseph-kabila-democratic-republic-of-the-congo
elections -transfer - power).
politics

The PostponedD.R.C. Elections: BehindThe TumultuousPolitics, BrookingsInstitution(Nov. 18,
2016) (onlineat www.brookings.edu/articles/the-postponed-drc-elections-behind-the-tumultuous-politics/acf) ; ThePostponedDRC Elections: WhatDoes The DRC's SituationLook Like Now?, BrookingsInstitution(Nov.22, 2016)(online at www.brookings.edu/articles/the-postponed-drc-elections-what-does-the-drcs-situation-look-like-now/).
U.N. Condemns Congo's Use ofForce Against Protesters and Monitors, New York Times (Jan. 23,2018) (online at www.nytimes.com/2018/01/23/world/africa/congo-un-protests-kabilahtml) ; As PresidentJoseph
KabilaDigsIn, Tensions Rise in Congo, New York Times (Dec. 17 , 2016) (online atwww.nytimes.com/2016/12/17/world/africa/congo-joseph-kabila-corruption.html) . See alsoDocumentLeakShows
KabilaFamily AssociatesLootedDRCFunds, AlJazeera( Nov. 21, 2021) ( onlineat

www.aljazeera.com/economy/2021/11/19/document-leak-shows-kabila-family-associates-looted-drc-funds ).
(Describing a 2021 financial document data leak that demonstrated how a private bank in the Democratic RepublicofCongo was used to channel at least $ 138 million ofpublic funds to former President Joseph Kabila’s family andassociates . The documents show that Congo's central bank sent $ 94.5 million to entities connected to the Kabilas,
while tens of millions of dollars arrived from other public institutions, including $20 million from the nation's state
owned mining company Gecamines . ).
595 Editorial: Obama Should Act on Congo Before It's Too Late, Washington Post (Nov. 22, 2016) (onlineat www.washingtonpost.com/opinions/global-opinions/obama-should-act-on-congo-before-its-toolate/2016/11/22/ec01b41a-b023-11e6-8616-52b15787add0_storyhtml); U.S. DisappointedCongoDidNot
AnnounceElectionCalendar, Reuters ( Sept. 19, 2016) (online at www reuters.com/article/us-congo-politics-usa/u-s
disappointed-congo-did-not-announce- election-calendar-idUSKCN11P22M) .
133

sanctions on the police chief in D.R.C.'s capital, Kinshasha.5 6 Shortly before leaving office, theObama Administration imposed sanctions on several senior government officials in the D.R.C. ,including the Deputy Prime Minister.597
Asitwastryingto suppress oppositionat home, the Kabilagovernmentinitiateda multimilliondollar lobbyingandpublic relationscampaignto court U.S. governmentofficials and win
overthe new TrumpAdministration.598 Inlate2016 as PresidentKabilaextendedhis rule the
Kabila governmentreportedlycontractedMER Securitiesand CommunicationsSystemsLtd.
(MER), an Israelisecurityfirm, to launcha multi-milliondollarD.C.lobbyingcampaign
designedto influencethe TrumpAdministration. MER had alreadybeenaidingthe D.R.C.'s
surveillanceand intelligenceefforts at home.599 The D.R.C.governmentfurtherexpandedits
influencecampaignonceTrumptook office, engaginglobbyingfirms likethe Republican-led
LivingstonGroupto help shoreup U.S. support amid growingcontroversysurroundingPresident
600
Kabila.6
InJuly 2017 , the U.S. Deputy Ambassador to the United Nations announced that the U.S.
was ready to take additional action to sanction those who stand in the way of D.R.C.'s first
democratic transition of power
As Voice ofAmerica reported , on July 11, 2017 , the U.S.
threatened to impose further targeted unilateral sanctions on anyone who hinders Democratic
Republic of Congo's already delayed preparations for an election to replace President Joseph
Kabila after the D.R.C.'s election commission president said [ ] that the vote , originally due
in November 2016 , was unlikely to take place in 2017.

US Imposes Sanctions on Kinshasa Police Chief in DRC, VOA News (June 23, 2016) (online atwww.voanews.com/a/us-imposes-sanctions-kinshasa-police-chief-drc/3389741.html).

US EUSanction DRC Officials for Undermining Democracy , VOA News (Dec. 12, 2016) ( online atwww.voanews.com/a/us-eu-drc-sanctions/3633014

html) .

598

Congo'sLobbyistsSeekAllies in WashingtonAmid ElectionTurmoil, The Hill(June 28, 2017) (onlineat
https://thehill.com/business-a-lobbying/business-a-lobbying/339927-congos-lobbyists-seek-allies-in-washington
amid ; CongoInks $5.6 MillionLobbyingDealAmidElectionStrife, The Hill (May 1, 2017) (onlineat
https://thehill.com/business-a-lobbying/lobbying-hires/331385-congo-inks-56-million-lobbying-deal-amid-election
strife ) .

599 How One Company Made ItEasierfor an Autocrat to Crack Down, Then Lobbied Trump And Won ,Buzzfeed (Dec. 30 , 2020 ) (online at www.buzzfeednews.com/article/albertsamaha/joseph-kabila-congo
authoritarian - rule -mer); Congo Inks $5.6 million Lobbying Deal Amid Election Strife, The Hill (May 1, 2017)(online at https://thehill.com/business-a-lobbying/lobbying-hires/331385-congo-inks-56-million-lobbying-dealamid -election - strife ) .

Congo's Lobbyists Seek Allies in Washington Amid Election Turmoil, The Hill (June 28, 2017) (online athttps://thehill.com/business-a-lobbying/business-a-lobbying/339927-congos-lobbyists-seek-allies-in-washington
amid Congo Inks $5.6 Million Lobbying DealAmid Election Strife , The Hill (May 1, 2017) (online athttps://thehill.com/business-a-lobbying/lobbying-hires/331385-congo-inks-56-million-lobbying-deal-amid-election
strife See also Targets of U.S. Sanctions Hire Lobbyists With Trump Ties to Seek Relief, New York Times (Dec. 10,2018) (online at www.nytimes.com/2018/12/10/us/politics/sanctions-lobbyists-usa html) ; Congo's Lobbyists Seek
Allies in Washington Amid Election Turmoil, The Hill (June 28, 2017) (online at https://thehill.com/business-a
lobbying/business-a- lobbying/339927-congos - lobbyists-seek-allies-in- washington -amid/) .
601 US Threatens Sanctions on Anyone Delaying DR Congo Vote (July 11, 2017) (online atwww.aljazeera.com/news/2017/7/11/us-threatens-sanctions-on-anyone-delaying-dr-congo-vote).

602 US Threatens More Sanctions for Hindering Democracy in Congo,VOA News (July 11, 2017) (online
134According to filings with the DOJ pursuant to FARA, the Livingston Group, on behalf of
MER, arranged a meeting on September 14, 2017, for Mr. Raymond Tshibanda, the Kabila
government's Special Envoy to the United States and former Minister for ForeignAffairs,
International Cooperation, and Francophonie of the D.R.C., and other D.R.C. representatives
with the Senior Advisor to the Under Secretary of State for Civilian Security, Democracy, andHuman Rights and a D.R.C. desk officer at the U.S. Department of State.
The documents
Mazars produced to the Committee indicate that on the day he met with the State Department
officials, Mr. Tshibanda stayed at the Trump International Hotel in Washington, D.C. His staythat day was the first of four stays by him recorded in the limited documents produced by
Mazars 604
Subsequently, betweenNovember28, 2017, and December 1, 2017, the Livingston
Grouparrangedmeetings for a D.R.C.delegation includingMr. Tshibanda and D.R.C.'s
Ambassadortothe UnitedStates, FrancoisBalumuene with U.S. public officials, former U.S.
605

ambassadorsand State Departmentofficials, and severalMembers of Congress.

Inlate 2017 , Nikki Haley, then-President Trump's Ambassador to the United Nations ,visited President Kabila in the Congolese capital , Kinshasa . During her visit, Ambassador Haley
pushed Kabila to cede power and threatened economic sanctions if he did not do so.606 Then
Ambassador Haley had been sharply critical of the conditions in the D.R.C. In an op- ed
published by CNN, she noted that the country had never witnessed a democratic , peacefultransfer of power.
Earlier in 2017, she had reportedly described the Kabila regime as
corrupt and prey [ ing] on its citizens .
In late 2017 , after Ambassador Haley's trip to
Kinshasha , the U.S. imposed sanctions on business interests in theat www.voanews.com/a/us-threatens-more-sanctions-for-hindering-democracy-in-drc/3937904.html

).

603

Department ofJustice , Supplemental Statement Pursuant to the Foreign Agents Registration Act of1938, as Amended (Nov. 30 , 2017) (online at https :// efile fara.gov/docs/6428-Supplemental-Statement-20171221
1.pdf) ; Raymond Tshibanda , Congo Envoy, Sees Election Hurdles , Washington Times (July 9 , 2017) (online atwww.washingtontimes.com/news/2017/jul/9/raymond-tshibanda-congo-envoy-sees-election-hurdle/ ) ; United
Nations , Secretary -General Meets Foreign Minister of Democratic Republic of Congo (Sept. 24, 2016) ( online athttps ://dam media.un.org/archive/The-Secretary-General-with-H-E--Mr--Raymond-Tshibanda-N-tungamulongoForeign- Minister --DEMOCRATIC - REPUBLIC - OF- THE - CONGO --2 AM9LOLSRG8Z.html ) .
604 MAZARS- OVERSIGHT_COMMITTEE- 00018306.

605

Departmentof Justice, SupplementalStatementPursuantto theForeignAgents RegistrationActof
1938, asAmended(Mar. 31, 2018) (online at https://efile.fara.gov/docs/6344-Supplemental-Statement-20180511
4.pdf) . Accordingto public filings by the LivingstonGroup, these meetingswere arranged to discuss recent
politicaldevelopmentsin the DRC [ ] , economic cooperationandbusiness opportunitiesbetween [the UnitedStates andtheDRC], developmentand humanitarianissues in the DRC, and strategicdevelopmentsaffectingthe
D.R.C.and Central Africa.

How One CompanyMade ItEasierfor anAutocratto CrackDown, Then Lobbied Trump AndWon,
Buzzfeed (Dec.30, 2020) (online at www.buzzfeednews.com/article/albertsamaha/joseph-kabila-congo
authoritarian-rule-mer).
607 Nikki Haley: This Is Why the President Is Sending Me to Africa, CNN (Oct. 22, 2017) ( online atwww.cnn.com/2017/10/21/opinions/un-drc-south-sudan-nikki-haley-opinion/index
608html).

NikkiHaley Calls for Cuts in U.N. PeacekeepingFunding, NPR (Mar. 30 , 2017) ( online atwww.npr.org/2017/03/30/522015640/nikki-haley-calls-for-cuts-in-u-n-peacekeeping-funding).
609

U.S. Department ofthe Treasury , PressRelease: United States Sanctions Human Rights Abusers and135

InMarch 2018 , after hearing from individuals displaced from the D.R.C. and aid workers
who had traveled there , the United Nations issued a press release warning , Humanitarian Crisis
in Democratic Republic of Congo Will Worsen Without Political Transition , End to Violence ,Speakers Warn Security Council .
In April 2018 , the New York Times reported that , [t ] heUnited Nations says challenges to Mr. Kabila’s rule have caused a collapse of political authority ,leading to fighting that has displaced 4.5 million people

Inmid-2018, as MER was reportedly stepping up its efforts to target individuals who heldsway with the Trump Administration , including Rudy Giuliani.6
InJuly 2018, Mr. Giuliani
612

attended a cocktail party in Washington , D.C. , featuring a speech by Special Envoy Tshibanda.613
After that party, Ambassador Balumuene suggested in a September 2018 interview that the
D.R.C. was working with Mr. Giuliani to figure out the [ Trump ] administration's position on an
upcoming presidential election called by Mr. Kabila to avoid threatened sanctions .
Ambassador Balumuene stated, What I know is that it is possible that Giuliani will let us know
how to go ahead, possibly suggesting that Mr. Kabila's government expected to receive inside
information from Mr. Giuliani.615 Ambassador Balumuene later walked that statement backhowever, claiming he had never met or spoken to Giuliani.

InAugust 2018, Mr. Kabila announced that he would not run for President in the617
upcoming election, which had finally been scheduled for December of that year.
Publicly, Mr.
Kabila endorsed Emmanuel Ramazani Shadary, who had been serving as one of three deputy
prime ministers and interior minister, as his successor. 618 Behind the scenes, however, Mr.

CorruptActors Across the Globe (Dec. 21, 2017) (online at https://home.treasury.gov/news/press-releases/sm0243 ) .
610 United Nations, Meetings Coverage, Security Council, 8207th Meeting, AM, Press Release:
Humanitarian Crisis in Democratic Republic of Congo Will Worsen Without Political Transition, End to Violence,
Speakers Warn Security Council (Mar. 19, 2018) (online at https://press.un.org/en/2018/sc13253.doc htm) .
611

DespiteMillionsofDisplaced People, Congo Rejects U.N. Aid Effort, New York Times (Apr. 7, 2018)( online at www.nytimes.com/2018/04/07/world/africa/congo-kabila-aidhtml).

612How One Company Made ItEasierfor An Autocrat To Crack Down, Then Lobbied Trump And Won,
Buzzfeed (Dec. 30, 2020) (online at www.buzzfeednews.com/article/albertsamaha/joseph-kabila-congo
authoritarian-rule-mer).
613 Id Targets of U.S. Sanctions Hire Lobbyists with Trump Ties to Seek Relief, New York Times (Dec. 10,2018) (online at www.nytimes.com/2018/12/10/us/politics/sanctions-lobbyists-usa

614

.

615

.

html) .

616 How One Company Made ItEasierfor An Autocrat To Crack Down, Then Lobbied Trump And Won,
Buzzfeed (Dec. 30, 2020 ) (online at www.buzzfeednews.com/article/albertsamaha/joseph-kabila-congo
authoritarian -rule -mer).
617 Waitingfor Democracyin Congo, ForeignAffairs (Aug. 17, 2018) (online atwww.foreignaffairs.com/articles/democratic-republic-congo/2018-08-17/waiting-democracy-congo) ; Joseph Kabila,
Congo Strongman, Will Step Down After 17 Years in Power, New York Times (Aug. 8 , 2018) (online atwww.nytimes.com/2018/08/08/world/africa/joseph-kabila-congo.html).
618 Emmanuel Ramazani Shadary: Kabila's Choice for DR Congo President, BBC News (Dec. 18. 2018)( online at www.bbc.com/news/world-africa-46447089 ) ; Joseph Kabila, Congo Strongman, Will Step Down After 17
Years inPower, New York Times (Aug. 8 , 2018) (online at www nytimes.com/2018/08/08/world/africa/joseph136

Kabila reportedly negotiated a secret power- sharing arrangement with a different candidate :619
Félix Tshisekedi.61
After the elections were finally held on December 30 , 2018 , Félix
Tshisekedi was declared the winner through a process that regional election observers and theinternational community widely viewed as fraudulent . 620

On January 22, 2019, a group of U.S. government agencies , including the Department of
the Treasury, reportedly drafted a statement calling the election deeply flawed and troublingand concluding that the D.R.C.'s election commission had failed to live up to the responsibility
to conduct a fair election reflecting the will of the Congolese people.
This statement,
however, was never released
For reasons that are not clear , the Trump Administration instead
released a statement that welcomed the Congolese Constitutional Court's certification of Félix
Tshisekedi as the next President and praised Kabila's commitment to becoming the first
President in DRC history to cede power peacefully through an electoral process.

Inthe spring of2019 , the parties of Tshisekedi and Kabila announced loose plans toform a coalition government .
According to sources in the parties, Kabila would choose theprime minister and negotiate over cabinet appointments under a power-sharing deal with his
successor Felix Tshisekedi

kabila- congo.html ) .

How One CompanyMade ItEasierfor AnAutocratTo CrackDown, Then LobbiedTrump
Buzzfeed(Dec.30 , 2020) ( online at www.buzzfeednews.com/article/albertsamaha/joseph-kabila-cong
authoritarian- rule- mer) .
620

Won

Mounting Evidence ofFraud in Congo Vote Prompts Rare Rebuke from the African Union, Washington

Post (Jan. 18, 2019) (online at www.washingtonpost.com/world/mounting-evidence-of-fraud-in-congo-vote
prompts- rare- rebuke - from -the - african- union/ 2019/ 01/ 18/ 3164c184-1a97-11e9 - b8e6-567190c2fd08_story html) .

621How WashingtonGoton Boardwith Congo'sRiggedElection, ForeignPolicy( Feb. 1, 2019) ( onlineat
https://foreignpolicy.com/2019/02/01/how-washington-got-on-board-with-congos-rigged-election-drc-tshisekedi
kabila- great- lakes/) .

622

.

623

Department of State , Press Release: U.S. Response to Constitutional Court Decision in the Democratic
Republic ofthe Congo (Jan. 23, 2019) (online at https://2017-2021-translations.state.gov/2019/01/23/u-s-response
to-constitutional-court-decision-in-the-democratic -republic-of-the-congo ) ; See also How One Company Made It
Easierfor An Autocrat To Crack Down, Then Lobbied Trump And Won, Buzzfeed (Dec. 30 , 2020) (online atwww.buzzfeednews.com/article/albertsamaha/joseph-kabila-congo-authoritarian-rule-mer ); How Washington Goton
Board with Congo's Rigged Election , Foreign Policy (Feb. 1, 2019) (online athttps://foreignpolicy.com/2019/02/01/how-washington-got-on-board-with-congos-rigged-election-drc-tshisekedi

kabila-great- lakes/) .

624 Congo's Ex- Leader Kabila's Party to Pick Prime Minister : Sources , Reuters (Mar. 8 , 2019) ( online atwww.reuters.com/article/us-congo-politics/congos-ex-leader-kabilas-party-to-pick-prime-minister-sources
).
625

.
137

HeadofStateMiningAgencyAlbertYuma

The D.R.C.'s economy is driven by its mining sector , and specifically by mining of thecountry's substantial reserves of two metals copper and cobalt.626 Mr. Albert Yuma , former
Congolese mining magnate and then-head of state mining agency Gécamines , was at the centerof corruption allegations against the agency, which controls the nation's copper and cobalt
reserves.627 Mr. Yuma took control of Gécamines in 2010, reportedly acquiring the post throughhis political connections.
As then-Chairman, he was accused of nepotism, self-dealing, andgovernment corruption during his tenure.629 The State Department warned for years that heabused his position to enrich friends , family members and political allies.

InMarch 2018, Mr. Yuma appeared to be engaged in a lobbying tour ofthe United States
to improve his image and stayed for several nights at the Trump International Hotel inWashington , D.C. Mr. Yuma also attended meetings arranged by several lobbying firms with
officials from the World Bank and several U.S. Departments , including the Department ofEnergy At several ofthese meetings , he was reportedly accompanied by Gentry Beach, a Texas
based hedge fund manager, fundraiser for then-President Trump , and close friend of Donald
Trump Jr. Mr. Beach reportedly had been trying to secure a mining deal in Congo, andpreviously invested with Mr. Trump [Jr. ] in a mining project there . In 2018, Mr. Yuma also
visited and met with Mr. Trump Jr. for a quick meet- and-greet at Trump Tower in New York .
Weeks later, however, the State Department revoked Mr. Yuma's visa after finding involvement
by several senior DRC officials in significant corruption related to the DRC's electoral
process and human rights violations . 631
December2021, PresidentTshisekedifired Mr. Yuma from Gécaminesas part ofa
restructuringofthe board followingthe long- standingcorruptionallegations against him,
includingaccusationsthat he diverted $ 8.8 billioninminingrevenuesover the years

626 GlobalWitness, Regime CashMachine: How the Democratic Republic of Congo's BoomingMining
ExportsAre Failingto BenefitIts People, New Your Times (July 2017) ( online athttps://int.nyt.com/data/documenttools/regime-cash-machine-freeport-and-tfm-big-role/64ef83a9813262bb/full.pdf
).

627
628

. SeealsoDRC: Gécaminesand theMissingMillions, The AfricaReport( June 6 , 2022) ( onlineat

www.theafricareport.com/210908/drc-gecamines-and-the-missing-millions/) .

629GlobalWitness, Regime CashMachine: How the DemocraticRepublic ofCongo's BoomingMining
ExportsAreFailingto BenefitIts People, New YourTimes (July 2017) (online athttps://int.nyt.com/data/documenttools/regime-cash-machine-freeport-and-tfm-big-role/64ef83a9813262bb/full.pdf);
DRC: Gécamines and the MissingMillions, The Africa Report(June 6, 2022) (online atwww.theafricareport.com/210908/drc-gecamines-and-the-missing-millions/).
630

Huntfor the

Blood Diamond of Batteries

Impedes Green Energy Push, New York Times (Nov. 19,2021) (online atwww.nytimes.com/2021/11/29/world/congo-cobalt-albert-yuma-mulimbi.html

631

).

.

632 FormerCongo President'sAlly LosesChairmanshipofStateMiningCompany, Reuters(Dec.2, 2021)( onlineatwww reuters.com/markets/commodities/former-congo-presidents-ally-loses-chairmanship-state-mining
company-2021-12-03 ; Congo Ousts MiningLeaderinA CloudofCorruptionClaims, NewYork Times (Dec.3,2021) (onlineatwww.nytimes.com/2021/12/03/world/congo-cobalt-albert-yuma-mulimbi.html).
138

Emoluments
Paidby the D.R.C.to Trump- OwnedBusinesses

The Mazarsrecords produced to the Committee show that between September 2017 andMarch 2018, Congolese government officials and the then- chairmanofthe D.R.C. state- owned
miningentity Gécamines spent $ 25,171 at the Trump InternationalHotelin Washington, D.C.

The vast majority of these expenditures were incurred by Raymond Tshibanda, then
D.R.C President Joseph Kabila's Special Envoy to the United States . Mr. Tshibanda stayed at thehoteltwice in September 2017, from November 26 through December 4, 2017, and again at theend ofDecember 2017. For these four stays, he spent a combined total of nearly $18,000.633 As
discussed, Mr. Tshibanda first appears in the documents produced to the Committee by Mazars in
the Trump International Hotel in Washington , D.C.'s guest ledger for September 2017. Media
reports indicate that he also traveled to Washington , D.C., as part of the D.R.C.'s lobbying effort
earlier in 2017, but because Chairman Comer curtailed Mazars's document productions to theCommittee , it is unclear ifMr. Tshibanda stayed at a Trump property during that trip.634
Inaddition , D.R.C.'s Ambassador to the United States , Francois Balumuene , spent $ 1,600
635

at the Trump International Hotel on October 12 , 2017.63

The Mazarsrecords producedto the Committee also show that Albert Yuma spent $ 5,642
for two adjacent rooms at the Trump InternationalHotel in Washington, D.C., between March 13
and March 16, 2018.636

--.

---

---

633 MAZARS OVERSIGHT_COMMITTEE 00018306 ; MAZARS OVERSIGHT_COMMITTEE

00018315 ;MAZARS OVERSIGHT COMMITTEE 00018324 ; MAZARS OVERSIGHT COMMITTEE

00018334 ;MAZARS OVERSIGHT COMMITTEE 00018343 ; MAZARS OVERSIGHT COMMITTEE
00018349 ;MAZARS OVERSIGHT COMMITTEE 00018353 ; MAZARS OVERSIGHT COMMITTEE
00018400 ;MAZARS OVERSIGHT COMMITTEE 00018451 ; MAZARS OVERSIGHT COMMITTEE
00018914 ;MAZARS OVERSIGHT_COMMITTEE 00018916 ; MAZARS OVERSIGHT_COMMITTEE
00018919 ;MAZARS OVERSIGHT COMMITTEE 00018924 ; MAZARS OVERSIGHT COMMITTEE
00018929 ;MAZARS OVERSIGHT COMMITTEE 00018937 ; MAZARS OVERSIGHT COMMITTEE
00018942 MAZARS OVERSIGHT_COMMITTEE 00018947 ; MAZARS OVERSIGHT_COMMITTEE
00018956 MAZARS OVERSIGHT_COMMITTEE 00019049 ; MAZARS OVERSIGHT_COMMITTEE
00019052

Congo's Lobbyists Seek Allies in Washington Amid Election Turmoil, The Hill (June 28 , 2017) (online athttps://thehill.com/business-a-lobbying/business-a-lobbying/339927-congos-lobbyists-seek-allies-in-washington
amid Congo Inks $ 5.6 Million Lobbying Deal Amid Election Strife , The Hill (May 1, 2017) (online athttps://thehill.com/business-a-lobbying/lobbying-hires/331385-congo-inks-56-million-lobbying-deal-amid-election
strife Department of Justice , Supplemental Statement (Oct. 31,2017) (online at https://efile.fara.gov/docs/6415
Supplemental-Statement - 20171128-1.pdf).
635 MAZARS- OVERSIGHT_COMMITTEE - 00018553 ; MAZARS - OVERSIGHT_COMMITTEE
00018555---

636 MAZARS OVERSIGHT COMMITTEE 00016648 ; MAZARS OVERSIGHT COMMITTEE
00016659 ;MAZARS OVERSIGHT_COMMITTEE 00016671; MAZARS OVERSIGHT_COMMITTEE
00016678.

139

ALBANIA

The records Mazars provided to the Committee show that during the Trump presidency,
the Prime Minister of Albania , Edi Rama , and his advisors , as well as an Albanian government
minister, spent approximately $ 6,000 at the Trump International Hotel in Washington , D.C.
Albania'sEmolumentSpendingat TrumpProperties

Date

January
2018
March

March

March

June

,

, 2018, 2018, 2018, 2018AmountLocation

Expenditure

Trump International Hotel(Washington , D.C.)

DorjanDucka, Advisorto
Mr.Rama$1,503637

Trump International Hotel(Washington , D.C.)

EdiRama, PrimeMinister$ 1,15863

Trump International Hotel(Washington , D.C.)

Endri Fuga, Advisor to Mr.

Trump International Hotel(Washington , D.C.)

Keisi Seferi, Advisor toTrump International Hotel

Damian Gjiknuri ,Minister of Infrastructure( Washington, D.C.)

638

ofAlbania$1,158639

Rama

1,158640

Mr. Rama$ 1,025641

and Energy
EMOLUMENTSPAID BY ALBANIA$ 6,002( 2017-2020)

Albania is a parliamentary democracy, and since September 2013 , it has been led byPrime Minister Edi Rama, a member of the Socialist Party. 642 In recent years , Albania has been a
key NATO ally, an opponent of Russian aggression, and an important player in combatting
terrorism.643 It has also suffered from pervasive corruption in all branches of government andmunicipal institutions. 644

637 MAZARS- OVERSIGHT_COMMITTEE- 00028926; MAZARS- OVERSIGHT_COMMITTEE
00028930.

638 MAZARS- OVERSIGHT_COMMITTEE- 00016568; MAZARS- OVERSIGHT_COMMITTEE
00016576 .

639 MAZARS- OVERSIGHT_COMMITTEE- 00016568; MAZARS- OVERSIGHT_COMMITTEE
00016577

640 MAZARS- OVERSIGHT_COMMITTEE- 00016569; MAZARS- OVERSIGHT_COMMITTEE
00016577

641 MAZARS-OVERSIGHT_COMMITTEE -00017647 ; MAZARS -OVERSIGHT_COMMITTEE

00017657 MAZARS - OVERSIGHT_COMMITTEE - 00017669 .

642 EdiRamaSwornin as Albania PM, BalkanInsight( Sept. 16, 2013) ( onlineat
https://balkaninsight.com/2013/09/16/edi-rama-sworn-in-as-albania-pm/).

643Former FBIAgent's Side Work Puts Bureau Under New Scrutiny, Washington Post (Feb. 13 , 2023)(online at www.washingtonpost.com/national-security/2023/02/13/mcgonigal-albania-deripaska-indictment-fbi/).
644 U.S. Department of State , 2020 Country Reports on Human Rights Practices : Albania (Mar. 30 ,2021)
140

At the time ofPresident Trump's election , the Albanian opposition party, the center -right
Democratic Party of Albania, and its former leader Lulzim Basha ( whose slogan was Make
Albania Great Again ) had accused Prime Minister Rama's Socialist Party of endemic corruption
and ties to organized crime.645 The 2017 Albanian parliamentary elections were contentious : inthe months preceding the election , Albania's Democratic Party boycotted the Albanian646
Following Mr. Rama's electoral victory , opposition groups
parliament and sponsored protests .
accused him of conspiring with organized crime groups and rigging the vote.647
Amidst this rancor and volatility , Albanian political parties turned to K Street to try togain a political advantage in Washington . The three main Albanian parties hired U.S.- based
lobbyists with close ties to then -President Trump ; two of the three parties reportedly funded theirlobbying services through obscure shell companies with ties to Russian interests.648 Mr.
Socialist Party retained the firm of Brian Ballard a Trump fundraiser and D.C. lobbyist— at a
rate of $ 20,000 a month.649 His political rival , Mr. Basha , hired Nicholas Muzin, a former aideto Senator Ted Cruz who had also advised the Trump campaign . As one Washington lobbyist
noted, a picture with the U.S. President often translated to political capital : The fact that[ foreign politicians ] could get a meeting , have a handshake and take a picture that gets
distributed far and wide back home that is gold to them . They'll almost do anything to achievethat 650 Accordingly , in the months leading up to the Albanian parliamentary election , Mr.

( online at www.state.gov/reports/2020-country-reports-on-human-rights-practices/albania/
) .

645

The Head of Albania's Conservative Party Faces Criminal Charges , and an Ex - Trump Aide Is Involved
Mother Jones (June 13, 2019 ) (online at www.motherjones.com/politics/2019/06/the-head-of-albanias-conservative
party-faces -criminal- charges -and-an-ex- trump -aide-is-involved ); Thousands ofAlbanians Callfor EdiRama's
Resignation ,Jazeera (Jan. 27 , 2018 ) (online at www.aljazeera.com/news/2018/1/27/thousands-of-albanians-callfor- edi-ramas- resignation ).

646 U.S. Diplomat Tries to Mediate Compromise in Albanian Politics, Associated Press (May 15, 2017)(online at www ksl.com/article/44254626/us-diplomat-tries-to-mediate-compromise-in-albanian-politics ) ; How a
Russian-LinkedShell Company Hired an Ex- Trump Aide to Boost Albania's Right-Wing Party in D.C., Mother Jones(Mar. 6, 2018) (online at www motherjones.com/politics/2018/03/how-a-russian-linked-shell-company-hired-an-ex
trump-aide-to-boost-albanias- right - wing-party-in-dc ) .
647 Albania President Cancels Elections, Citing Tense Climate , New York Times (June 9 , 2019) (online atwww.nytimes.com/2019/06/09/world/europe/albania-elections-canceled.html).

648 How a Mysterious Overseas Shell Company Used a Former GOP Congressman to Lobby Trump andCongress, Mother Jones ( Apr. 25, 2018 ) (online at www motherjones.com/politics/2018/04/how-a-mysterious
overseas- shell-company-used-a-former-gop-congressman -to- lobby-trump-and- congress/) ; How a Russian-Linked
Shell Company Hired an Ex- Trump Aide to Boost Albania's Right- Wing Party in D.C., Mother Jones (Mar. 6, 2018)( online at www motherjones.com/politics/2018/03/how-a-russian-linked-shell-company-hired-an-ex-trump-aide-to

boost-albanias-right-wing-party-in-dc ) . LSI, the third largest party, funded its lobbying through a Cypriot-shellcompany with ties to Russian oligarch Oleg Deripaska . Deripaska would later pay McGonigal to illegally assist him
in an effort to get U.S. sanctions lifted. Indictment, 10 (June 13 , 2003), United States ofAmerica v. Charles F.
McGonigal , D.D.C. ( No. 1:03 CV 00652 ) ; Department of Justice , Press Release : Former Special Agent In Charge
ofthe New York FBICounterintelligence Division Pleads Guilty to Conspiring To Violate U.S. Sanctions On Russia(Aug. 15, 2023) (online at www.justice.gov/usao-sdny/pr/former-special-agent-charge-new-york-fbi
counterintelligence -division-pleads - guilty).

How a Russian-Linked Shell Company Hired an Ex-Trump Aide to BoostAlbania's Right-Wing Party in
D.C. Mother Jones (Mar. 6, 2018) (online at www.motherjones.com/politics/2018/03/how-a-russian-linked-shellcompany-hired-an-ex- trump -aide-to-boost- albanias - right -wing - party-in-dc ) .
The Swamp That Trump Built, New York Times (Oct. 10 , 2020) (online at141

Muzinarrangedfor Mr. Bashato take a photowithPresidentTrump at a fundraiser. The
DemocraticParty ofAlbaniadisseminatedthe photo widely in an effort to portray a close
relationshipbetween Mr. Bashaand PresidentTrump 651
Accordingto a filing with the DOJpursuantto FARA, Mr. Ballardcontinuedto lobby on
behalfofPrimeMinisterRama'sparty through 2017, by updat[ ing] individualson current
eventsinAlbaniaand discuss[ ing] U.S.-Albania bi- lateralrelations with MembersofCongress
and State Departmentofficials

the nights of March 3 and March 4 , 2018, Albanian Prime Minister Edi Rama stayedat the Trump International Hotel in Washington , D.C., along with two advisors. Federal
prosecutors have alleged that on March 4 , Mr. Rama dined with Charles McGonigal, a former
FBI counterintelligence chief, and Agron Neza, a New Jersey businessman who previously
worked at an Albanian intelligence agency. 653 The DOJ determined that Mr. McGonigal had
previously traveled to Albania to meet with Mr. Rama several times and, by the time ofthe
March 4 meeting, Mr. McGonigal had received $225,000 in cash payments from Mr. Neza.
Mr. McGonigal had also allegedly passed along potentially damaging information about Mr.
Muzin the U.S. lobbyist for Mr. Rama's chiefrival from Mr. Rama's office to others in U.S.
law enforcement.655 In late February, less than a week before the McGonigal- Rama meeting, theFBI formally opened an investigation into an American lobbyist, thought to be Mr. Muzin, at
McGonigal's request and upon his guidance
Mr. McGonigal's work on behalf of Mr. Ramaand Mr. Neza would later be at the center of a federal criminal case brought against Mr.
McGonigal in 2022, several years after he left the Bureau. He has since pleaded guilty to one
count of illegally concealing from the FBI his business activities in Albania.657

www.nytimes.com/interactive/2020/10/10/us/trump-properties-swamphtml) .

The HeadofAlbania's ConservativeParty Faces Criminal Charges, andan Ex-Trump Aide is
Involved, Mother Jones (June 13, 2019) (online at www motherjones.com/politics/2019/06/the-head-of-albanias
conservative-party- faces-criminal-charges- and-an-ex-trump-aide-is-involved ) .
652

Departmentof Justice, SupplementalStatementPursuantto the ForeignAgents RegistrationActof
1938, asAmended(May 31, 2018) (online at https://efile fara.gov/docs/6415-Supplemental-Statement-20180531
2.pdf) .
653 Indictment United States v . McGonigal, No. 1:23 00021 (D.D.C. Jan. 18 , 2023 ) (online at.

www.justice.gov/usao-dc/press-release/file/1563516/download ); How Prosecutors Say a Top F.B.I. Agent Sold His
Services Overseas , New York Times (Feb. 3, 2023 ) (online at www.nytimes.com/2023/02/03/nyregion/fbi
intelligence -charged - albania html)
654
655

.

How Prosecutors Say a Top

Agent SoldHis Services Overseas, New York Times (Feb. 3 , 2023)( online at www nytimes.com/2023/02/03/nyregion/fbi-intelligence-charged-albania.html
).

656

.

Ex-FBICounterspyChiefMcGonigalPleads Guilty in PaymentPlot, WashingtonPost( Sept. 22, 2023)(onlineat www.washingtonpost.com/dc-md-va/2023/09/22/fbi-counterspy-mcgonigal-plea/) ; Departmentof Justice,
PressRelease: RetiredFBISpecialAgentin Charge PleadsGuiltyto ConcealingInformationfrom the FBI(Sept.
22, 2023) ( online at www.justice.gov/opa/pr/retired-fbi-special-agent-charge-pleads-guilty-concealing-informationfbi) ; IndictmentUnitedStates v. McGonigal, No. 1:23 00021(D.D.C.Jan. 18, 2023) (online atwww.justice.gov/usao-dc/press-release/file/1563516/download); How ProsecutorsSaya Top
Agent SoldHis
ServicesOverseas, NewYorkTimes (Feb. 3, 2023) (online at wwwnytimes.com/2023/02/03/nyregion/fbi
142

Emoluments Paid by Albania to Trump - Owned Businesses

Prime Minister Rama chose to patronize the Trump International Hotel in Washington ,D.C., during his March 2017 visit . Over the course of two nights , Mr. Rama and his aides spent$3,474 at the hotel. They stayed on the same floor as Mr. Neza.658
There is no indication in the records produced by Mazars that Mr. McGonigalstayed at
Trump International Hotel during this period in March 2017.
Separately, Mr. Dorjan Duçka , another Rama advisor, booked four rooms over two nights
at Trump International Hotel in Washington , D.C. on January 18 and January 19, 2018, at a costof $ 1,503.659

The Mazars records further show that Albania's then - Minister of Infrastructure andEnergy, Damian Gjiknuri , stayed at the Trump International Hotel in Washington , D.C. , from
June 24 through June 26, 2018 , spending $ 1,025.660

intelligence- charged - albania html) .
658

MAZARS- OVERSIGHT COMMITTEE- 00016568; MAZARS- OVERSIGHT COMMITTEE

00016569 ; MAZARS-OVERSIGHT_COMMITTEE -00016576 ; MAZARS-OVERSIGHT_COMMITTEE
00016577

659 MAZARS-OVERSIGHT_COMMITTEE -00028926 ; MAZARS-OVERSIGHT_COMMITTEE

00028930 .

660 MAZARS-OVERSIGHT_COMMITTEE - 00017647 ; MAZARS - OVERSIGHT_COMMITTEE
00017657 ;MAZARS - OVERSIGHT COMMITTEE - 00017669 ; MINISTRIA E INFRASTRUKTURES DHE

ENERGJISE , Minister of Infrastructure and Energy , Albania , Press Release : Minister Gjiknuri in Washington ,Meetings at the State Department (Feb. 6 , 2018) (online at www.infrastruktura.gov.al/en/minister-gjiknuri-in
washington - meetings -at- the -state- departmen ); Albanian PMReshuffles Cabinet After Student Protests , Reuters(Dec. 28 , 2018) (online at www.reuters.com/article/us-albania-government-reshuffle/albanian-pm-reshuffles
cabinet -after- student -protests -

).

143

KOSOVO

During the Trump Administration , Kosovo sought to leverage U.S. support in order togain greater international recognition, including from neighboring Serbia. The Mazars records
show that several officials from Kosovo's Ministry of Foreign Affairs including the thenDeputy Prime Minister and Foreign Minister, Behgjet Pacolli stayed at the Trump International
Hotel in Washington , D.C., in July 2018, spending nearly $5,000 at the hotel. Social media
posts indicate that other Kosovar officials again visited the property later in the Trump
Administration , but Mazars did not produce any documents to the Committee regarding that
visit . Kosovo eventually signed an economic cooperation agreement with Serbia at a WhiteHouse event over which then-President Trump presided.
Kosovar Emolument Spending at Trump Properties

Date

Location

July 25-26 , 2018

Trump International Hotel( Washington , D.C.)

Stay by Deputy Prime
Minister and Foreign
Minister of Kosovo

July 25-28 , 2018

Trump International Hotel

Stay by additionalofficials
ofthe Kosovo Ministryof

Expenditure

Amount661$ 9906

Behgjet Pacolli(Washington , D.C.)

662$

ForeignAffairs
EMOLUMENTSPAID BY KOSOVO$ 4,950( 2018)Inthe former Yugoslavia , Kosovo had been an autonomous province of Serbia. 663
While Serbians consider Kosovo to be the birthplace of their nation, more than 90% ofthe
population of Kosovo is ethnically Albanian.
A CRS report explains that by 1998, growing
ethnic unrest and violence in Kosovo, promoted by the Kosovo Liberation Army (KLA) , ledSerbian leader Slobodan Milosevic to launch a counterinsurgency campaign against the ethnic
Albanian and Kosovar communities in Kosovo."
According to the State Department, Serbianforces and paramilitaries implemented a systematic campaign to ethnically cleanse Kosovo.

661 MAZARS- OVERSIGHT_COMMITTEE - 00017891 ; MAZARS - OVERSIGHT_COMMITTEE
00017900 .

---

---

---

662 MAZARS OVERSIGHT_COMMITTEE 00017891 ; MAZARS OVERSIGHT_COMMITTEE
00017900 ;MAZARS OVERSIGHT COMMITTEE 00017910 ; MAZARS OVERSIGHT COMMITTEE.

00017911 ;MAZARS OVERSIGHT_COMMITTEE 00017919 ; MAZARS OVERSIGHT_COMMITTEE
00017920
663 Congressional Research Service , Kosovo : Background and U.S. Relations (Aug. 13 , 2018) (online athttps://crsreports.congress.gov/product/pdf/R/R44979/11 ) .

664

Kosovo: Why Is ViolenceFlaringBetweenEthnic Serbs and Albanians, BBC( Oct.2, 2023) (online at).
www.bbc.com/news/62382069
665

Congressional Research Service, Kosovo : Background and U.S. Relations (Aug. 13, 2018) (online athttps://crsreports.congress.gov/product/pdf/R/R44979/11 ) .
666,

Department of State Ethnic Cleansing in Kosovo

144: An Accounting, (Dec. 1999) (online at https:// 1997

Thousands were killed and [ o] ver 1.5 million Kosovar Albanians

at least 90 percent of theestimated 1998 Kosovar Albanian population of Kosovo were forcibly expelled from theirhomes
The United States joined NATO in an air campaign in an effort to end thehumanitarian crisis .668 According to CRS, the NATO operation ultimately forced the Serbs toagree to withdraw their military and police forces from Kosovo . 669

In2008, Kosovo declared its independence from Serbia , and by 2018 , Kosovo had been
" recognized by over 110 countries worldwide , including the United States , but Serbia ha[ d]refused to recognize Kosovo's independence , as ha[d] Russia , China , and several EU
countries 670
As part of Kosovo's campaign to garner greater American support for its effort to secureinternational recognition , a delegation from the Kosovar government including then- President
Hashim Thaçi visited the United States in January 2017 , where they reportedly met withseveral Republican Members of Congress and tried to initiate a relationship with the incoming
Trump Administration .

As reported in Balkan Insight, the government of Kosovo

long seen the Democrats as their country's natural allies in US politics

which hadkeen to remind

whoever runs Washington of their staunchly pro- American credentials .
The government of Kosovo also used U.N. General Assembly meetings as opportunities
to meet with world leaders and advance its effort to gain greater international recognition for thecountry . While in New York for the 2017 and 2019 General Assembly meetings , then - President
Thaçi met with then - President Trump .673 Media reports indicate that Behgjet Pacolli , who wasthen Deputy Prime Minister and Foreign Minister of Kosovo , was part of the Kosovo delegation
674

attending the 2017 and 2019 U.N. meetings.6

2001.state.gov/global/human_rights/kosovoii/pdf/kosovii.pdf
).

667

.

668 North Atlantic Treaty Organization, Kosovo Air Campaign (March June 1999) (May 17, 2022) (onlineat www.nato.int/cps/en/natohq/topics_49602.htm ).

669

CongressionalResearch Service, Kosovo: Backgroundand U.S. Relations (Aug. 13, 2018) ( online athttps://crsreports.congress.gov/product/pdf/R/R44979/10
).
670

.

671Ambassador Reminds Trump That Kosovo Loves America , Balkan Insight (Jan. 18 , 2017 ) (online athttps://balkaninsight.com/2017/01/18/kosovo-ambassador-in-us-brief-talk-with-trump-01-18-2017/
672

.

.

673

Thaçi Meets with U.S. President Donald Trump , Euronews . Albania (Sept. 25, 2019) (online athttps://euronews.al/en/president-of-kosovo-meets-u-s-president-donald-trump/ ) ; President Thaci Meets US
President Trump , Prishtina Insight (Sept. 20, 2017) (online at https://prishtinainsight.com/president-thaci-meets-uspresident -trump ) .
674

Thaçi Meetswith U.S. President Donald Trump, Euronews. Albania (Sept. 25 , 2019) (online athttps://euronews.al/en/president-of-kosovo-meets-u-s-president-donald-trump/); PresidentThaci Meets US
PresidentTrump, Prishtina Insight (Sept. 20, 2017) (online at https://prishtinainsight.com/president-thaci-meets-uspresident-trump ; CongressionalResearch Service, Kosovo: Background and U.S. Relations (Aug. 13, 2018)(online at https://crsreports.congress.gov/product/pdf/R/R44979/11) .
145

BrianBallard-

Trump fundraiserand D.C.lobbyist

reportedina filingwiththe DOJ

pursuantto FARAthat he beganto representKosovoon December22, 2017.675 InJune 2018,
Politicoreportedthat Ballardhad personallylobbiedTrump on behalfofthe county inApril
676
2018.6

The Trump Administration apparently proved interested in helping Kosovo and Serbia
improve their relationship . In December 2018 , Trump reportedly wrote to Thaçi and Serbian
President Aleksandar Vucic , dangling a potential Rose Garden peace ceremony if they could
resolve their differences 677 In October 2019 , shortly after that year's U.N. General Assembly,
then- President Trump appointed the U.S. Ambassador to Germany , Richard Grenell , to serve inan additional role as the special envoy for peace negotiations between Serbia and Kosovo. 678
InSeptember2020, at a White House event over whichthen- PresidentTrumppresided,
Serbiaand Kosovosignedan agreement to normalizeeconomicties[
The agreementdid not,however, provide for the full diplomaticrecognitionthat Kosovosoughtand thatthe Trump
Administrationand EuropeanUnionhad reportedlysupported.679

InOctober2020, Forbes reported:

President Donald Trump added a new line to his foreign policy resume this week,
repeatedly insisting he brokered an end to the violent conflict between Serbia andKosovo, even though the Kosovo War ended more than two decades ago a bizarre andinaccurate claim as the president looks to tout his dealmaking skills in the final week of
the campaign.
680

For example , speaking at a rally in Omaha , Nebraska , on October 27, 2020, thenPresident Trump referred to the arrangement between Kosovo and Serbia signed in the Oval
Office . He said :675

Department of Justice , Supplemental Statement Pursuant to the ForeignAgents Registration Act of1938, as Amended (May 31,2018) (online at https://efile.fara.gov/docs/6415-Supplemental-Statement-20180531
2.pdf).
676 Ballard Lobbied Trump on Kosovo , Politico (June 6 , 2018) (online atwww.politico.com/newsletters/politico-influence/2018/06/06/ballard-lobbied-trump-on-kosovo-244463).

SerbiaandKosovoSignBreakthroughEconomicAccordthat is ShortofNormalRelations, Washington
Post( Sept.4 , 2020) ( onlineat www.washingtonpost.com/politics/trump-kosovo-serbia
agreement/2020 / 09/ 04/ b1283f8c - eec0-11ea - 99a1-71343d03bc29_story html) .

678

Trump Names Ric Grenell His Special Envoyfor Serbia and Kosovo, Politico (Oct. 4, 2019) (online atwww.politico.eu/article/trump-names-ric-grenell-his-special-envoy-for-serbia-and-kosovo/ ) ; Thaçi Meets with U.S.
President Donald Trump , Euronews . Albania (Sept. 25, 2019 ) (online at https://euronews.al/en/president-of-kosovo
meets-u-s-president -donald-trump /# !) .
679 Serbia and Kosovo Sign Breakthrough Economic Accord that is Short of Normal Relations , Washington
Post ( Sept. 4 , 2020) ( online at www.washingtonpost.com/politics/trump-kosovo-serbia
agreement/ 2020/ 09/ 04/ b1283f8c- eec0-11ea- 99a1-71343d03bc29_storyhtml) .

680

Trump Takes Creditfor Ending Kosovo War , Which Ended In 1999, Forbes (Oct. 28, 2020) (online at

www forbes.com/sites/joewalsh/2020/10/28/trump-takes-credit-for-ending-kosovo-war-which-ended-in-1999/
146).

You know what, it took about 20 minutes . They'd been fighting for 40 years . I thinkthey'd been fighting for 400 years , you want to know the truth . But they'd been fighting
for a long time . They want to make a deal . All of a sudden, two months ago , they're in
the oval office hugging the two prime ministers [] hugging and kissing.

681

Then-President Trump also said that,as a result ofthe deal, We save a lot of lives,that's
a good thing 682
Total Kosovar Emolument Spending

Records produced to the Committee by Mazars show that Kosovo's then -Deputy Prime
Minister and Foreign Minister Pacolli stayed at the Trump International Hotel in Washington ,D.C., on July 25 and July 26, 2018. He was accompanied by two other officials from theKosovo Ministry of Foreign Affairs , including Jetlir Zyberaj , an advisor to Mr. Pacolli; both ofthese officials stayed at the hotel for additional days after it appears that Mr. Pacolli had left. 683
Together , all of the rooms booked by the Kosovar officials at the hotel cost $ 4,950.684

A social media post indicates that approximately two years later, then-Kosovar Justice
Minister Selim Selimi and then-Kosovar Foreign Minister Meliza Haradinaj (who was Foreign
Minister of Kosovo subsequent to Pacolli) met with Ambassador Grenell at the Trump
International Hotel in Washington , D.C., in 2020 at or about the time Serbia and Kosovo signed
the economic normalization deal at the White House.685 The Committee has not received any
documents from Mazars indicating whether or not the Kosovar officials made payments toTrump -owned entities during this time.

681 President Trump Campaign Rally in Omaha , Nebraska, C-SPAN (Oct. 27 , 2020) (online at www.cspan.org/video/?477342-1/president-trump-campaign-rally-omaha-nebraska ).
682.

683 Kosovo Bans Serbian Officials inNew Diplomatic Dispute , Radio Free Europe/ Radio Liberty (July 4 ,

-- -

-- -

-- -

2019) (online at www.rferl.org/a/kosovo-bans-serbian-officials-in-new-diplomatic-dispute/30037050html).

684 MAZARS OVERSIGHT COMMITTEE 00017891 ;MAZARS OVERSIGHT COMMITTEE
00017900 MAZARS OVERSIGHT COMMITTEE 00017910 ; MAZARS OVERSIGHT COMMITTEE
00017911 ;MAZARS OVERSIGHT_COMMITTEE 00017919 ; MAZARS OVERSIGHT_COMMITTEE
00017920.

685 AdriatikKelemendi, Facebook( Sept.5 , 2020) ( online atwww.facebook.com/adriatik
kelmendi/posts/pfbid02rJEdPxW2P4BxBc77yS1CuSq5zqACEpWNmFf4Jdts4SVZpn) ; Meliza Haradinaj (@MelizaHaradinaj), X (formerlyTwitter) (Sept.5, 2020) (online athttps://x.com/MelizaHaradinaj/status/1302225600887828481?s=20) ; Haradinaj-StubllaResignsas ForeignMinister
andQuitsAAK, PrishtinaInsight (Mar. 9 , 2021) ( onlineat https://prishtinainsight.com/haradinaj-stublla-resigns-as
foreign-minister-and- quits-aak) ; KosovoAmericanEducationFund, Facebook(June 5 , 2020) (onlineat
www.facebook.com/kaefonline/photos/a.10150263607456156/10157181290271156/?type=3).
147

ADDITIONALEMOLUMENTSPENDING

The ledgers provided to the Committee by Mazars record several additional governments
whose officials patronized President Trump's businesses while he was in office . These
emoluments are enumerated below .

Date

Location

Expenditure

Amount2018

Trump World Tower

PermanentMissionof$ 38,30268( New York, NY)

Afghanistan( 2018)686

EstimatedTotal
Emolumentfor

4 Years:$ 153,208( 2017-2020)

February23-25,

Trump International Hotel2018( Washington, D.C.)

KhanAgha Rezayee,
MemberofParlia

September 24

Trump International Hotelfrom Kabul, Afghanistan
Self- DeclaredTurkish$ 8,800688

Republicof Northern
Cyprus
KorneliosKorneliou,$ 590627, 2017

February( Washington , D.C.)
Trump InternationalHotel

,

2018

( Washington, D.C.)

October 11-12 ,Trump InternationalHotel( Washington, D.C.)

2017---. -$ 1,542687

689

PermanentRepresentative
ofthe Republicof
Cyprus to the United
Nations
TimurSuleimenov,$ 1,050

Minister ofNational
Economyof Kazakhstan

-----

-----

686 MAZARS OVERSIGHT_COMMITTEE 00027356 ; MAZARS OVERSIGHT_COMMITTEE

00027402 ;MAZARS OVERSIGHT_COMMITTEE 00027449 ; MAZARS OVERSIGHT_COMMITTEE
00027498 MAZARS OVERSIGHT_COMMITTEE 00027556 ; MAZARS OVERSIGHT_COMMITTEE
00027613 ;MAZARS OVERSIGHT COMMITTEE 00027707 ; MAZARS OVERSIGHT COMMITTEE
00027661 MAZARS OVERSIGHT_COMMITTEE 00027754 ; MAZARS OVERSIGHT_COMMITTEE
00027796 ;MAZARS OVERSIGHT_COMMITTEE 000027839 ; MAZARS OVERSIGHT_COMMITTEE
00027884

687 MAZARS-OVERSIGHT_COMMITTEE -00019372 ; MAZARS-OVERSIGHT_COMMITTEE
00019379 MAZARS-OVERSIGHT_COMMITTEE -00019384.
688 MAZARS OVERSIGHT COMMITTEE 00018392 ; MAZARS OVERSIGHT COMMITTEE
00018400 ;MAZARS OVERSIGHT_COMMITTEE 00018411;MAZARS OVERSIGHT_COMMITTEE
00018412 MAZARS OVERSIGHT_COMMITTEE 00018423

-

-

.

-

-

689 MAZARS - OVERSIGHT_COMMITTEE - 00019247 ; MAZARS - OVERSIGHT_COMMITTEE
00019252.

MAZARS- OVERSIGHT_COMMITTEE - 00018542 ; MAZARS - OVERSIGHT_COMMITTEE
00018553

148

October 11-14,

Trump InternationalHotel2017 and April( Washington, D.C.)

DaniyarAkishev,
Governorofthe National

17-21, 2018$

BankofKazakhstan; andadditionalofficials fromthe NationalBankof
Kazakhstan(staysfor each person
varied within the specified
timeframes)

TrumpInternationalHotel( Washington, D.C.
)

October 11-12,
2017

Arman Sapargaliyev ,Second Secretary at the$1,050692

Embassy of Kazakhstan
in the U.S.
May28-31, 2018

Adil Mukhamejanov ,Chairmanofthe

Trump InternationalHotel( Washington, D.C.)$ 1,411693

ManagementBoardof
KazakhstanHousing
Company
May 29-31, 2018

Trump International Hotel( Washington, D.C.)

Ainur Kuatova, Managing
Directorandmemberof694$ 1,05069

the ExecutiveBoardof
BaiterekNational
ManagingHolding( Kazakhstan)

July 24-25 , 2018

Trump International Hotel

Embassy of Lebanon

7,720695( Washington , D.C.)--.

-- --- , --August 18-24,

Trump International Hotel

Grisada Boonrach,2018( Washington, D.C.
)

Minister for Agriculture$ 11,3406 6

691 MAZARS OVERSIGHT_COMMITTEE 00018546 ; MAZARS OVERSIGHT_COMMITTEE

00018554 ;MAZARS OVERSIGHT_COMMITTEE
00018558 ;MAZARS OVERSIGHT_COMMITTEE
00018566 ;MAZARS OVERSIGHT_COMMITTEE
00018568 MAZARS OVERSIGHT_COMMITTEE
00017007 ;MAZARS OVERSIGHT_COMMITTEE
00017036 ; MAZARS OVERSIGHT_COMMITTEE
00017052

00018557 MAZARS OVERSIGHT_COMMITTEE
00018564 ; MAZARS OVERSIGHT_COMMITTEE
00018567 ; MAZARS OVERSIGHT_COMMITTEE
00016982 ; MAZARS OVERSIGHT_COMMITTEE
00017022 MAZARS OVERSIGHT_COMMITTEE
00017037 ; MAZARS OVERSIGHT_COMMITTEE

692 MAZARS- OVERSIGHT_COMMITTEE - 00018543 ; MAZARS - OVERSIGHT_COMMITTEE
00018554---

693 MAZARS OVERSIGHT COMMITTEE 00017410 ; MAZARS OVERSIGHT COMMITTEE
00017415 MAZARS OVERSIGHT_COMMITTEE 00017421 ;MAZARS OVERSIGHT_COMMITTEE
00017428.

694 MAZARS-OVERSIGHT_COMMITTEE -00017417 ; MAZARS-OVERSIGHT_COMMITTEE
00017422 MAZARS-OVERSIGHT_COMMITTEE -00017430 .
695

MAZARS-OVERSIGHT_COMMITTEE -00017883 ; MAZARS -OVERSIGHT_COMMITTEE

00017894 ;MAZARS - OVERSIGHT_COMMITTEE - 00017895 .

696 MAZARS- OVERSIGHT_COMMITTEE - 00018079 ; MAZARS - OVERSIGHT_COMMITTEE
149

and Cooperatives ofThailand and additional
officials from theGovernment of Thailand(stays for each person
varied within the specified
time periods)
October 7-15,

TrumpInternationalHotel2017 andApril
17-23, 2018

( Washington, D.C.)

April24-25,
2018

Trump International Hotel

Bayartsaikhan Nadmid,
Governor , Bank of

8,486697

Mongolia$1,011698

György Janos Barcza,
Chief Executive Officer ,( Washington, D.C.)

Government Debt
Management Agency of
Hungary
October 11-15,

Trump International Hotel

Ilmars Rimsevics,

2017( Washington , D.C.)

Governor, Bankof Latvia$ 2,73969 9

Afghanistan spent money at both Trump World Tower in New York and the Trump
International Hotel in Washington , D.C., during then -President Trump's term . The
Permanent Mission of Afghanistan maintained a unit at Trump World Tower throughout
the Trump presidency , incurring $ 38,302 in common monthly charges for that unit in2018

as noted, the only year for which Mazars provided records of expenditures at
Trump World Tower
Assuming the monthly charges did not change during President

--

--

--

00018088 MAZARS OVERSIGHT_COMMITTEE 00018089 ; MAZARS OVERSIGHT_COMMITTEE

00018095 ;MAZARS OVERSIGHT COMMITTEE 00018100 ; MAZARS OVERSIGHT COMMITTEE
00018106 MAZARS OVERSIGHT_COMMITTEE 00018113 ; MAZARS OVERSIGHT_COMMITTEE
00018124

.

----

----

----

697 MAZARS OVERSIGHT COMMITTEE 00018509 ; MAZARS OVERSIGHT COMMITTEE
00018516 MAZARS OVERSIGHT_COMMITTEE 00018526 ; MAZARS OVERSIGHT_COMMITTEE
00018536 ;MAZARS OVERSIGHT_COMMITTEE 00018548 ; MAZARS OVERSIGHT_COMMITTEE
00018559 MAZARS OVERSIGHT_COMMITTEE 00018569 ; MAZARS OVERSIGHT_COMMITTEE
00018577 MAZARS OVERSIGHT_COMMITTEE 00018582 ; MAZARS OVERSIGHT_COMMITTEE
00016978 ;MAZARS OVERSIGHT COMMITTEE 00017001 ; MAZARS OVERSIGHT COMMITTEE
00017020 ;MAZARS OVERSIGHT COMMITTEE 00017034 ; MAZARS OVERSIGHT COMMITTEE
00017049 MAZARS OVERSIGHT_COMMITTEE 00017064 ; MAZARS OVERSIGHT_COMMITTEE
00017072

.

-

-

-

698 MAZARS-OVERSIGHT_COMMITTEE -00017082 ; MAZARS -OVERSIGHT_COMMITTEE
00017094
699

MAZARS- OVERSIGHT COMMITTEE - 00018541 ; MAZARS - OVERSIGHT

COMMITTEE

00018557 MAZARS-OVERSIGHT_COMMITTEE-00018566; MAZARS-OVERSIGHT_COMMITTEE
00018575 MAZARS-OVERSIGHT_COMMITTEE-00018581.
700

New York City Department of Finance, Document ID: 2009082401334002 (Aug. 21, 2009) (online athttps://a836-acris.nyc.gov/DS/DocumentSearch/DocumentImageView?doc_id=2009082401334002 ) (accessed Dec.
7, 2023) New York City Department of Finance, Assessment Roll 2016-2017, Borough: Manhattan, Block: 1340,
Lot: 1212 (Jan. 5, 2016) (accessed Dec. 6, 2023); New York City Department of Finance, Assessment Roll2017
2018, Borough: Manhattan, Block: 1340, Lot: 1212 (Jan. 5, 2017) (accessed Dec. 6, 2023) ; New York City
150

Trump's four-year term, this report estimates that Afghanistan spent $153,208 on
Incommon monthly charges for the unit during President Trump's time in office .
addition, the records provided by Mazars show that Khan Agha Rezayee, a Member ofAfghanistan's Parliament, paid $ 1,542 for a stay at the Trump International Hotel inWashington, D.C., in late February 2018.702
Officialsfromthe self- declaredTurkishRepublicof NorthernCyprus rentedmultiple
roomsat Trump InternationalHotelin Washington, D.C., from September24 throughSeptember27, 2017, spending$ 8,800.703 A militarized greenline dividesthe island of
Cyprus, separatingthe Turkish- controllednorthernsector from the southern,predominantly Greek - speaking nation of the Republic of Cyprus . Turkish control ofthe
northern enclave is not recognized by any other nation . The U.N. peace - keeping mission
Cyprus is one of the longest running in U.N. history 704
Kornelios Korneliou , a member of the diplomatic service of the Republic of Cyprus ,patronized the Trump International Hotel in Washington , D.C. , on at least one occasion ,spending $ 590 for two nights in early February 2018. At the time , he was Cyprus's
Permanent Representative to the U.N.705

Departmentof Finance, Assessment Roll 2018-2019, Borough: Manhattan, Block: 1340, Lot: 1212 (Jan. 5 , 2018)( accessedDec. 6 , 2023) ; New York City Department of Finance, Final Assessment Roll 2019-2020, Borough:Manhattan, Block: 1340, Lot: 1212 (Jan. 5 , 2019) ( accessed Dec. 6 , 2023) ; New York City Department of Finance,
Final Assessment Roll 2020-2021, Borough: Manhattan, Block: 1340, Lot: 1212 (Jan. 5 , 2020) (accessed Dec.6 ,2023) New York City Department of Finance, Final Assessment Roll 2021-2022, Borough: Manhattan, Block:
1340, Lot: 1212 (Jan. 5 , 2021) ( accessed Dec. 6 , 2023)

000274--. ----MAZARS OVERSIGHT COMMITTEE 00027---

MAZARS OVERSIGHT COMMITTEE

701 MAZARS- OVERSIGHT_COMMITTEE- 00027356; MAZARS- OVERSIGHT_COMMITTEE

00027498 ;MAZARS OVERSIGHT COMMITTEE 00027556 ; MAZARS OVERSIGHT COMMITTEE
00027613 ;MAZARS OVERSIGHT COMMITTEE 00027707 ; MAZARS OVERSIGHT COMMITTEE
00027661 ;MAZARS OVERSIGHT COMMITTEE 00027754 ; MAZARS OVERSIGHT COMMITTEE
00027796 ;MAZARS OVERSIGHT_COMMITTEE 00027839 ; MAZARS OVERSIGHT_COMMITTEE
00027884

702 MAZARS-OVERSIGHT COMMITTEE-00019372; MAZARS-OVERSIGHT COMMITTEE
00019379 MAZARS-OVERSIGHT_COMMITTEE-00019384; Khan Rezayee, LinkedIn (online athttps://af.linkedin.com/in/khan-rezayee-58578b47) (accessed Oct. 31, 2023); Young, Modern Afghans Fear Losing
Everything'as Taliban Regains Ground, PBS (July 14, 2021) (online at www.pbs.org/newshour/show/young
modern-afghans-fear-losing-everything-as-taliban-regains -ground).
703 MAZARS- OVERSIGHT_COMMITTEE-00018392 ; MAZARS- OVERSIGHT_COMMITTEE
00018400; MAZARS-OVERSIGHT COMMITTEE-00018411; MAZARS- OVERSIGHT COMMITTEE
00018412; MAZARS-OVERSIGHT_COMMITTEE-00018423.
704 Erdogan's Visit to Northern Cyprus Stokes Decades-Long Dispute , New York Times (Nov. 17, 2020)( online at www nytimes.com/2020/11/15/world/europe/cyprus-turkey-erdogan.html ) .

705 MAZARS-OVERSIGHT_COMMITTEE-00019247; MAZARS-OVERSIGHT_COMMITTEE
00019252; Kornelius S. Korneliou, LinkedIn (online at https://il.linkedin.com/in/kornelios-s-korneliou
2337633b/en) (accessed Oct. 31, 2023) ; Embassy of the Republic of Cyprus in Tel Aviv,Ambassador Kornelios S.
Korneliou, Ministry of Foreign Affairs of the Republic of Cyprus (online at
http://www mfa.gov.cy/mfa/embassies/embassy_telaviv.nsf/DMLambassador_en/DMLambassador_en) (accessed
Oct. 31, 2023).
151

Inaddition, recordsproducedto the Committeeby Mazarsalso show that inMay2018,
the InternationalCoordinatingCommittee Justice for Cyprus(PSEKA) , an advocacy
groupthatcondemnsthe Turkishoccupationof NorthernCyprus, held a conferenceat the
TrumpInternationalHotelinWashington, D.C., and spent$ 11,421on rooms.706 The
explicitpurposeofthe gatheringwas to influencethen- PresidentTrump. Newsreports
statedthatthe Cyprus NewsAgency, a partiallygovernment-funded news outlet, claimed
itsmemberswere looking into ways of exertinginfluenceon US PresidentDonald
Trump witha view to avertingthe Islamizationofthe TurkishoccupiedpartofCyprus.
Reportedly, at least three foreigngovernmentofficialsattendedthe gathering, including
the mayorsoftwo Cypriottowns anda memberofthe Greek parliament. The head of
PSEKAopenedthe eventby stating:get the message.

Trump is not a politician, andwe hope that he can

The Republic of Kazakhstan , including nine government officials , spent at least$ 21,311 at the Trump International Hotel in Washington , D.C , in the fall of 2017 and thespring of2018. These officials included the Kazakh Minister of National Economy,
Timur Suleimenov , and other officials from the National Bank of Kazakhstan , including
its Chairman , Daniyar Akishev . The Second Secretary of the Embassy of Kazakhstan ,Arman Sapargaliyev , also stayed at the hotel.708 The names of the Minister , theChairman, and the other officials from the National Bank of Kazakhstan appear among
the Accredited Members ofthe Delegations at the 2017 Annual Meetings included in
the Summary Proceedings of the World Bank's 2017 Annual Meetings of the BoardsofGovernors , which were held between October 13 and October 15 ,706 MAZARS-OVERSIGHT_COMMITTEE -00017355 ; MAZARS-OVERSIGHT_COMMITTEE
00017366 MAZARS-OVERSIGHT_COMMITTEE -00017376 ; MAZARS-OVERSIGHT_COMMITTEE
00017377 ;PSEKA International Coordinating Committee Justice for Cyprus ,About PSEKA (online athttps://pseka.org/about/) (accessed Oct. 27 ,2023).
707

DelegationFrom Mueller-Scrutinized Cyprus Gets Sweet Dealat Trump's D.C. Hotel, The Daily Beast(June 18, 2018) (online at www.thedailybeast.com/delegation-from-mueller-scrutinized-cyprus-gets-sweet-deal-at

trumps-dc-hotel); PSEKA Conference Delegates Highlight Need to Inform US Administration aboutthe Danger ofOccupied Cyprus Islamization, Parikiaki (May 23, 2018) (online at www.parikiaki.com/2018/05/pseka-conferencedelegates-highlight-need-to-inform-us-administration-about-the-danger -of-occupied-cyprus-islamization ).

---------,
00017037 ;MAZARS -OVERSIGHT_COMMITTEE -00017052 ; Kazakh President Appoints New
Minister,
Minister of National Economy , Astana Times (Dec. 29 ,2016) (online at https://astanatimes.com/2016/12/kazakh- -new- -minister -minister-of-national-economy/ ;Official Website of the President of the
Republic of Kazakhstan , Eventswith the Chairman of the National Bank of Kazakhstan Daniyer Akishev
3 ,2016 online atof-the-national-bank -of-kazakhstan -daniyar-akishev-5);U.S. Department of State , Embassy of the Republic of
Kazakhstan (Archived Content from Jan. 20 ,2009 to Jan. 20,2017) (online at https ://2009
htm#K) .
MAZARS OVERSIGHT_COMMITTEE
708MAZARS- OVERSIGHT_COMMITTEE- 00018542;
00018543 MAZARS OVERSIGHT_COMMITTEE 00018546; MAZARS OVERSIGHT_COMMITTEE
00018553. MAZARS OVERSIGHT COMMITTEE 00018554 ; MAZARS OVERSIGHT COMMITTEE
00018557;MAZARS OVERSIGHT_COMMITTEE 00018558 ;MAZARS OVERSIGHT_COMMITTEE
00018564 MAZARS OVERSIGHT_COMMITTEE 00018566 ; MAZARS OVERSIGHT_COMMITTEE
00018567 ;MAZARS OVERSIGHT COMMITTEE 00018568; MAZARS OVERSIGHT COMMITTEE
00016982 ;MAZARS OVERSIGHT COMMITTEE 00017007 ; MAZARS OVERSIGHT COMMITTEE
00017022 MAZARS OVERSIGHT_COMMITTEE 00017036 ; MAZARS OVERSIGHT_COMMITTEE
Foreignpresident appoints)

foreign

Meeting(Aug.

)(

www.akorda.kz/en/events/akorda_news/meetings_and_receptions/meeting-with-chairman

2017.state.gov/s/cpr/rls/dpl/221208
709

The World Bank Group, 2017AnnualMeetings ofthe BoardsofGovernors SummaryProceedings(Oct.
152

Kuatova , Managing Director and member of the Executive Board of the state - owned
Baiterek National Managing Holding , stayed at the hotel in late May 2018 , spending$ 1,050.710 Also staying at the Trump International Hotel in Washington , D.C., in late
May 2018 , was Adil Mukhamejanov , Chairman of the Management Board of Kazakhstan
711

Housing Company , who spent $ 1,411.7

The records provided to the Committee by Mazars indicate that the Embassy of
Lebanon made two expenditures at a Trump - owned property .

Embassy of Lebanon

Transient Bookings appears on a list of embassies that had accounts at a Trump -owned
property . The Start Date for this account was March 20, 2017 just weeks after
President Trump took office.712 Mazars did not provide any documents showing theamount of or services provided for this expenditure , or the specific location of theexpenditure . The second expenditure was made at the Trump International Hotel inWashington , D.C. , on the nights of July 24 and July 25, 2018 , when the Embassy of
Lebanon booked nine rooms at a cost of $ 7,720.713

The Minister for Agriculture and Cooperatives of Thailand , Grisada Boonrach, stayed at
the Trump International Hotel in Washington , D.C., on the nights ofAugust 18 to August22, 2018. He was accompanied by additional officials from the Government of Thailand
who stayed at the hotel on the nights of August 18 through August 24, 2018. Together,714
they spent $11,340 at the hotel.
The Governorofthe Bank of Mongolia, Bayartsaikhan Nadmid, stayed at the Trump
International Hotel in Washington, D.C., on the nights of October 7 through October 15,

13-15,2017) (online at https ://documents 1.worldbank.org/curated/es/400001527620999731/pdf/2017-Summary
Proceedings -cleared - by - YT - 05232018.pdf).
MAZARS-OVERSIGHT_COMMITTEE -00017417 ; MAZARS - OVERSIGHT_COMMITTEE
00017422 ; MAZARS - OVERSIGHT_COMMITTEE -00017430 ; Ainur Kuatova , LinkedIn (online athttps://kz.linkedin.com/in/ainur-kuatova-7a3a2b6 ) (accessed Oct. 31,2023).
MAZARS-OVERSIGHT_COMMITTEE-00017410 ; MAZARS-OVERSIGHT_COMMITTEE
00017415; MAZARS -OVERSIGHT COMMITTEE-00017421; MAZARS-OVERSIGHT COMMITTEE

00017428; Baiterek, Mukhamejanov Adil Bektasovich, Deputy Chairman of the Management Board (online athttps://baiterek.gov kz/en/about-holding/management/ management/mukhamedzhanov-adil-bektasovich ) (accessed
Oct. 31, 2023) .
MAZARS- OVERSIGHT_COMMITTEE - 00008041.

713 MAZARS-OVERSIGHT_COMMITTEE-00017883; MAZARS-OVERSIGHT_COMMITTEE
00017894 MAZARS-OVERSIGHT_COMMITTEE-00017895.
714 MAZARS-OVERSIGHT_COMMITTEE - 00018079 ; MAZARS- OVERSIGHT_COMMITTEE
00018088 ; MAZARS - OVERSIGHT COMMITTEE -00018089 ; MAZARS -OVERSIGHT COMMITTEE
00018095 ; MAZARS - OVERSIGHT COMMITTEE - 00018100 ; MAZARS -OVERSIGHT COMMITTEE
00018106 ; MAZARS - OVERSIGHT_COMMITTEE -00018113 ; MAZARS -OVERSIGHT_COMMITTEE
00018124 Thai Cabinet Reshuffle Underlines Junta's Bid to Reach Farmers , Nikkei Asia (Nov. 17, 2017) (online athttps://asia.nikkei.com/Politics/Thai-cabinet-reshuffle-underlines-junta-s-bid-to-reach-farmers ); Committee on
World Food Security , Forty-Fifth Session (Oct. 15-19,2018) (online at www.gisa-unr.com/pdf/fao2018
delegados.pdf).

1532017, and again on the nights of April 17 through April 23, 2018, spending a combined
total of$8,486.715
The Chief Executive Officer of the Government Debt Management Agency of Hungary,György Janos Barcza, stayed at the Trump International Hotel in Washington, D.C., on
the nights of April 24 and April 25, 2018, spending $1,011.7¹6
The Governorofthe BankofLatvia, IlmarsRimsevics, stayed at the TrumpInternational
Hotelin Washington, D.C., from October 11 through October 15, 2017, spending$2,739.
By virtue ofhis positionatthe Bank ofLatvia, Mr.Rimsevicswas also on the governing
councilofthe EuropeanCentralBank.
717

-- --

-- --

-- --

715 MAZARS OVERSIGHT_COMMITTEE 00018509 ;MAZARS OVERSIGHT_COMMITTEE
00018516 ;MAZARS OVERSIGHT COMMITTEE 00018526 ; MAZARS OVERSIGHT COMMITTEE
00018536 MAZARS OVERSIGHT_COMMITTEE 00018548 ; MAZARS OVERSIGHT_COMMITTEE
00018559 ;MAZARS OVERSIGHT_COMMITTEE 00018569 ; MAZARS OVERSIGHT_COMMITTEEARS OVERSIGHT COMMITTEE 00018582 ; MAZARS OVERSIGHT COMMITTEE
00018577;
00016978 MAZARS OVERSIGHT COMMITTEE 00017001 ; MAZARS OVERSIGHT COMMITTEE
00017020 MAZARS OVERSIGHT COMMITTEE 00017034 ; MAZARS OVERSIGHT COMMITTEE
00017049 ;MAZARS OVERSIGHT COMMITTEE 00017064 ; MAZARS OVERSIGHT COMMITTEE

--

--

,

--

,

00017072 Mongolia Governor Replaced Two Years Before End of Term Central Banking (July 21 2016) (online atwww.centralbanking.com/central-banking/news/2465628/mongolia-governor-replaced-two-years-before-end-of
term );The World Bank Group 2017 Annual Meetings of the Board of Governors Summary Proceedings (Oct.
15 2017)(online at https://documents1.worldbank.org/curated/es/400001527620999731/pdf/2017-Summary

,

,

-

- - -

.

Proceedings cleared by YT 05232018.pdf)

716 MAZARS- OVERSIGHT_COMMITTEE -00017082 ; MAZARS - OVERSIGHT_COMMITTEE
00017094 György Barcza (online at https://hu.linkedin.com/in/gy%C3%B6rgy-barcza-8206231b9 ) (accessed Oct.
10, 2023 ) ; Államadósság Kezel Központ Zrt ., Goals, Activities, and Legal Framework (Apr. 7, 2020) (online athttps://akk.hu/introduction/goals-activities-legal ) ; The World Bank Group , 2016 Sovereign Debt Management
Forum: Sovereign Debt Management in Emerging Markets : Is the Party Over ? (Oct. 19-20 , 2016) (online atwww.worldbank.org/en/events/2017/09/27/2016-sovereign-debt-management-forum ).
717 MAZARS -OVERSIGHT_COMMITTEE -00018541 ; MAZARS -OVERSIGHT_COMMITTEE
00018557 MAZARS - OVERSIGHT_COMMITTEE -00018566 ; MAZARS -OVERSIGHT_COMMITTEE

00018575 ; MAZARS - OVERSIGHT_COMMITTEE -00018581 ; Former ECB Governor to Testify on Bribery
Allegations , Reuters (July 4 , 2023) (online at www.reuters.com/world/europe/former-ecb-governor-testify-bribery
allegations -2023-07-04 ; ECB Slams Latvia for Banning Rimsevics Before Criminal Case , Bloomberg (Sept. 25 ,2018)(online at www.bloomberg.com/news/articles/2018-09-25/ecb-slams-latvia-for-banning-rimsevics-before
criminal -case);ECB Seeks EU Court Ruling on Latvian Central Bank Governor , New York Daily News (Apr. 7 ,2018) (online at www nydailynews.com/2018/04/06/ecb-seeks-eu-court-ruling-on-latvian-central-bank-governor/
154

.

)

ADDITIONAL

COUNTRIES WITH ACCOUNTS AT TRUMP - OWNED BUSINESSES

Inaddition to the documents recording the emoluments included in this report, therecords produced to the Committee by Mazars include an email from Michael Levchuck , theArea Director of Finance for the Trump International Hotel and Tower in New York and the
Trump International Hotel in Washington , D.C., to Donald Bender at Mazars , which includes anattachment referred to as an Embassy List from HMS

This list identifies more than a dozen

countries that apparently had accounts at a Trump property . For several of the countries andevents on the list such as the Embassy of the Philippines National Day Reception and theEmbassy ofMalaysia Delegation

produced records that provide at least some basic

details on the expenditures . However , the list includes the following country/ event accounts
with start dates after Donald Trump had been elected President but for which Mazars produced
no other records to the Committee :Embassy of Azeirbaijan [sic] 12/ 14/ 16- Conference of Presidents (start date
12/14/2016) ;Embassy ofGeorgia Delegation ( start date 03/30/2017) ;EmbassyofNamibiaVIP Visit ( start date 06/09/2017);

Embassy ofRomania VIP Visit

United States Embassy( start date 05/31/2017, end date 06/11/2017) ; andCosta Rica ( start date 05/01/2017)

Given the absence of relevant records, this report cannot determine the purposes andamounts ofthese countries expenditures at Trump- owned properties during President Trump's
term.

718 MAZARS- OVERSIGHT_COMMITTEE- 0008040.

719 MAZARS- OVERSIGHT_COMMITTEE- 0008041.

155

CONCLUSION

This report has documented the payment of many millions of dollars in unconstitutional
emoluments to Trump- owned businesses from at least 20 foreign governments as well as entities
and lobbyists acting on their behalf. As noted, given the incompleteness of the documents
received by the Committee and Chairman Comer's decision to act in concert with former
President Trump's attorneys to block the production of additional records , this total is likely but
a small fraction ofthe full universe of foreign emolument spending that took place during the
Trump presidency in violation ofthe U.S. Constitution .

President Trump's pervasive use of the presidency for personal financial gain isparticularly alarming given not only the significant dollar amounts and multiplicity ofcountries
involved, but also former President Trump's repeated indications of his willingness to allow his
personal financial interest to dictate policy decisions he made as President . The rich profits that
Trump businesses reaped from those countries , at best, leaves subject to question whether theoften favorable treatment they received from the Trump Administration resulted from the former
President's bona fide judgment about advancing the vital interests of the United States, or hisdesire to perpetuate the substantial personal enrichment he enjoyed from the lavish emolument
spending by those countries .
As he acceptedthese payments, Mr. Trump ignoredthe Foreign EmolumentClause's
explicit requirementthat he obtain congressional authorization before pocketingsuch
never even seeking, let alone securing, the consent of Congress to his receipt of these large- scaleemoluments. No president has ever come so close to brazenly ignoringthe ForeignEmoluments
Clause.

These facts demonstrate the need for urgent congressional action to prevent futurepresidents and senior officials from serving under similarly grave conflicts of interest andunconstitutional arrangements . Accordingly , this report recommends that Congress
expeditiously consider adopting measures that would require presidents and senior executive
officials to disclose to Congress their receipt of any foreign emoluments , set forth an explicit
procedure for presidents and senior officials to seek the requisite congressional authorization for
the receipt and retention of emoluments , and require the disclosure of payments to entities inwhich a sitting president has a financial interest of any kind whatever by officials and lobbyists
acting on behalf of kings, princes, and foreign governments .

156