Why Trump Actually Does Want To Make Overt Corporate Bribery Legal

Earlier today, we looked at how Trump is changing housing laws to normalize his own-- and his family's-- endemic racism. But that isn't the only law he's changing to justify his own ugly behavior patterns. Writing Sunday for HuffPo, Mary Papenfuss warned that Trump wants to change the laws that make foreign bribery illegal. Trump literally wants to change the statute making it illegal for American corporations to bribe foreign officials! Larry Kudlow admitted the regime is looking into changing the Foreign Corrupt Practices Act. Kudlow, a notorious coke addict who works for Trump: "I would just say: We are aware of it, we are looking at it, and we’ve heard complaints from some of our companies. I don’t want to say anything definitive policy-wise, but we are looking at it."

The new blockbuster by Philip Rucker and Carol Leonnig, A Very Stable Genius, quotes Señor Trumpanzee whining to former Secretary of State Rex Tillerson, "It’s just so unfair that American companies aren’t allowed to pay bribes to get business overseas. We’re going to change that."

The book is a scathing portrayal of Trump as an ill-informed, reckless, explosive bully. The passage published by The Post involves an attempt by military leaders and Tillerson to provide an extended briefing for the president early in his administration to educate him about such issues as American history, alliances and even the location of nations. Trump, who repeatedly barked during the briefing that other countries have to start paying up for American defense help, suddenly blasted the officials as a “bunch of dopes and babies,” the authors reported. It was after that meeting that Tillerson called the president a “fucking moron,” according to the book, which was reported at the time.

The book comes out tomorrow. I bet it goes to #1 on the New York Times best seller list-- but not the same way Trumpanzee, Jr.'s book wound up on the best seller list.

Cornered by Nancy Ohanian

During the 2016 campaign, I visited Azerbaijan and went to the scandal-ridden Trump Tower in Baku, which was in a strange and inaccessible part of town and which never fully opened and was then completely shut down when the CIA explained-- in no uncertain terms-- to candidate Trump that the Foreign Corrupt Practices Act prohibited many things, including the hotel's money-laundering arrangements with the Iranian Revolutionary Guards, whose head, Qasem Soleimani, Trump had assassinated a little over 2 weeks ago.

Trump has wanted to repeal the Foreign Corrupt Practices Act-- which he was calling "a horrible law" years before he ran for office-- since the day he wormed his way into the White House. One of Trump's first appointments was a egregiously crooked Wall Street defense attorney and Foreign Corrupt Practices Act opponent, Jay Clayton, to head the Securities and Exchange Commission, which, among other things Claytron should be nowhere near, enforces the Foreign Corrupt Practices Act. Putting Clayton in charge of policing Wall Street was one of the most classic fox-guarding-the-hen-house moves Trump has made. When the Democrats tried filibustering his nomination, every Republican plus 10 conservative and generally pro-corruption Democrats voted to shut it down. The Democraps who guaranteed Clayton's confirmation were:

• Michael Bennet (CO), consistently the single least popular of all the Democratic candidates for president this year
• Tom Carper (DE), the Senate's current version of Status Quo Joe
• Maggie Hassan (NH), a hopelessly out of her depth hack
• Heidi Heitkamp (ND), who was defeated for reelection the following year
• Joe Manchin (WV), who was the most pro-Trump Democrat in the Senate until Kyrsten Sinema was elected in 2018
• Claire McCaskill (MO), who was defeated for reelection the following year and was then immediately hired by Comcast TV to help degrade progressives and progressive ideas
• Bill Nelson (FL), who was defeated for reelection the following year
• Jeanne Shaheen (NH), see Hassan, Maggie
• John Tester (MT), worried about reelection
• John Warner (VA), a natural Republican with an incongruous "D" next to his name

Anyway, do you remember Adam Davidson's powerful exposé in March of 2017, Trump's Worst Deal, all about his crooked deal in Baku? To understand why Trump hates the Foreign Corrupt Practices Act as much as he does, just read Davidson's New Yorker piece, which really is wonderful. Trump's partners in the money launderings scheme with Soleimani was Azerbaijan's premier mafia family: "The Azerbaijanis behind the project were close relatives of Ziya Mammadov, the Transportation Minister and one of the country’s wealthiest and most powerful oligarchs. According to the Transparency International Corruption Perceptions Index, Azerbaijan is among the most corrupt nations in the world. Its President, Ilham Aliyev, the son of the former President Heydar Aliyev, recently appointed his wife to be Vice-President. Ziya Mammadov became the Transportation Minister in 2002, around the time that the regime began receiving enormous profits from government-owned oil reserves in the Caspian Sea. At the time of the hotel deal, Mammadov, a career government official, had a salary of about twelve thousand dollars, but he was a billionaire... But the Mammadov family, in addition to its reputation for corruption, has a troubling connection that any proper risk assessment should have unearthed: for years, it has been financially entangled with an Iranian family tied to the Iranian Revolutionary Guard Corps, the ideologically driven military force. In 2008, the year that the tower was announced, Ziya Mammadov, in his role as Transportation Minister, awarded a series of multimillion-dollar contracts to Azarpassillo, an Iranian construction company. Keyumars Darvishi, its chairman, fought in the Iran-Iraq War. After the war, he became the head of Raman, an Iranian construction firm that is controlled by the Revolutionary Guard. The U.S. government has regularly accused the Guard of criminal activity, including drug trafficking, sponsoring terrorism abroad, and money laundering. Reuters recently reported that the Trump Administration was poised to officially condemn the Revolutionary Guard as a terrorist organization."

Who Keeps Trying To Burn Down Trump Tower, Baku? As Trump Said, The Mob Takes The Fifth

Yesterday's fire at Trump Tower Azerbaijan isn't being covered correctly by the media. The real story is that Trump and his Mafia buddies have been trying to burn the building down-- for insurance purposes-- for a couple of years. I'll get to that in a moment. First, though, let's look at what's being so shoddily reported this weekend.

A skyscraper that was slated to become a Trump International Hotel in the Azerbaijani capital of Baku has caught fire.

The Azadliq newspaper reported that the blaze broke out on the middle floors of the 33-storey building, which is locally known as Trump Tower, and spread.

Etibar Mirzoev, deputy head of the Emergency Situations Ministry, said there were no injuries and authorities were working to establish the cause of the of the fire.

He said it took more than three hours to extinguish the flames and suggested the response was delayed because of road closures put in place for Sunday’s Grand Prix, on the Baku City Circuit.

It came after an apartment fire at Trump Tower in New York left a prominent art dealer dead and six firefighters injured earlier this month.

Development was started on the tower in Baku a decade ago but it has never opened.

Originally planned as a luxury apartment building by local developers, the project was taken over by the future US President’s company in 2012.

The Trump Organisation announced that a hotel would occupy the first 13 floors, with flats on the storeys above, but pulled out of the project in December 2016 following Mr Trump’s election.

There was controversy over affiliation between the company that owned the project, Baku XXI Century, and a local family associated with corruption. Every paragraph has at least one mistake, some so shockingly incorrect that it destroys the meaning of what actually happened. So... let me go back to

a post we wrote over a year ago.

Monday, both Rachel's researchers and New Yorker writer Adam Davidson made a few small-- but significant-- errors (and omissions) in the report that each filed on the Trump Azerbaijan scandal. Maddow's long, circuitous dramatic report-- once she got to it-- was just based on Davidson's article. As usual, she had nothing substantive to add, just some entertainment-value drama and random superfluous facts barely-- at best-- related to the matter at hand. The video above came after the long circuitous thing, which I won't bore you with, and is her interview with Davidson who spent more time in Baku than I did-- but must have not talked to the right people there... which I did... back in June.

Last summer I visited Azerbaijan for the first time, at the suggestion of first Alan Grayson and later Ted Lieu. Both had been there and both recommended it highly, especially since I was going to be in the "neighborhood" (Moscow) anyway. I did a few posts here and a few posts at my travel blog. The top takeaway was that Trump was in business-- not just in Azerbaijan, but literally everywhere in the world-- with the most corrupt criminal elements in the world. Both Davidson and Maddow got that.

What Davidson missed (he got it wrong) was that Trump Tower Baku did open (albeit without a "Grand Opening") and did start renting out rooms-- and was almost immediately shuttered-- and that eventually-- after it was clear it would not be in business in time for the week long festivities around the Formula 1 Race (the 2016 European Grand Prix), the Mammadov mafia tried burning it down, presumably for the insurance money. Davidson messing up on that caused Maddow to go off on her theory about how if the business was never meant to make any financial sense, it must have had another reason to exist. She isn't necessarily wrong about the money-laundering aspect from Iran's Revolutionary Guard-- the CIA had been talking about that and that relationship with Trump's partners, the Mammadovs, for years. But Trump Tower Baku was very much meant to be-- at least by Trump and Ivanka-- a profitable, on-going enterprise.

What they didn't quite understand was that Baku is a "with it" cosmopolitan and highly-educated and connected city/society. Other than the politics of a kleptocracy/kakistocracy, the city is not some impoverished backward backwater. As soon as Trump went on a campaign-related rampage against Muslims, this progressive and relative secular city realized he was shit-talking them. And that was the end of any chance Trump Tower Baku could be a success. By the time I got there, they were already debating how long it would take before they could change the name and re-open.

Here's the stuff Davidson missed that my sources in Baku told me. A team claiming to be part of the Trump Organization went through Baku's 5-star hotels hiring away many of the best employees. How could that have happened? They offered to pay people high salaries that included 6 month advances. Nothing like that had ever happened in the Baku hotel industry and Trump Tower was soon far more filled with employees than Trump doddering administration has been.

Now, remember, the crooked Transportation Minister, Ziya Mammadov, who went from a lowly railway worker to a billionaire/Mafioso, owns a lot of Azerbaijan. His son, Anar, is a shady character and a perfect fit for The Donald. It was only a matter of time before they found each other, which they did when Anar decided to rent Trump's name for his glitzy new hotel. He paid Trump between $2.5 and $2.8 million for the right to slap "Trump Tower" on his building and to get some "consultations" from Ivanka. In November, 2014, the Trump Organization announced that Trump Tower Baku was part of it's hotel empire and The Donald himself boasted that "Trump International Hotel & Tower Baku represents the unwavering standard of excellence of The Trump Organization and our involvement in only the best global development projects. When we open in 2015, visitors and residents will experience a luxurious property unlike anything else in Baku-- it will be among the finest in the world." Ivanka added that "This incredible building reflects the highest level of luxury and refinement, with extraordinary architecture inspired by the Caspian Sea and sophisticated interiors that seamlessly blend contemporary style with timeless appeal. We are looking forward to bringing our unparalleled Trump services and amenities to Azerbaijan.”

It sort of opened. Trump's partner, Anar, has been described by U.S. diplomats as "notoriously corrupt" and as working to launder money for the Iranian military. The hotel hired a full staff and started renting rooms but never had a promised grand opening. Everyone in the Baku hotel industry knows someone who worked there... briefly.

Trump often talks of hiring the best people and surrounding himself with people he can trust. In practice, however, he and his executives have at times appeared to overlook details about the background of people he has chosen as business partners, such as whether they had dubious associations, had been convicted of crimes, faced extradition or inflated their resumes.

...In the Azerbaijani case, Garten said the Trump Organization had performed meticulous due diligence on the company's partners, but hadn't researched the allegations against the Baku partner's father because he wasn't a party to the deal.

"I've never heard that before," Garten said, when first asked about allegations of Iranian money laundering by the partner's father, which appeared in U.S. diplomatic cables widely available since they were leaked in 2010.

Garten subsequently said he was confident the minister alleged to be laundering Iranian funds, Ziya Mammadov, had no involvement in his son's holding company, even though some of the son's major businesses regularly partnered with the transportation ministry and were founded while the son was in college overseas. Ziya Mammadov did not respond to a telephone message the AP left with his ministry in Baku or to emails to the Azerbaijan Embassy in Washington.

Garten told the AP that Trump's company uses a third-party investigative firm, which he did not identify, that specializes in background intelligence gathering and searches global watch lists, warrant lists and sanctions lists maintained by the United Nations, Interpol and others.

...Any American contemplating a business venture in Azerbaijan faces a risk: "endemic public corruption," as the State Department puts it. Much of that money flows from the oil and gas industries, but the State Department also considers the country to be a waypoint for terrorist financiers, Iranian sanctions-busters and Afghan drug lords.

The environment is a risky one for any business venture seeking to avoid violating U.S. penalties imposed against Iran or anti-bribery laws under the U.S. Foreign Corrupt Practices Act.

...Garten said the Trump Organization had performed background screening on all those involved in the deal and was confident Mammadov's father played no role in the project.

Experts on Azerbaijan were mystified that Trump or anyone else could reach that conclusion.

Anar Mammadov is widely viewed by diplomats and nongovernmental organizations as a transparent stand-in for the business interests of his father. Anar's business has boomed with regular help from his father's ministry, receiving exclusive government contracts, a near monopoly on Baku's taxi business and even a free fleet of autobuses.

"These are not business people acting on their own-- you're dealing with daddy," said Richard Kauzlarich, a U.S. ambassador to Azerbaijan under President Bill Clinton in the 1990s who went on to work under the Director of National Intelligence during the George W. Bush administration.

"Whatever the Trump people thought they were doing, that wasn't reality," Kauzlarich said.

Anar Mammadov, who is believed to be 35, has said in a series of interviews that he founded Garant Holdings' predecessor-- which has arms in transportation, construction, banking, telecommunications and manufacturing-- in 2000, when he would have been 19. Anar received his bachelor's degree in 2003 and a master's in business administration in 2005-- both from a university in London.

Mammadov's statement that he founded the business in 2000 appeared in a magazine produced by a research firm in partnership with the Azerbaijani government. In other forums, he has said he started the business in 2005, though several of its key subsidiaries predate that period.

As Davidson wrote, "After Donald Trump became a candidate for President, in 2015, Mother Jones, the Associated Press, the Washington Post, and other publications ran articles that raised questions about his involvement in the Baku project. These reports cited a series of cables sent from the U.S. Embassy in Azerbaijan in 2009 and 2010, which were made public by WikiLeaks. In one of the cables, a U.S. diplomat described Ziya Mammadov as 'notoriously corrupt even for Azerbaijan.' The Trump Organization’s chief legal officer, Alan Garten, told reporters that the Baku hotel project raised no ethical issues for Donald Trump, because his company had never engaged directly with Mammadov."

Late in the presidential campaign, after he had beaten all the Republicans and was facing Clinton, Trump had a visit from American intelligence officials who explained to him the ramifications of being in business with Mammadov was so overwhelmingly disqualifying that he had to end the relationship immediately. I don't know what they showed him exactly, but Trump Tower Baku completely disappeared from Trump World.

No evidence has surfaced showing that Donald Trump, or any of his employees involved in the Baku deal, actively participated in bribery, money laundering, or other illegal behavior. But the Trump Organization may have broken the law in its work with the Mammadov family. The Foreign Corrupt Practices Act, passed in 1977, forbade American companies from participating in a scheme to reward a foreign government official in exchange for material benefit or preferential treatment. The law even made it a crime for an American company to unknowingly benefit from a partner’s corruption if it could have discovered illicit activity but avoided doing so. This closed what was known as the “head in the sand” loophole.

...Even a cursory look at the Mammadovs suggests that they are not ideal partners for an American business. Four years before the Trump Organization announced the Baku deal, WikiLeaks released the U.S. diplomatic cables indicating that the family was corrupt; one cable mentioned the Mammadovs’ link to Iran’s Revolutionary Guard. In 2013, Radio Free Europe/Radio Liberty and the Organized Crime and Corruption Reporting Project investigated the Mammadov family’s corruption and published well-documented exposés. Six months before the hotel announcement, Foreign Policy ran an article titled “The Corleones of the Caspian,” which suggested that the Mammadovs had exploited Ziya’s position as Transportation Minister to make their fortunes.

...To this day, the Trump Organization has not provided satisfying answers to the most basic questions about the Baku deal: who owns Baku XXI Century, the company with which they signed the contracts; the origin of the funds with which Baku XXI Century paid the Trump Organization; whether the Mammadovs used their political power to benefit themselves and the Trump Organization; and whether the Mammadovs used money obtained from the Iranian Revolutionary Guard to fund the Trump Tower Baku.

...More than a dozen lawyers with experience in F.C.P.A. prosecution expressed surprise at the Trump Organization’s seemingly lax approach to vetting its foreign partners. But, when I asked a former Trump Organization executive if the Baku deal had seemed unusual, he laughed. “No deal there seems unusual, as long as a check is attached,” he said.

Remember, the first significant piece of legislation Trump signed was a bill repealing an Obama administration rule focring energy and mining companies to disclose any payments (bribes) they made abroad. Trumpanzee: "This is a big signing, a very important signing. And this is H.J. Resolution 41, disapproving the Securities and Exchange Commission's rule on disclosure of payments by resource extraction issuers. It's a big deal. And I want to thank Speaker Paul Ryan for being here. He's been tremendous. Jeb Hensarling very, very important and really worked hard. Representative Bill Huizenga and all of the friends-- Peter-- all of my friends are up here. And we really appreciate it." I'm sure he did-- and what's good enough for the Oil barons is certainly good enough for the hotel developing mobsters, no?

Donald Trump's History Predicted A Kleptocracy-- And It's Here

I haven't noticed any of the polling firms that now routinely ask if people think Trump is a liar or not-- most do-- whether or not people think Trump is a crook. I predict that in less than a year, that will be a standard polling question-- and that eventually most Americans will say yes. I assume the majority of DWT readers already are ready to say Trump is a crook. Personally, I saw it first hand when I was in Azerbaijan and visited the ridiculous-- and never officially opened-- Trump Tower in Baku. Trump and his crooked partners were laundering money for Afghan drug lords and the Iranian Revolutionary Guard. But that's just one project in one small country. Trump's business partners everywhere are the most corrupt and criminal elements in their countries. There is no country where Trump has reputable, upstanding business partners.

Last week, writing for the American Constitution Society, Dan Froomkin reported that Trump's world of luxury real estate is fueled by money-laundering. And Mueller is studying the sector meticulously, especially in regard to the Putin-connected Russian and Ukrainian oligarchs, all of whom are a criminal-- Mafia-- class. ALL OF THEM... 100%... no exceptions. There are no legitimate Russian billionaires, only criminals who looted the state after the Soviet Union collapsed.

The fact that money-launderers flock to luxury real estate is nothing new, and isn't much of a mystery either. It's the direct result of a major loophole in U.S. government rules that require banks to report cash deposits over $10,000-- but allow property owners to accept $10 million in cash for a condo without divulging who gave it to them.

When it comes to the real estate business, the anti-money-laundering rules only apply to banks and other financial institutions. So when buyers take out a mortgage from a lender, they are extensively scrutinized and unusual amounts of cash are reported to the government.

But by paying all cash-- behavior that would reasonably raise the most suspicion-- real estate buyers actually avoid setting off any alarm bells. The real estate agents and owners pocketing huge sums are under no legal obligation to report that to anyone.

For fraudsters, drug cartels, oligarchs and corrupt foreign government officials looking for a way to launder huge sums of illicit cash-- and park it somewhere safe-- high-end real estate is the investment of choice. "You can put a lot of money in one place at one time, without raising any eyebrows," says Heather Lowe, legal counsel for the dirty-money watchdog group Global Financial Integrity.

The Treasury Department explains it this way: "The real estate market can be an attractive vehicle for laundering illicit gains because of the manner in which it appreciates in value, 'cleans' large sums of money in a single transaction, and shields ill-gotten gains from market instability and exchange-rate fluctuations."

A New York Times series in 2015 found that more than half of the $8 billion spent each year on New York residences that cost more than $5 million comes from shell corporations that mask the real owners' identities, one possible sign of money-laundering.

Under pressure after the New York Times series, Treasury Department officials in early 2016 decided to try an experiment in Miami-Dade County and Manhattan, ordering title insurance companies there to identify the individuals who owned the shell companies making all-cash purchases-- and requiring them to send copies of the buyers' IDs to the Treasury's Financial Crimes Enforcement Network (FINCEN).

There were still some laughably large loopholes, chief among them the exemption of sales made with wire transfers, which are arguably the most common method of moving cash these days, especially from foreign sources.

But it helped: FINCEN reported on August 22 that a whopping 30 percent of the all-cash high-end real estate deals reported under the new program involved people who were already under government scrutiny due to potential money laundering-- including a One article in the Times series focused on apartments in the super-luxury Time Warner Center as an archetype, and "found a growing proportion of wealthy foreigners, at least 16 of whom have been the subject of government inquiries around the world, either personally or as heads of companies." That "included government officials and close associates of officials from Russia, Colombia, Malaysia, China, Kazakhstan and Mexico.

Another Times article concluded that "the flight of wealth accrued in the chaotic capitalism of post-Soviet Russia has been a powerful force behind the luxury condominium boom reordering New York City’s skyline."

Jennifer Shasky Calvery, then the direct of FINCEN, said last year that in her previous job-- prosecuting Russian organized crime-- she often found members "based outside of the United States were laundering their funds through the U.S. financial system. Often, this involved the suspected purchase of personal residences with criminal proceeds."

The Miami Herald reported last year that "Trump helped local developers sell condos to buyers from Latin America and Russia, including people allegedly involved in corruption and wrongdoing, as well as to dozens of anonymous offshore companies." Buyers included "members of a Russian-American organized crime group, a Venezuelan oilman convicted in a bribery scheme and a Mexican banker accused of robbing investors of their life savings."

McClatchy reported in May about "fugitive oligarchs and their kin accused of laundering Kazakh money in posh U.S. real estate-- including Trump Organization properties."

The U.S. Attorney's office in Manhattan abruptly and controversially settled a major money-laundering prosecution in May that had targeted Russian businessman Denis Katsyv, the owner of Prevezon Holdings. He was accused of laundering some of the $230 million he obtained through Russian tax fraud in luxury New York apartments.

None of those apartments were in Trump buildings-- but there was a connection to the Trump campaign: One of Kastyv's lawyers was Natalia Veselnitskaya, the Russian attorney who held a secret meeting in June 2016 with Trump’s son, son-in-law and then-campaign manager, offering them Russian government information on Hillary Clinton.

And once the laundered money is invested in real estate, the people who control the shell company are truly home free. It's just that simple.

They can use the property as collateral for a loan. They can charge rent and put the money in a domestic bank account. Ownership of shell companies can be shifted at any time, with no indication in property records. And the owner of the shell company can simply turn around and sell the property-- walking away with clean money. Depositing rental income or the proceeds of a real estate sale into U.S. financial institution sets off no automatic alarm bells.

"There's really no impediment" to accessing the money after it's been put into U.S. real estate, said Peter D. Hardy, a partner at the Ballard Spahr law firm and contributor to the Money Laundering Watch blog.

There may be some tax issues related to income or capital gains. But, Hardy said, "lots of money-laundering schemes don't really involve tax fraud per se, in terms of hiding the income. It's really more about being able to use it."

Lowe said if Treasury wanted to seriously crack down on money laundering through real estate, it would require real estate agents to adopt the same kind of due-diligence, know-your-customer standards as financial institutions.

Neither his campaign nor his presidency have led Trump to shy away from selling real estate to shell companies-- one of the possible indicators of money-laundering. In fact, a USA Today investigation published in June found that since Trump won the Republican nomination, "the majority of his companies’ real estate sales are to secretive shell companies that obscure the buyers’ identities."

That's a much larger proportion than the two prior years, USA Today found, but to be fair, the main concern is not so much money-laundering anymore as "that the secretive sales create an extraordinary and unprecedented potential for people, corporations or foreign interests to try to influence a President."

Meanwhile, Trump is welcoming a major figure in luxury U.S. real estate money-laundering to the White House on September 12: Malaysian Prime Minister Najib Razak.

The Justice Department last year began the process of seizing more than $1 billion in assets of the 1Malaysia Development Berhad, the government-owned investment fund founded by Najib. Then-Attorney General Loretta E. Lynch called it "the largest single action ever brought under the Kleptocracy Asset Recovery Initiative."

Those assets include a $30.6 million penthouse at the Time Warner Center in Manhattan and a $39 million mansion in the Los Angeles hills, both bought by shell corporations.

Najeeb might even bring this up in conversation with Trump: The assets are currently frozen, but they haven't actually been seized yet.

What Secrets Is Mueller Finding As He Investigates Trump's Shady Foreign Deals?-- Part I

-by Valley Girl



As I told Howie, I went to the New Yorker site looking for (cat) cartoons. But I never got that far, because almost immediately I discovered some fascinating investigative articles written by Adam Davidson. Two are worthy of particular note, given Robert Mueller’s brief to investigate the business dealings of Donald Trump. The first, published on March 13, 2017, is titled Donald Trump's Worst Deal. The subtitle is “The President helped build a hotel in Azerbaijan that appears to be a corrupt operation engineered by oligarchs tied to Iran’s Revolutionary Guard.” I’ll summarize that here. The second will appear in a separate post here at DWT later this evening... Yes, probably your first ever whole night in the Caucuses.

Howie has traveled to Azerbaijan, and seen the Trump Tower in Baku up close and personal. He’s written about this at DWT; here are some of his posts about Baku's rampant corruption and the Trump family.

Some background about Azerbaijan- from wiki:

The Azerbaijan Democratic Republic proclaimed its independence in 1918 and became the first democratic state in the Muslim-oriented world. The country was incorporated into the Soviet Union in 1920 as the Azerbaijan Soviet Socialist Republic. The modern Republic of Azerbaijan proclaimed its independence on 30 August 1991, prior to the official dissolution of the USSR in December 1991.

In summarizing Davidson’s ~7000 word article, I pared it down to the essence, but didn’t change his (very careful) wording. Note these when reading: The Foreign Corrupt Practices Act, Iranian Revolutionary Guard, Mammadov family’s corruption, The Corleones of the Caspian.

And, before or after you read the summary, watch: This CNN video interview is excellent, but not embeddable, alas: The New Yorker's Adam Davidson speaks to Christiane Amanpour about his piece on Donald Trump's business with oligarchs tied to Iran's Revolutionary Guard. It’s a "must watch," and the information jumps out at you in a way that it just doesn’t on the written page.

The Trump Tower Baku never opened. Trump partnered with an Azerbaijani family that U.S. officials called notoriously unethical.

Heydar Aliyev Prospekti, a broad avenue in Baku, the capital of Azerbaijan, connects the airport to the city. The road is meant to highlight Baku’s recent modernization, and it is lined with sleek new buildings.

As you approach the city center, a tower at the end of the avenue looms in front of you. The building, a five-star hotel and residence called the Trump International Hotel & Tower Baku, has never opened, though from the road it looks ready to welcome the public.

The more time I spent in the neighborhood, the more I wondered how the hotel could have been imagined as a viable business. The development was conceived, in 2008, as a high-end apartment building. In 2012, after Donald Trump’s company, the Trump Organization, signed multiple contracts with the Azerbaijani developers behind the project, plans were made to transform the tower into an “ultra-luxury property.” According to a Trump Organization press release, a hotel with “expansive guest rooms” would occupy the first thirteen floors; higher stories would feature residences with “spectacular views of the city and Caspian Sea.” For an expensive hotel, the Trump Tower Baku is in an oddly unglamorous location: the underdeveloped eastern end of downtown, which is dominated by train tracks and is miles from the main business district, on the west side of the city. Across the street from the hotel is a discount shopping center; the area is filled with narrow, dingy shops and hookah bars. Other hotels nearby are low-budget options: at the AYF Palace, most rooms are forty-two dollars a night. There are no upscale restaurants or shops. Any guests of the Trump Tower Baku would likely feel marooned.

The timing of the project was also curious. By 2014, when the Trump Organization publicly announced that it was helping to turn the tower into a hotel, a construction boom in Baku had ended, and the occupancy rate for luxury hotels in the city hovered around thirty-five per cent.

A former top official in Azerbaijan’s Ministry of Tourism says that, when he learned of the Trump hotel project, he asked himself, “Why would someone put a luxury hotel there? Nobody who can afford to stay there would want to be in that neighborhood.”

The Azerbaijanis behind the project were close relatives of Ziya Mammadov, the Transportation Minister and one of the country’s wealthiest and most powerful oligarchs. According to the Transparency International Corruption Perceptions Index, Azerbaijan is among the most corrupt nations in the world.

After Donald Trump became a candidate for President, in 2015, (several) publications … raised questions about his involvement in the Baku project... a U.S. diplomat described Ziya Mammadov as “notoriously corrupt even for Azerbaijan.” The Trump Organization’s chief legal officer, Alan Garten, told reporters that the Baku hotel project raised no ethical issues for Donald Trump, because his company had never engaged directly with Mammadov.

A month after Trump was elected President, Garten announced that the Trump Organization had severed its ties with the hotel project, describing the decision to CNN as little more than “housecleaning.” I was in Baku at the time, and it had become clear that the Trump Organization’s story of the hotel was incomplete and inaccurate.

Ivanka in Baku

An Azerbaijani lawyer who worked on the project revealed to me that the Trump Organization had not just licensed the family name; it also had signed a technical-services agreement in which it promised to help its partner meet Trump design standards. Technical-services agreements are often nominal addenda to licensing deals... The Azerbaijani lawyer told me, “We were always following their instructions. We were in constant contact with the Trump Organization. They approved the smallest details.”

Ivanka Trump was the most senior Trump Organization official on the Baku project. In October, 2014, she visited the city to tour the site and offer advice... The Azerbaijani lawyer said, “Ivanka personally approved everything.”

The sustained back-and-forth between the Trump Organization and the Mammadovs has legal significance... Tom Fox, a Houston lawyer who specializes in anti-corruption compliance, said, “It’s a problem if you’re making a profit off of someone else’s corrupt conduct.”

Before signing a deal with a foreign partner, American companies, including major hotel chains, conduct risk assessments and background checks that take a close look at the country, the prospective partner, and the people involved... A senior executive at one of the largest American hotel chains, who asked for anonymity because he feared reprisal from the Trump Administration, said, “We wouldn’t look at due diligence as a burden. There certainly is a cost to doing it, especially in higher-risk places. But it’s as much an investment in the protection of that brand. It’s money well spent.”

Alan Garten told me that the Trump Organization had commissioned a risk assessment for the Baku deal, but declined to name the company that had performed it. …according to Garten, the Trump Organization had undertaken “extensive due diligence” before making the hotel deal and had not discovered “any red flags.”

But the Mammadov family, in addition to its reputation for corruption, has a troubling connection that any proper risk assessment should have unearthed: for years, it has been financially entangled with an Iranian family tied to the Iranian Revolutionary Guard Corps, the ideologically driven military force.

I asked Garten how deeply the Trump Organization had looked into the Mammadov family’s political connections. …When I asked him to provide documentation of due diligence, he said that he couldn’t share it with me, because “it’s confidential and privileged.”

(But) the Trump Organization may have broken the law in its work with the Mammadov family. The Foreign Corrupt Practices Act, passed in 1977, forbade American companies from participating in a scheme to reward a foreign government official in exchange for material benefit or preferential treatment. The law even made it a crime for an American company to unknowingly benefit from a partner’s corruption if it could have discovered illicit activity but avoided doing so. This closed what was known as the “head in the sand” loophole.

Even a cursory look at the Mammadovs suggests that they are not ideal partners for an American business. Four years before the Trump Organization announced the Baku deal, WikiLeaks released the U.S. diplomatic cables indicating that the family was corrupt; one cable mentioned the Mammadovs’ link to Iran’s Revolutionary Guard. In 2013, Radio Free Europe/Radio Liberty and the Organized Crime and Corruption Reporting Project investigated the Mammadov family’s corruption and published well-documented exposés. Six months before the hotel announcement, Foreign Policy ran an article titled “The Corleones of the Caspian,” which suggested that the Mammadovs had exploited Ziya’s position as Transportation Minister to make their fortunes.

Alan Garten, the Trump Organization lawyer, did not deny that there was corruption involved in the project. “I’m not going to sit here and defend the Mammadovs,” he said. But, from a legal standpoint, he argued, the Trump Organization was blameless. In his opinion, the Foreign Corrupt Practices Act doesn’t apply to the Baku deal, even if corruption occurred. “We didn’t own it,” he said of the hotel. “We had no equity. We didn’t control the project. The flow of funds is in the wrong direction.” He added, “We did not pay any money to anyone. Therefore, it could not be a violation of the F.C.P.A.”

“No, that’s just wrong,” Jessica Tillipman, an assistant dean at George Washington University Law School, who specializes in the F.C.P.A., said. “You can’t go into business deals in Azerbaijan assuming that you are immune from the F.C.P.A.” She added, “Nor can you escape liability by looking the other way. The entire Baku deal is a giant red flag—the direct involvement of foreign government officials and their relatives in Azerbaijan with ties to the Iranian Revolutionary Guard. Corruption warning signs are rarely more obvious.”

Tillipman explained that the F.C.P.A. defines corruption as “the payment of money or anything of value” to a foreign official... Tillipman, along with several other F.C.P.A. experts, told me that the Trump Organization had clearly provided things of value in the Baku deal: its famous brand, its command of the luxury market, its extensive technical advice.

American companies must insure that they are not receiving funds that originated with any sanctioned entity. Ignorance is not a defense, especially if there is ample warning that a foreign partner could have a link to such an entity. Most firms, upon hearing of even a slight chance of Iranian involvement, conduct due diligence that is much more extensive than what is typical for F.C.P.A. compliance. Erich Ferrari, an attorney who specializes in sanctions-related legal cases, said that before the Trump Organization cashed any checks it should have been certain of “the source of the funds”—“not only the bank it was remitted from but how the Mammadovs actually earned the money they paid.” He said of the Baku deal, “It takes a lot to shock a lawyer, but I’ve had very few clients do so little due diligence.

To this day, the Trump Organization has not provided satisfying answers to the most basic questions about the Baku deal: (including) whether the Mammadovs used their political power to benefit themselves and the Trump Organization; and whether the Mammadovs used money obtained from the Iranian Revolutionary Guard to fund the Trump Tower Baku.

More than a dozen lawyers with experience in F.C.P.A. prosecution expressed surprise at the Trump Organization’s seemingly lax approach to vetting its foreign partners. But, when I asked a former Trump Organization executive if the Baku deal had seemed unusual, he laughed. “No deal there seems unusual, as long as a check is attached,” he said.

Next up: we head east to another sleazy Trump project steeped in corruption, money-laundering and a country's shadiest characters-- Señor Trumpanzee tries his luck in Batumi.

Another Trump Property Tarred With His Toxic Name Is Forced To Close-- Maybe Koi Could Reopen In Clay Co, Kentucky

I bet folks in McKee, Kentucky would LOVE a Trump-branded something in their town of 800. This one is available for moving

Just under a year ago I spent some time in Azerbaijan, mostly in Baku, the capital city. I went to see Trump Tower, which had opened and closed in a matter of days, and blogged about it a bit. Trump's Mafia business partners, the Mammadovs (AKA the Coreleones of the Caspian), were stuck holding the bag when the CIA insisted GOP nominee Trump extricate himself and Ivanka from a full-time criminal enterprise that was working as money launderers for the Iranian Revolutionary Guard. After it was shuttered, people wondered in Baku wondered if it would be rebranded with a less toxic name-- like Motel 6-- or if the Mammadovs would just wait it out and see if Trump's name became less toxic or even, alluring on some level. It didn't and they tried to burn it down.

Today it's still standing-- empty and forlorn-- in a sketchy Baku neighborhood, sucking money. It's just there, all 33 stories that you can see from almost anywhere in the city. The concierge from a much more luxurious Baku hotel told me Trump's name is so toxic in Azerbaijan that its not likely the hotel will ever open. The Trump Organization has removed it from its website-- disappeared; never happened.

This week another Trump property succumbed to... all things Trump. The high end sushi restaurant at Trump Soho, Koi, shut down because of a lack of business. According to GrubStreet, "his controversial campaign’s harsh rhetoric and administration’s agenda have made many potential customers uneasy about giving their business to Trump’s properties. Residents of Manhattan’s Trump Place successfully changed their property’s name, two celebrity chefs famously backed out of D.C.’s Trump International Hotel and others were unwilling to replace them, and Trump’s new line of hotels won’t bear his name. Then last December, a month after three NBA teams announced they wouldn’t stay at his hotels, members of the Cleveland Cavaliers (including Black Lives Matter supporter LeBron James) refused to stay at the Trump Soho. Now, that hotel’s restaurant operator, Koi, an international chainlet of sushi spots for beautiful people, is shuttering its outpost there. But this isn’t a closing as usual. It’s collateral damage from the rise of Trump." [By the way, folks in Clay County, Kentucky might think of sushi as bait but they only gave Hillary 11% of their vote last year. Sounds like a perfect place for Uday and Kusay to open Trump-branded properties... or Jackson County, where Trump won 88.9% of the vote, but where everyone is a prescription drug zombie.]

“Obviously, the restaurant is closing because business is down. I don’t think anyone would volunteer to close a business if they were making money,” Suzanne Chou, Koi Group’s general counsel, says with a laugh. “Beyond that, I would prefer not to speculate as to why, but obviously since the election it’s gone down.”

A California import, Koi is a familiar style of pan-Asian restaurant: clubby, expensive, and popular with celebrities and professional athletes. It’s not in any food snob’s regular rotation, but the Los Angeles original (branches have opened in Bangkok, Las Vegas, and Dubai) has long been a destination for the rich and famous. When the Soho location opened in 2012, Forbes Travel Guide wrote, “where there’s a Koi dish, there’s a celebrity.” Though Chou declined to delve specifically into how much business had gone down, Koi staffers say that the election has had an impact on the restaurant’s bottom line, and their paychecks.

Now, references to the downtown branch have been scrubbed from both the Koi Trump Soho’s homepages. A limited menu (“30 to 40 percent of what we used to carry,” the reservationist says) will be served until June 18, when Koi and menu items like “She’s So LA” rolls will vacate the building for good. No one other locations will close, and Chou says that the group hopes to reopen somewhere else downtown.

“Before Trump won we were doing great. There were a lot of people we had, our regulars, who’d go to the hotel but are not affiliated with Trump,” says Jonathan Grullon, a busser and host who has worked at the restaurant for a year and a half. “And they were saying if he wins, we are not coming here anymore.”

Ricardo Aca, who worked at the restaurant for four years until this February, concurs, noting twice that “the Kardashians stopped coming.” Following the election, Aca says that business dipped so much that he had to take a second part-time job while he was still working there. As a server in the hotel’s Koi-managed lounge, he saw his hourly earnings fall from about $20 to $15 an hour. And Grullon says he’s making almost $200 dollars less each week and that he, too, has had to get a second job.

According to Grullon, Koi now has just ten service employees, including those in the kitchen. Some staff started walking away once business evaporated, and now that news of the closing is public, more have started to leave. The dining room is often 30 to 40 percent full and never gets past 50 to 60 percent capacity. During lunch, they’ll serve fewer than 30 people in a restaurant that can seat 140.

“We’ve been getting cut all the time. There is no reason for us to be there,” Grullon says. “They say they’re going to close June 18, but I think it’s going to be sooner.”

In the meantime, New York’s other location of Koi, near Bryant Park, is still open. In fact, a reservationist at the Soho location offered to book a table uptown instead, saying “it would be a much better experience for you.”

After Trump, The Culture Of Corruption Will Never Be The Same-- Take Azerbaijan

Monday, both Rachel's researchers and New Yorker writer Adam Davidson made a few small-- but significant-- errors (and omissions) in the report that each filed on the Trump Azerbaijan scandal. Maddow's long, circuitous dramatic report-- once she got to it-- was just based on Davidson's article. As usual, she had nothing substantive to add, just some entertainment-value drama and random superfluous facts barely-- at best-- related to the matter at hand. The video above came after the long circuitous thing, which I won't bore you with, and is her interview with Davidson who spent more time in Baku than I did-- but must have not talked to the right people there... which I did... back in June.

Last summer I visited Azerbaijan for the first time, at the suggestion of first Alan Grayson and later Ted Lieu. Both had been there and both recommended it highly, especially since I was going to be in the "neighborhood" (Moscow) anyway. I did a few posts here and a few posts at my travel blog. The top takeaway was that Trump was in business-- not just in Azerbaijan, but literally everywhere in the world-- with the most corrupt criminal elements in the world. Both Davidson and Maddow got that.

What Davidson missed (he got it wrong) was that Trump Tower Baku did open (albeit without a "Grand Opening") and did start renting out rooms-- and was almost immediately shuttered-- and that eventually-- after it was clear it would not be in business in time for the week long festivities around the Formula 1 Race (the 2016 European Grand Prix), the Mammadov mafia tried burning it down, presumably for the insurance money. Davidson messing up on that caused Maddow to go off on her theory about how if the business was never meant to make any financial sense, it must have had another reason to exist. She isn't necessarily wrong about the money-laundering aspect from Iran's Revolutionary Guard-- the CIA had been talking about that and that relationship with Trump's partners, the Mammadovs, for years. But Trump Tower Baku was very much meant to be-- at least by Trump and Ivanka-- a profitable, on-going enterprise.

What they didn't quite understand was that Baku is a "with it" cosmopolitan and highly-educated and connected city/society. Other than the politics of a kleptocracy/kakistocracy, the city is not some impoverished backward backwater. As soon as Trump went on a campaign-related rampage against Muslims, this progressive and relative secular city realized he was shit-talking them. And that was the end of any chance Trump Tower Baku could be a success. By the time I got there, they were already debating how long it would take before they could change the name and re-open.

Here's the stuff Davidson missed that my sources in Baku told me. A team claiming to be part of the Trump Organization went through Baku's 5-star hotels hiring away many of the best employees. How could that have happened? They offered to pay people high salaries that included 6 month advances. Nothing like that had ever happened in the Baku hotel industry and Trump Tower was soon far more filled with employees than Trump doddering administration has been.

Now, remember, the crooked Transportation Minister, Ziya Mammadov, who went from a lowly railway worker to a billionaire/Mafioso, owns a lot of Azerbaijan. His son, Anar, is a shady character and a perfect fit for The Donald. It was only a matter of time before they found each other, which they did when Anar decided to rent Trump's name for his glitzy new hotel. He paid Trump between $2.5 and $2.8 million for the right to slap "Trump Tower" on his building and to get some "consultations" from Ivanka. In November, 2014, the Trump Organization announced that Trump Tower Baku was part of it's hotel empire and The Donald himself boasted that "Trump International Hotel & Tower Baku represents the unwavering standard of excellence of The Trump Organization and our involvement in only the best global development projects. When we open in 2015, visitors and residents will experience a luxurious property unlike anything else in Baku-- it will be among the finest in the world." Ivanka added that "This incredible building reflects the highest level of luxury and refinement, with extraordinary architecture inspired by the Caspian Sea and sophisticated interiors that seamlessly blend contemporary style with timeless appeal. We are looking forward to bringing our unparalleled Trump services and amenities to Azerbaijan.”

It sort of opened. Trump's partner, Anar, has been described by U.S. diplomats as "notoriously corrupt" and as working to launder money for the Iranian military. The hotel hired a full staff and started renting rooms but never had a promised grand opening. Everyone in the Baku hotel industry knows someone who worked there... briefly.

Trump often talks of hiring the best people and surrounding himself with people he can trust. In practice, however, he and his executives have at times appeared to overlook details about the background of people he has chosen as business partners, such as whether they had dubious associations, had been convicted of crimes, faced extradition or inflated their resumes.

...In the Azerbaijani case, Garten said the Trump Organization had performed meticulous due diligence on the company's partners, but hadn't researched the allegations against the Baku partner's father because he wasn't a party to the deal.

"I've never heard that before," Garten said, when first asked about allegations of Iranian money laundering by the partner's father, which appeared in U.S. diplomatic cables widely available since they were leaked in 2010.

Garten subsequently said he was confident the minister alleged to be laundering Iranian funds, Ziya Mammadov, had no involvement in his son's holding company, even though some of the son's major businesses regularly partnered with the transportation ministry and were founded while the son was in college overseas. Ziya Mammadov did not respond to a telephone message the AP left with his ministry in Baku or to emails to the Azerbaijan Embassy in Washington.

Garten told the AP that Trump's company uses a third-party investigative firm, which he did not identify, that specializes in background intelligence gathering and searches global watch lists, warrant lists and sanctions lists maintained by the United Nations, Interpol and others.

...Any American contemplating a business venture in Azerbaijan faces a risk: "endemic public corruption," as the State Department puts it. Much of that money flows from the oil and gas industries, but the State Department also considers the country to be a waypoint for terrorist financiers, Iranian sanctions-busters and Afghan drug lords.

The environment is a risky one for any business venture seeking to avoid violating U.S. penalties imposed against Iran or anti-bribery laws under the U.S. Foreign Corrupt Practices Act.

...Garten said the Trump Organization had performed background screening on all those involved in the deal and was confident Mammadov's father played no role in the project.

Experts on Azerbaijan were mystified that Trump or anyone else could reach that conclusion.

Anar Mammadov is widely viewed by diplomats and nongovernmental organizations as a transparent stand-in for the business interests of his father. Anar's business has boomed with regular help from his father's ministry, receiving exclusive government contracts, a near monopoly on Baku's taxi business and even a free fleet of autobuses.

"These are not business people acting on their own-- you're dealing with daddy," said Richard Kauzlarich, a U.S. ambassador to Azerbaijan under President Bill Clinton in the 1990s who went on to work under the Director of National Intelligence during the George W. Bush administration.

"Whatever the Trump people thought they were doing, that wasn't reality," Kauzlarich said.

Anar Mammadov, who is believed to be 35, has said in a series of interviews that he founded Garant Holdings' predecessor-- which has arms in transportation, construction, banking, telecommunications and manufacturing-- in 2000, when he would have been 19. Anar received his bachelor's degree in 2003 and a master's in business administration in 2005-- both from a university in London.

Mammadov's statement that he founded the business in 2000 appeared in a magazine produced by a research firm in partnership with the Azerbaijani government. In other forums, he has said he started the business in 2005, though several of its key subsidiaries predate that period.

As Davidson wrote, "After Donald Trump became a candidate for President, in 2015, Mother Jones, the Associated Press, the Washington Post, and other publications ran articles that raised questions about his involvement in the Baku project. These reports cited a series of cables sent from the U.S. Embassy in Azerbaijan in 2009 and 2010, which were made public by WikiLeaks. In one of the cables, a U.S. diplomat described Ziya Mammadov as 'notoriously corrupt even for Azerbaijan.' The Trump Organization’s chief legal officer, Alan Garten, told reporters that the Baku hotel project raised no ethical issues for Donald Trump, because his company had never engaged directly with Mammadov."

Late in the presidential campaign, after he had beaten all the Republicans and was facing Clinton, Trump had a visit from American intelligence officials who explained to him the ramifications of being in business with Mammadov was so overwhelmingly disqualifying that he had to end the relationship immediately. I don't know what they showed him exactly, but Trump Tower Baku completely disappeared from Trump World.

No evidence has surfaced showing that Donald Trump, or any of his employees involved in the Baku deal, actively participated in bribery, money laundering, or other illegal behavior. But the Trump Organization may have broken the law in its work with the Mammadov family. The Foreign Corrupt Practices Act, passed in 1977, forbade American companies from participating in a scheme to reward a foreign government official in exchange for material benefit or preferential treatment. The law even made it a crime for an American company to unknowingly benefit from a partner’s corruption if it could have discovered illicit activity but avoided doing so. This closed what was known as the “head in the sand” loophole.

...Even a cursory look at the Mammadovs suggests that they are not ideal partners for an American business. Four years before the Trump Organization announced the Baku deal, WikiLeaks released the U.S. diplomatic cables indicating that the family was corrupt; one cable mentioned the Mammadovs’ link to Iran’s Revolutionary Guard. In 2013, Radio Free Europe/Radio Liberty and the Organized Crime and Corruption Reporting Project investigated the Mammadov family’s corruption and published well-documented exposés. Six months before the hotel announcement, Foreign Policy ran an article titled “The Corleones of the Caspian,” which suggested that the Mammadovs had exploited Ziya’s position as Transportation Minister to make their fortunes.

...To this day, the Trump Organization has not provided satisfying answers to the most basic questions about the Baku deal: who owns Baku XXI Century, the company with which they signed the contracts; the origin of the funds with which Baku XXI Century paid the Trump Organization; whether the Mammadovs used their political power to benefit themselves and the Trump Organization; and whether the Mammadovs used money obtained from the Iranian Revolutionary Guard to fund the Trump Tower Baku.

...More than a dozen lawyers with experience in F.C.P.A. prosecution expressed surprise at the Trump Organization’s seemingly lax approach to vetting its foreign partners. But, when I asked a former Trump Organization executive if the Baku deal had seemed unusual, he laughed. “No deal there seems unusual, as long as a check is attached,” he said.

Remember, the first significant piece of legislation Trump signed was a bill repealing an Obama administration rule focring energy and mining companies to disclose any payments (bribes) they made abroad. Trumpanzee: "This is a big signing, a very important signing. And this is H.J. Resolution 41, disapproving the Securities and Exchange Commission's rule on disclosure of payments by resource extraction issuers. It's a big deal. And I want to thank Speaker Paul Ryan for being here. He's been tremendous. Jeb Hensarling very, very important and really worked hard. Representative Bill Huizenga and all of the friends-- Peter-- all of my friends are up here. And we really appreciate it." I'm sure he did-- and what's good enough for the Oil barons is certainly good enough for the hotel developing mobsters, no?