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Has Barrack been indicted yet? FCPA, AFA, FARA & Lobbying Act...

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Posted on July 31 2019


Has Barrack been indicted on FCPA?


How about FARA?


How about LDA?



You might find last Spring’s FARA write up informative because I think it’s time to do a far deeper dive into my most favorite Trump advisor - Thomas Barrack, But it’s also time to remind you about the Tennessee Valley Authority & Bellefonte Nuclear power plant, write found here. The reality is if I really was/am a partisan hack then I certainly wouldn’t go out of my way to point out Franklin Haney’s lobbying largesse. 


FYI Franklin Haney has LDA filings in various business entities, such as FLH Company which in 2018 thus far has spent >$360,000 in lobbying for his Nuclear Development but masked it by filing under his FLH Company, Senate LDA Database found here.


And let’s not forget the January 2019 Uranium meets FARA meets Trump/Putin by way of Flynn & Cohen, where I went in to great detail of the various FARA filings, Uranium Mining, Flynn, Cohen. I specifically embedded Energy Resources International, Inc. (ERI) FARA #6590 and drilled down on TENEX- Uranium & Russia

In accordance my standard rules of engagement, I have zero intention of wittingly or unwittingly doxing either Mr. and/or Mrs Manafort, nor do I have any desired to dox Mr. Barrack. To properly set your expectations, there are some prerequisite  details that need to be disclosed, otherwise it might lead you to question the veracity of facts. For example according to the Suffolk County Clerk’s Office, on July 24, 2004 Barrack provided the Manaforts the following Mortgages:


MORTGAGE # 1 $389,002.90

MECA  (EXT/CON/MOD) $1,760,000.00

On March 8, 2006 the County Clerk’s Office RECORDs indicate the Manaforts “satisfied” the two Mortgages Barrack extended to them. Barrack and Manafort go way back. I’m talking as far back as late 1984 “back” where the two became friends. And yes the 2004 Barrack & Manafort “Mortgage” has been widely reported but the specificities 

I uploaded the full mortgage encumbrance of Manafort’s (former) Hamptons property - the pertinent mortgage info can be found on page 2 of the file on my public drive, found here. I’m certain you may have friends that would “loan” you over $2 million to help  bail you out of the financial hole. I suppose one has to really wonder why would Thomas Barrack (along with Roger Stone), do so many favors for Manafort. Because in Mueller’s Report, Volume I - specifically on page 142 (marked page 132) we learn that the FBI interviewed Thomas Barrack on December 12, 2017 - which was less than two weeks are Manafort and Gates’ October 2017 Indictment. I  suppose we should give Barrack a 1/2 star for terminating Rick Gates’ employment at Colony NorthStar shortly after the October 2017 Indictment was unsealed. 



September/November 2017 House OverSight


Originally members of the House OverSight Committee for the 115th Congress seemed to narrow their scope to Flynn. However upon further document production (then) ranking Member Cummings, officially announced his intention to broaden the scope, thereby requesting document production and transcribed interviews with various “key” Foreign Policy advisors (both in and out of the White House) accordingly on September 15, 2017 both Cummings and Engel issued the following statement and letter:


The Ranking Members expanded their earlier document request to now include all communications with any Trump Administration officials or advisers, including Gary Cohn, President Trump’s top economic adviser, and Thomas Barrack Jr., “an adviser and real estate billionaire who helped plan the administration’s May trip to Saudi Arabia,” according to the Journal’s report.

all documents previously requested in our letters of June 19, 2017September 12, 2017, and September 15, 2017.”


On November 28, 2017 letter to Barrack. found  here on page 2 of the letter - See the blue arrow? At the time you and I probably didn’t know why this was important.


Moreover on October 31, 2018, Republican Senators Marco Rubio, Todd Young, Cory Gardner, Rand Paul, and Dean Heller sent a letter to President Trump urging him to:

”suspend talks related to a potential civil nuclear cooperation agreement between the United States and Saudi Arabia” due to “serious concerns about the transparency, accountability, and judgment of current decision-makers in Saudi Arabia.”


For context this letter from Senate Republicans occurred during the maelstrom of Trump and Kushner’s own making. When they decided that the life of a Washington Post Journalist who was murdered in the most barbaric way possible, which culminated in the use of a B-O-N-E S-A-W to desecrate the remains of Mr.Jamal Khashoggi. Trump and Kushner and Barrack abdicated America’s global moral authority. Telling our Allies that “human rights” and the “Free Press” hold minimal importance over the ultimately dollar. It is such a grotesque abuse of power but lacks any modicum of human decency. Neither Trump, Kushner, Bolton or Pompeo listed to the audio. Perhaps they don’t have the stomach to listen to how MbS assassins brutally murdered one of our Journalist - either way at least CIA Director Hapsel was “man enough” to listen to what MbS’ Assasin  



In December of 2018 Forbes published an interesting article concerning Barrack’s Colony and NortStar. The headline says it all: Disastrous Deal Staggers Trump Ally Thomas Barrack

Colony NorthStar have plunged by nearly 60% since they began trading in 2017. The merger was designed to create a giant real estate investment trust with a market value of $9 billion. Today the market capitalization of Colony NorthStar is $3.4 billion.

“The results have been disappointing, and that’s the bottom line,” Barrack said on a Colony NorthStar investor call earlier this year. “It’s the majority of my personal net worth. It’s the dominant factor in my and my family’s pride, reputation and future.”


In a vacuum you could argue “so what - he made a bad business decision - this has nothing to do with Barrack’s Saudi Nuclear Plan”. My counter argument would be - if you know the “fortune” you’ve spent your life building could be flushed down the toilet because over capitalization (which tends to be a poison pill) then it’s possible you’ll look to fortify and diversify your business portfolio. Meaning Barrack could unjustly enrich himself concurrently (potentially) running a foul of both FARA, Lobbying Disclosure Act and FCPA.


In February of 2019,  ProPublica published an exhaustive article, which walked us through the “secret memo”, Barrack, Middle East Plan, Nuclear Technology and what clearly looks like impermissible activity as detailed in the FARA and FCPA statues:


Federal prosecutors in Manhattan on Monday subpoenaed documents from the nonprofit 58th Presidential Inaugural Committee, including anything related to foreign donations. Such donations to presidential inaugural committees are barred by law. Investigators are probing whether foreigners gave money in exchange for influence with the incoming Trump administration, NBC News reported.

The memo, from Barrack’s investment firm, then called Colony NorthStar, is dated February 2017, just a month after the inaugural festivities organized by Barrack, who is a longtime Trump friend.


Shortly after ProPublica published their article, the House OverSight (remember this is the 116th Congress and the Democrats control the House gavel) published their own report to the general Public on February 19, 2019:


issued an interim staff report after multiple whistleblowers came forward to warn about efforts inside the White House to rush the transfer of highly sensitive U.S. nuclear technology to Saudi Arabia in potential violation of the Atomic Energy Act and without review by Congress as required by law—efforts that may be ongoing to this day. 

Cummings also sent letters to multiple entities involved with promoting this plan, including the White House; the Departments of Commerce, Defense, Energy, State, and Treasury; the Joint Chiefs of Staff; the Central Intelligence Agency; Flynn Intel Group; IP3; ACU Strategies; Colony NorthStar; and Mr. Barrack.


Supporting documents for the February 2019 Interim Staff Report found  here

February 19, 2019 letter to the White House concerning the Trump Administration’s selling nuclear technologies to Saudi Arabia found here.  And if you are still unbothered by the Trump Administration’s unapologetic coziness with MbS-Bone-Saw then the following datapoint should make the hair on the back of your neck stand up. Because contrary to the subversive disinformation spewing from the White House and Trump sycophants this isn’t “presidential harassment” it’s called Government OverSight - you incorrigible intractable ignoramus. Your quest to be included in the murderous “strong man” club means you are willing to brake the law just to make you and your friends richer. It’s gross and it’s a case study in actual dereliction of duty. 


“The Committee’s investigation is particularly critical because the Administration’s efforts to transfer sensitive U.S. nuclear technology to Saudi Arabia appear to be ongoing.  On February 12, 2019, the President met with nuclear power developers at the White House about sharing nuclear technology with countries in the Middle East, including Saudi Arabia.  In addition, next week Mr. Kushner will be embarking on a tour of Middle Eastern capitals—including Riyadh—to discuss the economic portion of the Administration’s Middle East peace plan.”


And now this brings us to the July 29, 2019 news. I’ll concede that you can say Trump’s racist tweets are meant to divide and distract us. I’m not saying racism is a distraction. Racism is a problem - it is a corrosive ideology that continues to weaken our moral authority and the reality is - those who voted for Trump already knew he was a racist and traffics in racist tropes.  It seems apt to remind you of this bizarre campaign stump speech. During his January 2016 campaign Trump visited Cedar Falls, Iowa. The context of Trump’s “dramatic reading” of “The Snake” is he was warning his supporters of the danger of letting in refugees from Syria. 



🌶SpicyFiles Sidebar🌶 For the record this RPC report shows just how many Syrian refugees the Trump Administration has let in to our Country. For example in 2019 the Trump Administration has only let in 33 Syrian Refugees. The numbers are in fact abysmal -kind of like Trump’s presidency.


Back to the topic of Trump and Barrack Nuclear Technology and Saudi Arabia - Some of you might think I’m throwing out a ubiquitous “it’s a distraction” thereby subjugating racism as a distraction. What I am saying is as a voter you should challenge yourself to perhaps take a moment and step back, to ask yourself the following: why would Trump launch a multi-day pernicious attack on one of the mosh powerful members of Congress?


I’d argue Trump knows how to manipulate the MainStream media that his tweets are like catnip and the media’s predicable reaction is an example of the well known Pavlovian Theory. Trump Tweets something objectively racist, the MSM then spends days on his abhorrent tweets - versus looking at what and why Trump is manipulating them and the overall public narrative. Meaning instead of focusing on the tsunami of unbelievable geo-political scandals of Trump’s own making, the media gives Trump (who’s an attention junkie) exactly what he’s looking for - attention, control and unfettered power.


On July 29, 2019 Chairman Cummings issued a second interim staff report in the Committee’s long standing investigation into efforts to transfer U.S. nuclear technology to Saudi Arabia. The second interim report is the product of over 60,000 documents and countless hours of interviews.

One particular subsection of the second interim report can be found on page 2, paragraph 2 of the Executive Summary sent chills up my spine:

During the Obama Administration, Saudi Arabia refused to agree to the Gold Standard. During the Trump Administration  Saudi Crown Prince Mohammed bin Salman (MBS) went further, proclaiming: “Without a doubt, if Iran developed a nuclear bomb, we will follow suit as soon as possible.”

 The other interesting tidbit was the ME Marshall Plan (weird how Flynn has since deleted his tweets were he extolled the wanderlust of the Marshall Plan) was the acquisition of WestingHouse Electric Company. Because I’d like to draw your attention to the Global Takedown of hackers who ...wait for it...targeted WestingHouse Electric via “chopstick” (later known as Xagent) which resulted in (then) Attorney General Holder for the first time in America’s history charged Chinese hackers with Cyber Espionage. At the time I noted that WEC was Ukraine’s sole nuclear power provider.



New documents and communications show that IP3, the private company lobbying the White House to transfer U.S. nuclear technology to Saudi Arabia, repeatedly sought a $120 million investment from Saudi Crown Prince Mohammed bin Salman.  It is unclear if the company ultimately received the investment.

New documents show that IP3 officials have had unprecedented access to the highest levels of the Trump Administration, including meeting directly with President Trump, Jared Kushner, Gary Cohn, KT McFarland, and Cabinet Secretaries Rick Perry, Steven Mnuchin, Mike Pompeo, Rex Tillerson, James Mattis, and Wilbur Ross. IP3 described the Trump Administration as “an extended team member.”

New documents (pages 19 thru 42) show that Thomas J. Barrack, Jr.—a longtime personal friend, campaign donor, and inaugural chairman—negotiated directly with President Trump and other White House officials to seek powerful positions within the Administration—including Special Envoy to the Middle East and Ambassador to the United Arab Emirates—at the same time he was;

((1) promoting the interests of U.S. corporations seeking to profit from the transfer of nuclear technology to Saudi Arabia;

(2) advocating on behalf of foreign interests seeking to obtain this U.S. nuclear technology; and

(3) taking steps for his own company, Colony NorthStar, to profit from the same proposals he was advancing with the Administration. 


I am also going to point out that in October of 2018 I pulled down a plethora of FARA filings and sure enough some of the materials in the underlying documents for the House OverSight Second Interim Report also match some of the “marketing materials” aka propaganda pushed by the Saudi Government.


FCPA it’s like FARA but way worse

And now this brings us to  the Rule of Law portion of today’s program. If you are not familiar with the Foreign Corrupt Practices Act aka 15 U.S.C. §§ 78dd-1 I liken FCPA as FARA’s much meaner sister. The penalties are far more onerous but here’s one thing pundits and politicians won’t tell you - FCPA has a unique deviation that makes FCPA Enforcement far more serious (don’t conflate this with multiplicity - to do so means you don’t fully understand how these penalties work). When the Government decides to criminally peruse criminal charges under the FCPA - the prosecution can in fact use the Alternative Fines Act  - which allows for all Criminal fines sought under FCPA to be increased by a measure of twice. See 18 U.S. Code § 3571 (d) 



 Of course the big assumption here is the Roy Cohn 2.0 Department of Justice would bring FCPA charges against Barrack - but a plain reading of the FCPA Statute gives a rational predicate that Barrack et al should be really concerned. Under the FCPA it is impermissible for:


prohibits payments, gifts, or even offers of “anything of value” to a “foreign official” for the purpose of influencing the official or otherwise “securing any improper advantage” in obtaining, retaining or directing business.


Under the FCPA there are three elements necessary for a successful prosecution;  (1) A payment or something of value is offered, promised, or given (2) to a foreign official (3) for a corrupt purpose. Generally speaking the “foreign official” encompasses (but not limited to) foreign official” under the FCPA an official doesn’t always mean it’s a “high ranking” official, in fact it can be employee or agent of a foreign government either direct or indirect - that’s an important distinction;


-Administrators and faculty at foreign state universities.
-Advisors to ministries, government agencies or government officials.
-Members of government committees or panels.
-Healthcare professionals at government-owned or controlled hospitals.
- Employees of a public international organization (World Bank, IMF and some NGOs).-Members of a royal family.


Corrupt Purpose: The statute and more importantly the DOJ defines Corrupt Purpose as:

willful use of the mails or any means of instrumentality of interstate commerce corruptly in furtherance of any offer, payment, promise to pay, or authorization of the payment of money or anything of value to any person, while knowing that all or a portion of such money or thing of value will be offered, given or promised, directly or indirectly, to a foreign official to influence the foreign official in his or her official capacity, induce the foreign official to do or omit to do an act in violation of his or her lawful duty, or to secure any improper advantage in order to assist in obtaining or retaining business for or with, or directing business to, any person.


Another often overlooked component of the FCPA is if a company has “securities” listed in the United States, pursuant to 15 U.S.C. § 78m - which requires companies to keep stringent accounting practices, as the DOJ explains:


accounting provisions, which were designed to operate in tandem with the anti-bribery provisions of the FCPA, require corporations covered by the provisions to (a) make and keep books and records that accurately and fairly reflect the transactions of the corporation and (b) devise and maintain an adequate system of internal accounting controls.


With respect to the Lobbying Disclosure Act - Lobbying Disclosure Act, as amended, 2 U.S.C. § 1601 et. seq there’s zero fuzz here. Those who engage in lobbying actives are required, by law to register. Granted in January of 2017 the “threshold” was increased but if you reread the House OverSight Reports and letters there’s an actual reason the word “lobbying” is repeatedly used. Because that’s exactly the Conduct Barrack et al engaged in and they failed to register - you can double check my lobbying research via the House LDA Database, found here




With Barrack’s recent announcement that he’s stepping down from Colony NorthStar - I think most forgot to read the fine print. His departure isn’t eminent and frankly I’m of the line of thinking that this is more of an open signal to investors to abandon ship - we are caught so sell now. Again that’s my opinion and I don’t have any inside information.

FARA - Barrack did you register?

This FARA link will take you to Saudi Arabia’s filings for the past two years. As far as the DOJ FARA Enforcement:

In 2017, Michael T. Flynn pleaded guilty in the District of Columbia to making false statements to the FBI pertaining to his communications with the Russian Ambassador to the United States.  In the Statement of Offense filed with his plea agreement, Flynn admitted to making materially false statements in multiple documents filed pursuant to FARA in conjunction with worked performed by him and his company for the principal benefit of the Republic of Turkey.

In 2018, Richard Gates pleaded guilty in the District of Columbia to two counts: (i) conspiracy to commit multiple offenses, including violating FARA by failing to register and by providing false statements in a document filed with FARA; and (ii) providing false statements to the FBI. Gates participated in a scheme with Paul Manafort to lobby on behalf of the Government of Ukraine, the Ukrainian Party of Regions, and former Ukrainian President Victor Yanukovych, without registering as an agent under FARA. Gates has been cooperating with the government and is awaiting sentencing.

In 2018, after being convicted at trial in the Eastern District of Virginia on bank fraud and tax charges, Paul J. Manafort, Jr., pleaded guilty in the District of Columbia to two counts: (i) conspiracy to commit multiple offenses, including violating FARA by failing to register and by providing false statements in a document filed with FARA, and laundering money; and (ii) conspiracy to obstruct justice by tampering with witnesses. Manafort failed to register under FARA as an agent of the Government of Ukraine, the Ukrainian Party of Regions, and former Ukrainian President Yanukovych. Manafort was sentenced to 73 months’ imprisonment, including the statutory maximum 60 months for the conspiracy to violate FARA (Manafort is due to serve an additional 17 months stemming from his conviction in the Eastern District of Virginia) .

In 2018, W. Samuel Patten pleaded guilty in the District of Columbia to violating FARA by engaging in lobbying and political consulting in the United States on behalf of the Opposition Bloc, a Ukrainian political party, without registering under FARA. Patten contacted members of Congress, the executive branch, and the news media; drafted talking points for a Ukraine oligarch for meetings with members of Congress and congressional staff; and helped the oligarch draft articles targeted at the U.S. press. Patten cooperated with and provided substantial assistance to the government, and was sentenced to 36 months of probation.

In 2018, a grand jury in the District of Columbia returned an eight-count indictment of 13 Russian nationals and three Russian companies (the Internet Research Agency LLC, Concord Management and Consulting LLC, and Concord Catering) for committing crimes while seeking to interfere in the U.S. political system, including the 2016 presidential election. Count One charges the defendants with, among other things, conspiracy to defraud the United States by impairing, obstructing and defeating the lawful functions of the U.S. Department of Justice to administer and enforce FARA. The indictment alleges that the “Defendants and their co-conspirators, while concealing their Russian identities and [Internet Research Agency] affiliation through false personas, began to produce, purchase, and post advertisements on U.S. social media and other online sites expressly advocating for the election of then-candidate Trump or expressly opposing Clinton.” The indictment also alleges “Defendants and their co-conspirators organized and coordinated political rallies in the United States.”

In 2018, Elena Alekseevna Khusyaynova, a Russian national, was charged by criminal complaint in the Eastern District of Virginia for her alleged role in a Russian conspiracy to interfere in the U.S. political system, including the 2018 midterm election. The complaint alleges that Khusyaynova conspired to defraud the United States by impairing, obstructing, and defeating the lawful functions of the U.S. Department of Justice to administer and enforce FARA, among other offenses.

In 2018, Nisar Ahmed Chaudhry pleaded guilty in the District of Maryland for failing to register under FARA as an agent for the Government of Pakistan, including its military, intelligence and diplomatic officials.

In 2019, the U.S. law firm Skadden, Arps, Slate, Meagher & Flom LLP entered into a settlement agreement resolving its liability for violations of FARA.  According to the agreement, Skadden acted as an agent of the Government of Ukraine by contributing to a public relations campaign directed at select members of the U.S. news media in 2012.  In response to inquiries from the FARA Unit about its role in that campaign, a partner then at Skadden made false and misleading statements to the FARA Unit, which led the FARA Unit to conclude in 2013 that the firm was not obligated to register. The facts, when uncovered, showed that Skadden was required to register in 2012. The firm registered, admitted it made false and misleading statements in response to inquiries from the FARA Unit, disgorged over $4.6 million in fees, and agreed to ensure it has formal, robust procedures for responding to inquiries concerning its conduct from any federal government entity and ensuring FARA compliance as to its engagements on behalf of foreign clients.

In 2019 Greg Craig - the Case is ongoing 

In the infancy of the Trump Administration Saudi Arabia had a literally FARA Army spending millions of dollars per month.

And this actually matters because it is not my opinion that Saudi Arabia had an Army of forms lobbying and the dates of this DOJ Report to Congress (reporting period June 2017 to December 2017) are important because this overlaps with the same timeframe Barrack was absolutely engaging in activity that would have required him to register as an Agent of a Foreign Government. They hired 29 separate firms yet after MbS-Bone-Saw ordered the brutal and barbaric murder of Washington Post Journalist Mr Khashoggi...



The fact remains that the DOJ has yet to send Congress their bi-Annual FARA Report, so it is a bit difficult to determine just how many foreign agents Saudi Arabia and/or the Middle East actually have on their payroll. But I can with 100% confidence inform you that Thomas Barrack or any other person or entity “lobbying” on behalf of Saudi Arabia and the nuclear technologies have not registered with FARA or the House/Senate LDA.



I will say this 2013 interview (which is an hour long) was pretty damn interesting and worthwhile to watch - it gives you a more in-depth understanding of how Barrack thinks and it shows just how revered he is, especially in Saudi Arabia - where he once lived:


Since you’ve made it this far in to this write up - I figured I’d reward you with a little under reported FARA nugget. FARA # 6698 - because clearly I’m in the wrong line of work - how the heck do I get a piece of that multimillion payday for a few months of work?


NEOM COMPANY and TENEO STRATEGY LLC, consultancy agreement 


The Employer shall pay the Consultant SAR 7,875,000 (the “Contract Price”) in accordance with this Contract. Subject to the Employer's pre-approval and an aggregate cap of SAR 500,000, business travel and expenses, with respect to airfare, vehicle transportation, meals and reasonable incidentals (excluding alcoholic beverages and tips), will be reimbursed at actual cost with receipts and supporting documentation.


The Commencement Date of the Services The Date for Completion of the Services shall be 31 October 2019 (the “Date for Completion"), as may be adjusted upon the mutual agreement of the Parties in accordance with this Contract.

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  • Sanne Janssen: August 12, 2019

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  • Marie G : August 01, 2019

    Great write up, Spicy. This recurring theme of ‘who paid off their debt’ is such a cornerstone of this sh$&show.

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