Trump Administration Gives All Clear to Laundering Money through Shell Companies and Bribing Foreign Officials
By Pam Martens and Russ Martens: March 19, 2025 ~
On February 10, President Donald Trump issued an Executive Order that suspended the Foreign Corrupt Practices Act (FCPA) for 180 days, giving an all clear to U.S. corporations to bribe officials in foreign countries to get business deals approved. The order bars federal prosecutors from starting any new FCPA investigations, enforcing new actions and orders a review of existing FCPA investigations to “restore proper bounds” on applying the FCPA law.
The FCPA, enacted in 1977, has been the law of the United States for almost half a century. In July 2020, the Justice Department and Securities and Exchange Commission issued a comprehensive and updated guide to the FCPA. It explained its purpose as follows:
“Foreign bribery is a scourge that must be eradicated. It undermines the rule of law, empowers authoritarian rulers, distorts free and fair markets, disadvantages honest and ethical companies, and threatens national security and sustainable development. This updated Guide is meant not only to summarize the product of the dedicated and hardworking individuals who combat foreign bribery as part of their work for the U.S. government, but also to help companies, practitioners, and the public — many of whom find themselves on the front lines of this fight —prevent corruption in the first instance. We hope that the Guide will continue to be an invaluable resource in those efforts.”
In early March the Trump administration gutted another anti-corruption law, the Corporate Transparency Act.
The Corporate Transparency Act became law in 2021. Its goal is to curb anonymous shell companies from money laundering in the U.S. behind a dark curtain. It requires that the true owners of these shell companies must file that beneficial ownership information into a federal registry established by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and it imposes stiff fines and up to two years in prison for failure to do so.
Quietly, with little fanfare on March 2, Trump’s newly installed Treasury Secretary (hedge fund honcho Scott Bessent) announced that he would not enforce the Corporate Transparency Act as the law was written. The statement from the Treasury Department said this:
“The Treasury Department is announcing today that, with respect to the Corporate Transparency Act, not only will it not enforce any penalties or fines associated with the beneficial ownership information reporting rule under the existing regulatory deadlines, but it will further not enforce any penalties or fines against U.S. citizens or domestic reporting companies or their beneficial owners after the forthcoming rule changes take effect either. The Treasury Department will further be issuing a proposed rulemaking that will narrow the scope of the rule to foreign reporting companies only. Treasury takes this step in the interest of supporting hard-working American taxpayers and small businesses and ensuring that the rule is appropriately tailored to advance the public interest.”
We have read regulatory announcements by the U.S. Treasury Department for decades. We have never read anything from prior administrations that is so unprofessionally constructed or that so brazenly thumbs its nose at duly passed laws by the U.S. Congress.
These two bizarre rollbacks of anti-corruption legislation raise the obvious question: Who benefits?
Donald Trump himself comes to mind.
In March 2017, USA Today published an explosive expose that revealed the following:
“Trump’s privately held company works through a network of subsidiaries and partnerships that make direct connections hard to trace, particularly since he has refused to release his tax filings. In addition, some of the Trump Organization’s investors and buyers operate through shell companies and limited liability corporations that hide the identities of individual owners.”
The article drilled down further to these specifics:
“• A member of the firm that developed the Trump SoHo Hotel in New York is a twice-convicted felon who spent a year in prison for stabbing a man and later scouted for Trump investments in Russia.
“• An investor in the SoHo project was accused by Belgian authorities in 2011 in a $55 million money-laundering scheme.
“• Three owners of Trump condos in Florida and Manhattan were accused in federal indictments of belonging to a Russian-American organized crime group and working for a major international crime boss based in Russia.
“• A former mayor from Kazakhstan was accused in a federal lawsuit filed in Los Angeles in 2014 of hiding millions of dollars looted from his city, some of which was spent on three Trump SoHo units.
“• A Ukrainian owner of two Trump condos in Florida was indicted in a money-laundering scheme involving a former prime minister of Ukraine.
“…What’s more, Trump and his companies have had business dealings with Russians that go back decades, raising questions about whether his policies would be influenced by business considerations.”
In 2008 Trump’s son, Donald Jr., told Russian media while he was in Moscow that “Russians make up a pretty disproportionate cross-section of a lot of our assets; say in Dubai, and certainly with our project in SoHo and anywhere in New York. We see a lot of money pouring in from Russia. There’s indeed a lot of money coming for new-builds and resale reflecting a trend in the Russian economy and, of course, the weak dollar versus the ruble” according to USA Today reporting in December 2016.
On Wed, Mar 19, 2025, 11:22 AM Gunnar Larson <
g@xny.io> wrote:
Goldman Sachs:
xNY.io - Bank.org is prepared to take any potential arguments to every Supreme Court on Planet Earth for consideration.
xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
Thank you,
Gunnar Larson
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Gunnar Donald Arthur Peter Larson
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On Wed, Mar 19, 2025, 10:23 AM Gunnar Larson <
g@xny.io> wrote:
Goldman Sachs:
xNY.io - Bank.org's research could paint a stark image for Gomdman Sachs' Board Directors if the firm knowingly made efforts to defraud the United States of America AND xNY.io - Bank.org symaltaniouly; While under an active Deferred Prosecution Agreement with the United States of America.
xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
Thank you,
Gunnar Larson
--
Gunnar Donald Arthur Peter Larson
xNY.io - Bank.org
917-580-8053
On Wed, Mar 19, 2025, 8:04 AM Gunnar Larson <
g@xny.io> wrote:
Goldman Sachs:
xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
Thank you,
Gunnar Larson
--
Gunnar Donald Arthur Peter Larson
xNY.io - Bank.org
917-580-8053
On Tue, Mar 18, 2025, 12:46 PM Gunnar Larson <
g@xny.io> wrote:
Goldman Sachs:The whole idea of Goldman Sachs' Deferred Prosecution Agreement is to uphold oversight of the Board Directors' Independence; To uphold the Agreement's mandates; And to respect 'third-party' relationships.
Activist Investor Calls For Reconstitution Of Parkland's Board
By Jade Martinez-Pogue
Activist hedge fund Engine Capital on Monday called for a comprehensive reconstitution of Calgary, Alberta-based Parkland Corp.'s board of directors, saying that the current board has overseen "meaningful underperformance" and demonstrated "zero interest" in engaging with its shareholders.
Read full article » | Save to favorites »
Will Goldman Sachs' Board Directors submit the Board to an audit of the Deferred Agreement’s mandates?
xNY.io - Bank.org confirms, Goldman Sachs' Deferred Prosecution Agreement holds certain employee, customer and vendor data requirements.
Goldman-Sachs-Deferred-Prosecution-Agreement.pdf:
"Proper Oversight and Independence
- 7. The Company will assign responsibility to one or more senior corporate executives of the Company for the implementation and oversight of the Company’s anti-corruption compliance code, policies, and procedures. Such corporate official(s) shall have the authority to report directly to independent monitoring bodies, including internal audit, the Company’s Board of Directors, or any appropriate committee of the Board of Directors, and shall have an adequate level of stature and autonomy from management as well as sufficient resources and authority to maintain such autonomy.
Third-Party Relationships
- 14. The Company will institute appropriate risk-based due diligence and compliance requirements pertaining to the retention and oversight of all agents and business partners, including: a. properly documented due diligence pertaining to the hiring and appropriate and regular oversight of agents and business partners; ..."
xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
Thank you,
Gunnar Larson
--
Gunnar Donald Arthur Peter Larson
xNY.io - Bank.org
917-580-8053
On Tue, Mar 18, 2025, 7:13 AM Gunnar Larson <
g@xny.io> wrote:
Goldman Sachs:
Your firm's Deferred Prosecution Agreement with the United States of America was a supreme agreement; To protect New Yorkers and Americans from Goldman Sachs' potential future descresions.
xNY.io - Bank.org's running hypothesis is to move the Deferred Agreement conversation forward on or before March 24, 2025.
- Further inquiry could eventually summerise an enterprise software racket perpetuated by Goldman Sachs;
- Perhaps, an enterprise software RICO could be argued visavie Goldman Sachs' software relationships at Coinbase, Fireblocks, Robinhood, Apple Card and WorldBank.org;
- While under active Deferred Prosecution Agreement with the United States of America.
xNY.io - Bank.org's research could paint a stark image for Gomdman Sachs' Board Directors if the firm knowingly made efforts to defraud the United States of America AND xNY.io - Bank.org symaltaniouly; While under an active Deferred Prosecution Agreement with the United States of America.
xNY.io - Bank.org respectfully reserves all Interjurisdictional rights.
Thank you,
Gunnar Larson
--
Gunnar Donald Arthur Peter Larson
xNY.io - Bank.org
917-580-8053
---------- Forwarded message ---------
From:
Laura Peavey <lpeavey@fsforum.com>Date: Mon, Mar 17, 2025, 5:22 PM
Subject: Forum Welcomes Nomination for Fed Vice Chair for Supervision
To: Gunnar Larson <
G@xny.io>
The Forum congratulates Michelle Bowman on her nomination to serve as the Federal Reserve Board’s Vice Chair for Supervision.  “Banking regulation and supervision play critical roles in ensuring a safe and sound financial system.” Washington, D.C. – Financial Services Forum President and CEO Kevin Fromer issued the following statement today after President Trump announced his nomination of Federal Reserve Governor Michelle Bowman to serve as the Federal Reserve Board’s Vice Chair for Supervision: “The Forum congratulates Governor Bowman on her nomination and commends President Trump for his action to fill this position. Banking regulation and supervision play critical roles in ensuring a safe and sound financial system. The Vice Chair for Supervision focuses on the policies and practices which affect the ability of banks to serve our economy and contribute to financial stability. America’s leading banks—the strongest and most diversified financial institutions based in the United States—look forward to working with the next Vice Chair for Supervision to implement sound regulation and effective supervision that promotes economic growth.” The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. |
|
On Mon, Mar 17, 2025, 3:02 PM Gunnar Larson <
g@xny.io> wrote:
Dear Goldman Sachs:
Today, xNY.io - Bank.org doubles down on our commitment to Peace on Planet Earth.
xNY.io - Bank.org shares 492 highlights to: "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."
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Gunnar Larson
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----- (PAGE BREAK) -----
492 highlights to: "UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 22-CV-14102-MIDDLEBROOKS DONALD J. TRUMP, Plaintiff, v. HILLARY R. CLINTON, et al., Defendants."
INTRODUCTION
March 24, 2022
1. In the run-up to the 2016 Presidential Election, Hillary Clinton and hercohortsorchestrated an unthinkable plot – one that shocks the conscience and is anaffront to this nation’s democracy. Acting in concert, the Defendantsmaliciously conspired to weave a false narrative that their Republicanopponent, Donald J. Trump, was colluding with a hostile foreignsovereignty.The actions taken in furtherance of their scheme—falsifying evidence,deceiving law enforcement, and exploiting access to highly-sensitive datasources - are so outrageous, subversive and incendiary that even the eventsof Watergate pale in comparison.2. Under the guise of ‘opposition research,’ ‘data analytics,’ and otherpoliticalstratagems, the Defendants nefariously sought to sway the public’s trust.They worked together with a single, self-serving purpose: to vilify DonaldJ. Trump. Indeed, their far-reaching conspiracy was designed to crippleTrump’s bid for presidency by fabricating a scandal that wouldbe used to trigger an unfounded federal investigation and ignite a mediafrenzy.3. The scheme was conceived, coordinated and carried out by top-levelofficials at theClinton Campaign and the DNC—including ‘the candidate’ herself—whoattempted to shield her involvement behind a wall of third parties.1 Tostart, the Clinton Campaign and the DNC enlisted the assistance of theirshared counsel, Perkins Coie, a law firm with deep Democrat ties, in thehopes of obscuring their actions under the veil of attorney-clientprivilege. Perkins Coie was tasked with spearheading the scheme to find—orfabricate—proof of a sinister link between Donald J. Trump and Russia.To do so, Perkins Coie launched parallel operations: on one front, PerkinsCoie partner Marc Elias led an effort to produce spurious ‘oppositionresearch’ claimingto reveal illicit ties between the Trump Campaign and Russian operatives;on a separate front, Perkins Coie partner Michael Sussmann headed acampaign to develop misleading evidence of a bogus ‘back channel’connection between e-mail servers at Trump Tower and a Russian-ownedbank.4. Marc Elias, in his mission to obtain derogatory anti-Trump ‘oppositionresearch,’ commissioned Fusion GPS, an investigative firm, and itsco-founders, Peter Fritsch and Glenn Simpson, and directed them to dredgeup evidence—actual or otherwise—of collusion between Trump and Russia.Fritsch and Simpson, in turn, enlisted the assistance of Orbis Ltd. and itsowner, Christopher Steele, to produce a series of reports purporting tocontain proof of thesupposed collusion. Of course, the now fully debunked collection ofreports, known as the “Steele Dossier,” was riddled with misstatements,misrepresentations and, most of all, flat out lies. In truth, the SteeleDossier was largely based upon information provided to Steele by hisprimarysub-source, Igor Danchenko, who was subsequently indicted for falsifyinghis claims. Even more damning, Danchenko had close ties to senior ClintonCampaign official, Charles Halliday Dolan, Jr., who knowingly providedfalse information to Danchenko, who relayed it to Steele, whoreported it in the Steele Dossier and eagerly fed the deceptions to boththe media and the FBI. This duplicitous arrangement existed for a singularself-serving purpose – to discredit Donald J. Trumpand his campaign.5. At the same time, Michael Sussmann, in his hunt for damaging intelagainst theTrump Campaign, turned to Neustar, Inc., an information technology company,and one of its top executives, Rodney Joffe, a fervent anti-Trumper who hadrecently been promised a high-ranking position with the ClintonAdministration, to exploit their access to non-public data in search of asecret “back channel” connection between Trump Tower and Alfa Bank. When itwas discovered that no such channel existed, the Defendants resorted totruly subversive measures – hacking servers at Trump Tower, Trump’s privateapartment, and, most alarmingly, the White House. Thisill-gotten data was then manipulated to create a misleading “inference” andsubmitted to law enforcement in an effort to falsely implicate Donald J.Trump and his campaign.2 All of these actswere carried out in coordination with the Clinton Campaign and the DNC, atthe behest of certain Democratic “VIPs.”36. While their multi-pronged attack was underway, the Defendants seized ontheopportunity to publicly malign Donald J. Trump by instigating a full-blownmedia frenzy. Indeed, the Clinton Campaign and DNC—admittedly on a“mission” to “raise the alarm” about their contrived Trump-Russialink4—repeatedly fed disinformation to the media and shamelesslypromoted their false narratives. All the while, Hillary Clinton, JakeSullivan, Debbie Wasserman Schultz, and others did their best toproliferate the spread of those dubious and false claims throughpress releases, social media, and other public statements.7. The fallout from the Defendants’ actions was not limited to the publicdenigrationof Trump and his campaign. The Federal Bureau of Investigation(FBI)—relying on the Defendants’ fraudulent evidence—commenced alarge-scale investigation and expended precious time, resources andtaxpayer dollars looking into the spurious allegation that the TrumpCampaignhad colluded with the Russian Government to interfere in the 2016presidential election. The effects of this unfounded investigation wereprolonged and exacerbated by the presence of a small faction of Clintonloyalists who were well-positioned within the Department of Justice and theFBI– James Comey, Andrew McCabe, Peter Strzok, Lisa Page, Kevin Clinesmith,and Bruce Ohr. These government officials were willing to abuse theirpositions of public trust to advance the baseless probe to new levels,including obtaining an extrajudicial FISA warrant and instigating thecommencement of an oversight investigation headed by Special Counsel RobertMueller. As a result, Donald J. Trump and his campaign were forced toexpend tens of millions of dollars in legalfees to defend against these contrived and unwarranted proceedings. Justicewould ultimately prevail – following a two-year investigation, SpecialCounsel Mueller went on to exonerate Donald J. Trump and his campaign withhis finding that there was no evidence of collusion with Russia.8. The full extent of the Defendants’ wrongdoing has been steadily andgradually exposed by Special Counsel John Durham, who has been heading aDOJ investigation into the origins of the Trump-Russia conspiracy. To date,he has already issued indictments to Sussmann and Danchenko, among others,for proffering false statements to law enforcement officials. Asoutlined below, these ‘speaking’ indictments not only implicate many of theDefendants named herein but also provide a great deal of insight into theinner-workings of the Defendants’ conspiratorial enterprise. Based onrecent developments and the overall direction of Durham’sinvestigation, it seems all but certain that additional indictments areforthcoming.9. In short, the Defendants, blinded by political ambition, orchestrated amaliciousconspiracy to disseminate patently false and injurious information aboutDonald J. Trump and his campaign, all in the hopes of destroying his life,his political career and rigging the 2016 Presidential Election in favor ofHillary Clinton. When their gambit failed, and Donald J. Trumpwas elected, the Defendants’ efforts continued unabated, merely shiftingtheir focus to undermining his presidential administration. Worse still,the Defendants continue to spread their vicious lies to this day as theyunabashedly publicize their thoroughly debunked falsehoods in aneffort to ensure that he will never be elected again. The deception,malice, and treacheryperpetrated by the Defendants has caused significant harm to the Americanpeople, and to the Plaintiff, Donald J. Trump, and they must be heldaccountable for their heinous acts.____________________BACKGROUND
September 8, 2022
Plaintiff initiated this lawsuit on March 24, 2022, alleging that “theDefendants, blinded by political ambition, orchestrated a maliciousconspiracy to disseminate patently false and injuriousinformation about Donald J. Trump and his campaign, all in the hopes ofdestroying his life, his political career and rigging the 2016 PresidentialElection in favor of Hillary Clinton.” (DE 177, Am. Compl. ¶ 9). On thisgeneral premise, Plaintiff brings a claim for violations of the RacketeerInfluenced and Corrupt Organizations Act (“RICO”), predicated on the theftof trade secrets, obstruction of justice, and wire fraud (Count I). Headditionally brings claims for: injurious falsehood (Count III); maliciousprosecution (Count V); violations of the Computer Fraud and Abuse Act(“CFAA”) (Count VII); theft of trade secrets under the Defend Trade SecretsAct of2016 (“DTSA”) (Count VIII); and violations of the Stored Communications Act(“SCA”) (Count IX). The Amended Complaint also contains counts for variousconspiracy charges and theories of agency and vicarious liability. (CountsII, IV, VI, and X–XVI). Plaintiff’s theory of this case, set forth over 527paragraphs in the first 118 pages of the Amended Complaint, is difficult tosummarize in a concise and cohesive manner.It was certainly not presented that way. Nevertheless, I will attempt todistill it here.The short version: Plaintiff alleges that the Defendants “[a]cting inconcert . . . maliciously conspired to weave a false narrative that theirRepublican opponent, Donald J. Trump, was colluding with a hostile foreignsovereignty.” (Am. Compl. ¶ 1). The Defendants effectuated thisalleged conspiracy through two core efforts. “[O]n one front, Perkins Coiepartner Mark Elias led an effort to produce spurious ‘opposition research’claiming to reveal illicit ties between the Trumpcampaign and Russian operatives.” (Id. ¶ 3).To that end, Defendant Hillary Clinton and her campaign, the DemocraticNational Committee, and lawyers for the Campaign and the Committeeallegedly hired Defendant Fusion GPS to fabricate the Steele Dossier. (Id.¶ 4). “[O]n a separatefront, Perkins Coie partner Michael Sussman headed a campaign to developmisleading evidence of a bogus ‘back channel’ connection between e-mailservers at Trump Tower and a Russian-owned bank.” (Id.). Clinton and her operatives allegedly hired DefendantRodney Joffe to exploit his access to Domain Name Systems (“DNS”) data, viaDefendant Neustar, to investigate andultimately manufacture a suspicious pattern of activity betweenTrump-related servers and a Russian bank with ties to Vladimir Putin, AlfaBank. (Id. ¶ 3). As a result of this “fraudulent evidence,” the FederalBureau of Investigations (“FBI”) commenced “several large-scaleinvestigations,” which were “prolonged and exacerbated by the presence of asmall faction ofClinton loyalists who were well-positioned within the Department ofJustice”—Defendants James Comey, Andrew McCabe, Peter Strzok, Lisa Page,Kevin Clinesmith, and Bruce Ohr. (Id. ¶ 7).And while this was ongoing, the Defendants allegedly “seized on theopportunity to publicly malign Donald J. Trump by instigating a full-blownmedia frenzy.” (Id. ¶ 6). As a result of this “multi-pronged attack,”Plaintiff claims to have amassed $24 million in damages.1(Id. ¶ 527).Defendants now move to dismiss the Amended Complaint as “a series ofdisconnected political disputes that Plaintiff has alchemized into asweeping conspiracy among the many individuals Plaintiff believes to haveaggrieved him.” (DE 226 at 1). They argue that dismissal iswarranted because Plaintiff’s claims are both “hopelessly stale”—that is,foreclosed by the applicable statutes of limitations—and because they failon the merits “in multiple independent respects.” (Id. at 2). As they viewit, “[w]hatever the utilities of [the Amended Complaint] as a fundraisingtool, a press release, or a list of political grievances, it has no meritas a lawsuit.” (Id.).I agree. In the discussion that follows, I first address the AmendedComplaint’s structural deficiencies. I then turn to subject matterjurisdiction and the personal jurisdiction arguments raised by certainDefendants. Finally, I assess the sufficiency of the allegations as to eachof thesubstantive counts.____________________BACKGROUND
October 31, 2022
PlaintifP’s pleadings and theories were obviously and fatally defectivefrom the veryinceptionof this action. Plaintiff's initial Complaint spanned 108 pagesand S08 paragraphs. DE 1 (March 24, 2022). It named 28 individualdefendants, as well as 10 John Does and 10 ABC Corporations. /d.Less than a month after the Complaint was filed, Hillary Clinton moved todismiss it with prejudice. DE 52 (Apr. 20,2022). Defendant Clinton’s motionidentified manyofthe fundamentalfactual deficiencies and legal flaws thatwould ultimately lead this Court to dismiss the AmendedComplaint: namely, (1) that Plaintifs claims were untimely on their face,DE 52 at 1-5; (2) that Plaintiff's own tweets confirmed his knowledge ofhissupposed claimsno later than October 2017, DE 52 at 2-3; (3) thatPlaintiffs Complaint was replete with inadequate and conclusoryallegations, DE 52 at 6; (4) that Plaintiff failed to allege a RICOenterprise, DE 52 at 7; (5) thatPlaintiff failed to allege the predicate act of theft of trade secretsbased on DNS information, DE 52 at 8-9; (6) thatPlaintifffailedtoallege thepredicate act ofobstructionofjustice in part becausehe identified no “official proceeding,” DE 52 at 9-10; (7) that Plaintifffailed to allege a patter of racketeering activity, DE 52 at 11-12; (8)that Plaintiff failed to adequately allege RICO standing because hissupposed injuries were almostentirely undescribed, DE 52.at 12-14; (9) thatPlaintiffs injurious falsehood claim was barred by the First Amendment, DE52 at 15-17; (10) that Plaintiff failed to allege almost every necessaryclementof injurious falsehood under Florida law, DE 52 at17-18; (11) that Plaintiff failed to allege a malicious prosecution claimas to any official proceeding and, in particular, as to the properlypredicated Crossfire Hurricane investigation, DE 52 at 19-20; and (12) thatPlaintiff failed to allege a claim for “agency” because it is not an
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