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russian gambling ring busted california Donald Trump's finances are almost hopelessly opaque, exacerbating concerns that the wealthiest president in American history—and the first in decades not to meaningfully divest from his business holdings—may be even more financially compromised than is already thought, and in ways that may impact his decisions in office.
To keep kompromat on friends is a must.
Over a similar period, Trump and the Trump Organization have become heavily intertwined with some of the same government-linked Russian business elites.
The ease with which deliberate contacts and coordination between Russia and Trump associates could have occurred is readily apparent.
While Special Counsel Robert Mueller investigates the extent of the interactions between the Trump campaign and Russia, there are steps policymakers can take now to address some of the vulnerabilities that have exposed U.
First, the legislative and executive branches should crack down on the use of shell corporations as a means to launder money or conceal the provenance of funds flowing into campaigns.
Congress and the executive branch should also curb money laundering through domestic real estate, which is currently pervasive due to virtually absent regulations in this sector.
Lastly, legislators must continue to shine a light on corruption and conflicts of interest, which weaken democratic systems from within and make them susceptible to adversaries.
By recognizing the central role that illicit and furtive money plays in the undermining of democratic institutions, U.
This report is organized into the following four chapters.
This section examines how Russia has leveraged economic and financial ties in its political influence campaigns in Europe, particularly the former Soviet bloc countries.
Presented examples establish a framework through which to analyze influence campaigns in the United States, notably in the context of the 2016 presidential election and beyond.
It also considers the possible implications of his disparagement of anti-bribery laws in the context of his deals in the corruption-prone former Soviet countries such as Azerbaijan, Georgia, and Kazakhstan.
Notably, in recent years Russian security organs have relied on sophisticated means of leveraging compromising evidence of financial misdeeds—including allegations of money laundering and corruption—to achieve its aims.
Recommendations The recommendations urge policymakers and law enforcement to address acute regulatory gaps by deterring abuse of shell companies for purposes of obscuring sources of funds flowing into U.
Furthermore, proper anti-money laundering due diligence and reporting mechanism should be used to close the loophole of all-cash anonymous purchases of real estate.
And in interdicting possible vectors of foreign influence beyond elections, legislators also need to ensure that office holders properly divest from their businesses, thereby checking potential conflicts of interests.
It also meant the oligarchy would act on behalf of the state, thus erasing the boundary between the two.
Under Putin, they were co-opted, marginalized, or strong-armed into obedience.
Some, such as Vladimir Gusinsky and Boris Berezovsky, who dared to challenge Putin through their media empires, were forced into exile.
Others, most prominently Mikhail Khodorkovsky, the owner of Yukos Oil Company, were jailed on charges such as tax evasion.
Observers have commented on the political underpinnings of these charges.
More recently, Vladimir Yevtushenkov, another energy tycoon, lost his regional oil producer Bashneft to Rosneft under similar circumstances.
Following the Yeltsin-era privatization, the renationalization of companies under Putin has been an important mode of consolidating state power over strategic assets such as oil and gas producers, as well as major manufacturers and banks.
In September 2014, the Russian authorities accused Yevtushenkov of money laundering in connection with his 2009 purchase of Bashneft.
After the charges were levied, Yevtushenkov was placed under house arrest and Bashneft was ultimately renationalized.
Analysts at the time noted echoes of the Yukos affair and compared Yevtushenkov to Khodorkovsky by way of their shared experience with the reach of the state.
However, there was a key difference between the two cases, which made those inside the patrimonial system even more apprehensive.
Unlike Khodorkovsky, Yevtushenkov was not an opposition figure.
If the Kremlin will target a captain of industry as compliant as Yevtushenkov, the implication is that no one is safe.
One of the most notable examples occurred in 2009, when, on national television, the Russian president cowed the aluminum magnate Oleg Deripaska.
Deripaska, an otherwise fearsome oligarch, was submissive when Putin, cameras in tow, paid a visit to his factory and forced Deripaska to sign a document granting several concessions.
In a made-for-television moment, Putin first provided Deripaska with a pen for signing, then snarled at him when, ostensibly overcome by anxiety, Deripaska forgot to return it.
Since then media assets have been steadily consolidated in the hands loyal to the Putin regime.
In recent years, consolidation and suppression of media outlets has continued, as Masha Lipman described in The New Yorker.
Most recently, RBC, a major Russian media organization owned by billionaire Mikhail Prokhorov, sacked a number of its editors.
In November 2014, mere months after the first of the U.
The law aimed to increase tax revenues in anticipation of a sustained economic recession, which the sanctions only worsened.
For some wealthy elites, the de-offshorization law became a motive to shed their Russian tax residency status, creating a population of semi-exiled oligarchs.
For others, such as Roman Abramovich, the high-profile owner of the Chelsea Football Club professional soccer team, the law provided an opportunity to reaffirm their loyalty to the regime.
Despite appearing to spend most of his time in London, Abramovich has retained check this out Russian residency status for tax purposes, a decision the Russian-language version of Forbes cited in July 2016 as an example of his patriotism.
Another underexplored consequence of the de-offshorization law is how to control your gambling addiction it gives the Russian https://veronsmeatmarket.com/gambling/gambling-taxes-in-vegas.html greater insight into the previously hidden foreign business networks and assets of its business and political elites.
The law may not have check this out away with the veil of shell companies that the wealthy use to hide their assets, but it made the veil more sheer.
This transparency is critical, especially when considering how overseas commercial networks can be activated to facilitate foreign policy objectives.
Shell companies are legal entities that generally have no physical assets or operations and may be used solely to hold property rights or financial assets.
They represent one mode by which corporations can be used to obscure ultimate beneficiaries, assets, and sources of funds.
Another common method is the use of front companies, which may combine illicit proceeds of a crime with lawful proceeds from legitimate business operations, thereby masking the origins of the former.
Nominee-held funnel accounts may be used to make structured deposits and corresponding withdrawals across multiple geographic jurisdictions.
Increasingly isolated from the global markets, tycoons such as the Rotenberg brothers and Gennady Timchenko have had to turn their investments inward.
Moreover, some have taken on major endeavors for the good of the state, but at a loss to their pockets.
However, the bridge is not expected to be profitable.
After other contractors turned down the project, Rotenberg acquiesced.
These examples illustrate how Putin has cultivated a patronage system with respect to the Russian oligarchy and business elites, relying on a combination of rewards and punishments.
The same method of coopting has been applied to politicians in Russia, as the recent cases of the former Komi Republic Governor Vyacheslav Gaizer and the former Minister of the Economy Aleksey Ulyukayev illustrate.
Both men were accused of corruption and other financial crimes.
It is critical to view corruption as a binary that can both reward and punish.
Corruption provides for illicit favors, which in turn engender debt and compromising evidence of having engaged in such an activity.
As Marshall Goldman describes in his book, The Piratization of Russia: Russian Reform Goes Awry, the Kremlin has been pursuing this strategy since the days of the Soviet Union.
Goldman writes: Beyond espionage and facilitating and financing foreign trade, the Soviet overseas network of businesses and banks had yet a third task.
Soviet multinational banks and corporations were also charged with funding the national communist parties around the globe.
This involved diverting funds from their ostensible purpose: in other words, money laundering.
In the decades since, money launderers and financial obfuscators have honed their craft using anonymous shell companies, nominee accounts, offshore secrecy havens, and creative transaction structuring.
For example, where so-called mirror trades were once a preferred means of moving money out of Russia and russian gambling ring busted california the global financial system, launderers now reportedly favor illicit reinsurance contracts and falsified court judgments.
The process bypassed tax officials, currency regulators, and anti-money laundering controls.
Deutsche Bank representatives have reportedly commented that the ultimate purpose or destination of the mirror trades, which facilitated the funneling of billions of dollars out of Russia, was never uncovered.
The study argues that the Kremlin has manipulated its deep economic and financial ties with its trade partners, particularly its neighbors in Central and Eastern Europe and the Caucasus, to penetrate and corrupt local governments.
On a geopolitical scale, Russia has used state-owned conglomerates such as Gazprom and Rosneft as tools of foreign policy.
In countries such as Bulgaria and Hungary, Russia has also used its multinationals to allocate choice contracts to individuals it could then manipulate in local politics.
Financial incentives are especially effective in countries reeling economically.
The CSIS study found that numerous local government officials associated with pro-Russian political parties, politicians, businessmen, and nongovernmental organizations have been involved in a series of bribery and public procurement scandals that have penetrated all levels of government.
In the eyes of the Kremlin, Donald Trump would have represented a perfect target for corrupting, well before the 2016 presidential campaign.
Before he ran for president, Trump was a conspicuous business mogul, constantly flirting with bankruptcy and financial collapse.
Shunned by traditional Western lenders, he made frequent overtures to Russian money and accepted injections of cash from Kremlin-linked figures, such as Dmitry Rybolovlev.
He repeatedly disparaged anti-bribery laws and regulations, eschewed transparency through use of shell companies and impervious corporate jurisdictions, and embraced unsavory business partners.
With a pivot to international licensing deals click to see more the mid-2000s, Trump grew increasingly accessible and more exposed to tampering and potential compromise.
Any such cultivation would have matured when the conspicuous mogul became a contender for the presidency of the United States see more proceeded to run his campaign in the same way he had run his opaque business empire: in a haphazard manner, with little vetting of those executing the work.
The myth of a successful businessman Trump spent the 1990s and 2000s mired in bankruptcy, litigation, and debt.
These convergences resulted in mutually beneficial relationships, both circumstantial and deliberate, that Russia could exploit decades down the line.
With the subjugation of its oligarchy, the line between private and public wealth in Russia is often blurry.
Trump cannot be considered financially stable.
These catastrophic losses persisted into the following decade, with two additional bankruptcies in 2004 and 2009.
Perhaps as a mea culpa gesture, Trump resigned as chairman of Trump Entertainment Resorts that year.
As the country transitioned, a handful of Russian financial buccaneers made vast fortunes virtually overnight, most notably through the loans-for-shares program and other means of buying up state assets, including gas and oil conglomerates, for a fraction of their value.
Thus emerged the oligarch class.
Despite this quasi-private wealth creation, Russia itself remained volatile, often teetering on the edge of bankruptcy and political calamity.
It was also ravaged by organized crime.
The loans-for-shares program was the principal method by which many of the formerly state-owned corporations were privatized after the fall of Soviet Union.
After the fall of the Soviet Union, it was vital to get the money out of Russia without a trace, stashing it away from the prying eyes of tax agencies or law enforcement.
Clandestine transfer was particularly critical if that money represented proceeds of a crime.
Foreign real estate soon emerged as a preferred safe harbor.
While many analysts have observed and examined the apparent magnetic appeal of Trump real estate to the Russian consumer, it is important to dwell on a key theme that emerged from this period.
Despite the crash, he continued to break ground on multiple ambitious projects, both domestically and abroad, projecting to the world that he was resistant to the forces that brought down Wall Street titans.
In actuality, the domestic and international licensing deals Trump signed swedish gambling address the crisis reveal the depth of his financial troubles.
Despite the at-times deliberate conflation in its marketing materials, the Trump Organization was no longer building, developing, or investing in property in Manhattan or elsewhere around the country.
First, the Trump Organization was continuing to see an influx of Russian money through commission earned on the sale of individual units in Trump-branded properties as well as direct purchases of Trump-owned gambling and betting association estate.
Second, sustained interest from Russia and the former Soviet Union republics resulted in an explosion of foreign licensing deals.
This figure encompasses merely the units for which it was possible to determine the ultimate beneficial owners.
This property was purchased through an anonymous shell corporation, initially concealing the ultimate owner, but it was later reported and confirmed that the Russian oligarch was indeed the buyer.
The same trend of Russian money flowing into Trump-branded real estate continued elsewhere around the country, particularly in New York, where Trump licensed his name to a tower in SoHo.
Trump SoHo was reportedly financed and developed by the Bayrock Group hereafter Bayrocka company with shareholders and executives from the former Soviet Union, including Tevfik Arif and Felix Sater.
Though a degree of mutual affinity between Trump and Russian buyers already existed by the time Trump SoHo broke ground, there were nonetheless active marketing campaigns aimed at maintaining that connection.
A bank-to-bank transfer is normally involved, which would bring the transaction at least partially within the scope of the Bank Secrecy Act.
However, if the originating bank is located abroad, the potential for abuse is higher.
In addition to doing income checks, banks serve as a critical line of defense against money laundering.
In contrast to the real estate industry, banks and other lending institutions must abide by strict regulations and anti-money laundering AML reporting requirements, aimed at spotting and halting financial crimes.
We have all the funding we need out of Russia.
We just go there all the time.
In another instance of convergence, it is worth noting that golf—virtually nonexistent in Russia 20 years ago—recently has become a favorite pastime of some oligarchs, including Aras and Emin Agalarov, Oleg Deripaska, and Roman Abramovich, all of whom have built luxurious courses in Russia.
Moreover, Global Witness, a nonprofit organization that aims to expose corruption, recently investigated large-scale money laundering allegedly conducted through the Trump Ocean Club in Panama and found that Russian-speaking real estate brokers worked for the property developers and specifically targeted Eastern Europeans, both in Panama and abroad, as potential buyers.
To fully appreciate the stark shift, recall that, prior to the Great Recession, Trump built his business empire domestically and rarely ventured abroad.
Though he had pursued deals in other countries, particularly in Russia, since the late 1980s, few, if any, materialized, in part because of the additional risks of international developments.
During a real estate conference in September 2008, Donald Trump, Jr.
As much as we want to take our business there, Russia is just a different world.
Though the legal structure is in place for what we have today, and even 99 percent is covered, that 1 percent not covered could be 100 percent over there because it is a question of who knows who, whose brother is paying off who, etc.
And yet, in the months and years following this statement, the Trump Organization leapt into deals in countries such Azerbaijan, Georgia, and Kazakhstan, which international transparency organizations consider just as corrupt as Russia.
Many of the licensing projects mentioned in this report—including those in New York; Fort Lauderdale, Florida; Phoenix; Toronto; and Panama City —ultimately ended up in receiverships or subjects of investor lawsuits.
The limited liability intrinsic to a licensing arrangement has arguably allowed Trump to absolve himself and the Trump Organization of responsibility and challenge in court.
Licensing arrangements have proven a reliable vehicle to profit handsomely, even off of projects in which other partners lost money.
These arrangements have also proven reliable when distancing the Trump Organization and its owner from controversy.
In effect, the licensing arrangement became a license to look the other way.
There was a flurry of activity on all post-Soviet fronts, which the truncated timeline below illustrates.
Petersburg starring a Russian mixed martial arts fighter, Fedor Emelianenko.
The Trump Organization signed multiple contracts with the Azerbaijani developers behind the Trump International Hotel and Tower Baku.
On the same trip, Trump reportedly met with Alex Sapir and Rotem Rosen, his partners in Trump SoHo, to discuss other opportunities in Moscow.
Needless to say, most of the above pursuits were licensing deals, meaning Trump did not have to come up with financing to launch them.
The Wall Street banks who have shunned Trump in Manhattan could hardly be expected to follow him to Baku.
Given the regional economic volatility as well as corruption concerns, underwriting loans for such projects would have been too much of a risk.
The sanctions, rolled out by the Obama administration in several tranches, are far-reaching and have had a chilling effect on the Russian economy.
Moreover, because the Office of Foreign Assets Control OFAC sanctioned major Russian banks like Sberbank, Gazprombank, Vnesheconombank VEBand Vneshtorgbank VTBmovement of money has generally been adversely impacted.
As an example, consider the meeting Jared Kushner had with the head of VEB, Sergey Gorkov.
Recently, private banks in Russia have found themselves targets of a concerted government restructuring effort, with the aim of nationalizing the Russian financial sector.
The push reportedly stems from the downturn in the Russian economy, caused by U.
Aras and Emin Agalarov, an ascendant oligarchic family, hosted the event.
The Miss Universe trip has become significant to the collusion probes both because of the allegations made in the Steele dossier and the subsequent reemergence of the Agalarovs as the reported conduits for conveying damaging information on Hillary Clinton from the Russian government to the Trump campaign.
As reported in The New York Times, Rob Goldstone, a publicist working with Emin Agalarov, go here the following to Donald Trump, Jr.
The Crown prosecutor of Russia met with his father Aras this morning and in their meeting offered to provide the Trump campaign with some click to see more documents and information that would incriminate Hillary and her dealings with Russia would be very useful to your father.
Trump—helped along by Aras and Emin.
The anatomy of this brief exchange—with Donald Trump, Jr.
However, one can hardly expect a Putin deputy to show up at such a meeting, or to attempt to set one up.
Maintaining plausible deniability requires russian gambling ring busted california of opportune, often low-profile, middlemen, activated to complete discrete tasks.
Even the Agalarovs, albeit more prominent, can be considered convenient intermediaries.
However casual, the nexus was already there.
Several months of planning the Miss Universe pageant, followed by a few days of close interactions in Moscow, including discussions of building a tower together, were sufficient to cement a relationship.
This relationship was later activated with the stated intent to influence the 2016 presidential campaign.
In dissecting this trip and its implications, it is important to understand that the same scenario could have played out on numerous other occasions.
Intimate gambling vs market and relationship building accompanied each deal signing, ground breaking, or ribbon cutting ceremony.
Notably, the economic category contained the most examples, including the following: shady bank deals; offshore activity and capital flight; holding of foreign bank accounts; involvement in illegal financial schemes; inappropriate or illegal election campaign financing; preferential treatment in business deals and contracts; giving or accepting of bribes; or illegitimate income or fees received.
Even as late as 2011 and 2012, when Trump was busy chasing deals in the former Soviet states, the private sector in these regions was underdeveloped and inextricably linked to the government.
It was thus not surprising to see ministers, government officials, and heads of state such as the former President of Georgia Mikheil Saakashvili attend events with Trump.
In contrast, one could hardly imagine Angela Merkel gleefully heaping shovels of dirt alongside Trump, had someone in Germany decided to build a Trump tower.
A number of these interactions, both ceremonial and operational, occurred through preexisting state-cum-private channels, with the same individuals emerging as brokers across projects and countries.
These business events then proved a natural setting in which to schmooze with, and possibly be compromised by, bureaucrats and representatives of government structures or state-owned corporations—apparatchiks—of various sorts.
Many of the elements and themes considered thus far converge in the figure of Felix Sater.
Felix Sater: A study in fluid shifts between business and politics Felix Sater is perhaps the best embodiment of the blurred line between the realms of business and politics in the Trump orbit.
A longtime business associate of Donald Trump, Sater has emerged multiple times in the context of the More info probes, most recently in December 2017, when it was reported that the House Intelligence Committee sought to interview him as part of its investigation.
On November 3, 2015, Sater wrote: Michael I arranged for Ivanka to sit in Putins private chair at his desk and office in the Kremlin.
I will get Putin on this speaking, singapore problem gambling germany indeed and we will get Donald elected.
Buddy our boy can become President of the USA and we can engineer it.
I will get all of Putins team to buy in apologise, gambling statistics us 2020 think this.
According to his discussions with Cohen, the tower in Moscow was meant to help Trump win.
This endeavor, in a time of chilled relations brought on by Russian aggression in eastern Ukraine and subsequent sanctions, was no small feat.
In his efforts to secure the deal, Sater was eager to show his Russian contacts clips of Trump praising Russia.
There was no shortage of these.
He does his work well.
Much better than our Bush.
Notably, VTB, the bank that Sater had supposedly lined up to provide the latter, has been subject to U.
Peskov has confirmed he received the email but says he did not respond.
Cohen has also confirmed that he had discussed this deal with Trump three times.
Though the above pursuit ultimately did not materialize, Sater, who first began working with Trump in 1999, remained relentless.
In February 2017, Sater once again teamed up with Cohen, this time in an attempt to establish a backchannel discussion between then-National Security Adviser Michael Flynn and Andrii Artemenko, a pro-Kremlin Ukrainian politician.
Through Cohen and Sater, Artemenko wanted to convey a plan for easing the conflict with Russia in eastern Ukraine.
His plan hinged on the United States lifting the sanctions it had imposed on Russia in 2014.
A week after Cohen hand-delivered the sanctions-related proposal to Flynn, the latter resigned from office.
It is worth unpacking how Sater came within reach of the campaign and the transition team.
I reported to him on everything.
Sometimes twice a day, sometimes twice a week, sometimes twice a month.
And so on for ten years.
In 2005, Trump signed a one-year deal with Bayrock to find a suitable location in Moscow for a Trump-branded tower.
Beyond Russia, Sater and Tevfik Arif scouted deals for Trump in Ukraine, Poland, and Turkey, according to Russian media.
None of the deals abroad were realized, prompting some journalists to question whether Sater exaggerated his connections in Russia and elsewhere.
Though many of his deals have been unsuccessful, this does not take away from his role as a middleman and conduit between Trump and Russia.
Sater has shifted fluidly from real estate to the geopolitical realm, which supports the established argument that business deals are central to the ongoing Russian meddling investigations.
Sater symbolizes not only a link to Russia, demonstrating the interconnectedness established well before the presidential campaign, but also a mode of doing business.
To note a few parallels, both Trump and Sater have been accused of misrepresentation in the course of sales to potential investors; both have cultivated partnerships with questionable business associates; and both were named as parties to Racketeer Influenced and Corrupt Organizations Act RICO lawsuits.
Trump ultimately settled the lawsuits brought in relation to the sale of Trump SoHo units as well as the Trump University, admitting no wrongdoing in either case.
Sater, sued by a former business partner who claimed that Bayrock had committed fraud by concealing his criminal background, has also denied any wrongdoing.
As noted above, in December 2016, a judge in the case ruled that the case could proceed as a racketeering matter, according to the order.
This lawsuit is currently ongoing.
Trump has an established history of public fulmination about anti-corruption laws, specifically as they regard overseas business.
He has also payed multiple fines for violating anti-money laundering laws, and operates his business through a dense network of shell companies that is at least superficially similar to those used by known financial criminals to hide their fortunes.
In May 2012, he railed against the Foreign Corrupt Practices Act FCPA when asked to comment on the unfolding Tunica gambling casinos map Mexico graft scandal.
In fact, Kazakhstan, where Trump planned to build a tower in 2012, was perceived to be more corrupt than Mexico, according to the index.
As president, Trump has continued his crusade against the FCPA.
Already in debt, Trump could hardly embrace the risk of millions in fines assessed by the Securities and Exchange Commission SEC and the Department of Justice DOJwho have, since the mid-2000s, become more aggressive in implementing the law.
To date no FCPA tax revenue uk charges have been brought against the Trump Organization and related entities.
However, there have arguably been enough red flags to warrant serious scrutiny on the part of the regulators.
Adam Davidson of The New Yorker has written effectively on this topic, studying several suspicious foreign deals.
The FCPA prosecutes bribery of foreign officials with the intent of securing or facilitating business; since Trump has merely licensed his name to local partners, one could argue that he has preemptively removed himself from any such scenario.
In recent years enforcement actions have targeted many different types of players in the real estate sector, including property managers, a role the Trump Organization has often played in conjunction with licensing the Trump name to foreign buildings.
In the context of the FCPA, even if the Trump Organization had contracted a local third-party to help with inspections and licensing, and that third-party had committed bribery, a violation of the FCPA might have taken place.
The ubiquitous issue of money laundering Perhaps more so than with corruption, the real estate industry has long been associated with money laundering.
Though neither Trump nor the Trump Organization have ever been sued or indicted on charges of money laundering through real estate, investigative journalists have documented many instances in which Trump-owned and branded properties have allegedly been used to launder money.
Khrapunov has reportedly worked on several deals with Felix Sater, who, in January 2018, was subpoenaed for information as part of the ongoing money laundering lawsuit in the Southern District of New York.
The plaintiffs in the lawsuit against Khrapunov are the Kazakh BTA Bank and the City of Almaty.
Sater is not party to the lawsuit and has denied any wrongdoing, as has Khrapunov.
These allegations have been fleshed out in several U.
If true, that would have been illegal, as Michael Zeldin, a legal expert, explained: Under criminal money laundering statues, it is a crime for any person to engage knowingly in a financial transaction with knowledge that the transaction involves gambling organisations uk proceeds of criminal activity.
The courts have interpreted knowledge to include actual knowledge and willful blindness—deliberately avoiding gaining knowledge when faced with a high likelihood of criminal activity, i.
In other words, the task before the plaintiffs, investigators, and prosecutors has been two-fold: to prove that Bayrock had engaged in criminal activity and that Trump knew this and looked the other way.
Both Bayrock and Trump have denied any wrongdoing or knowledge thereof.
The lawsuit Kriss filed against Bayrock, Sater, and others in May 2010 is currently ongoing in the U.
District for the Southern District of New York.
In December 2016, a judge in the https://veronsmeatmarket.com/gambling/gambling-took-over-my-life.html ruled that the case could proceed as a racketeering RICO matter, according to the order.
Money laundering is rarely prosecuted in isolation and is typically linked to an underlying crime, such as drug trafficking or illegal gambling.
In one instance in April 2013, federal agents raided an apartment at Trump Tower in New York City as part of a larger round up of nearly 30 suspected members of two global gambling rings, allegedly run by Alimzhan Tokhtakhounov.
­­­ In April 2014, two U.
Twenty-eight defendants in this case pled guilty and two entered into deferred prosecution agreements.
In 2014, the FBI described Tokhtakhounov as a fugitive who was still being sought.
There have been other allegations of criminals using Trump properties to clean illicit money.
It does, however, add to a pattern that is more difficult to dismiss on the basis of ignorance.
Although Trump has not faced criminal money laundering charges related to his real estate empire, his casino businesses have incurred multiple record fines.
Money laundering as a sign of system vulnerabilities A discussion of certain endemic vulnerabilities that allow for widespread money laundering in the United States is also one of the ways that a foreign actor can penetrate and undermine a local system from within, be it by abetting organized crime or, more subtly, by covertly funding political campaigns and grassroots movements.
Some purists may argue that funding campaigns rarely falls within the definition of money laundering, as enforcement of the principal anti-money laundering laws in the United States, including the Bank Secrecy Act, is typically tethered to concrete crimes: One either launders money to clean the proceeds of a crime or to perpetrate a subsequent crime, as in terrorist financing.
In this report, however, the discussion of money laundering also encompasses the process by which actors obfuscate the problematic provenance and ultimate destination of their funds.
After all, in light of U.
Real estate transactions are often used in both layering and integration, the final phase of money laundering.
A money launderer, for instance, may purchase a property using one anonymous shell corporation then sell it to other corporations he or she controls at successively higher prices, thereby creating a chain of sales of escalating value.
Additionally, many countries, including the United States, do not require extensive due diligence for purchases made through brokers or allow for purchases without the buyer needing to be physically present in the country of the property.
Because of these oversights, and because commercial real estate provides both a store of value and appreciation, money launderers often invest in real estate to integrate money once it has been sufficiently layered.
The three stages of money laundering are placement, layering, and integration.
Placement refers to the process by which the individual or organization introduces illicit money into the legitimate economy.
According to the international watchdog organization the Financial Action Task Force FATFthis first step often involves breaking up large amounts of illegally-obtained cash into smaller, less conspicuous amounts, which are then deposited directly into bank accounts or converted into monetary instruments such as article source or money orders.
Once the money has been deposited into the economy, an individual layers the money through repeated transactions, establishing a paper trail that creates the appearance that the money was obtained legitimately through investments in real estate, gambling, or payments for goods and services.
One common method for doing so is by creating anonymous shell corporations, which allow people to do business without disclosing the identities of the ultimate beneficial owners.
The money launderer may pass the money through multiple bank accounts or shell corporations, thus further obfuscating its origins.
Real estate is often involved in both layering and the final phase of money laundering, integration.
At this stage, the funds re-enter the legitimate economy through more transparent purchases of assets.
To see how real estate investments can be abused for purposes of money laundering, it is critical to deconstruct these transactions further and look at shell companies specifically.
The ills of shell companies, or how to hide the money trail Discussions of Russian money and Trump frequently run into a wall, namely, anonymous shell companies.
For the same reason, any assessments of Trump and potential issues of money laundering or corruption have typically been couched in mountains of legal disclaimers about the tenuousness of the connections drawn, nature of the relationships, knowledge of the activities, and so on.
One argument that can be made unequivocally, however, is that Trump and financial miscreants share a strong affinity for shell companies.
In perpetuating the myth of Trump as a successful businessman during the campaign, his proponents have pointed to the fact that he owns more than 500 companies.
In reality, the vast majority of these companies are shells, meaning they are not bona fide companies with operations and revenue but only exist on paper and serve the purpose of layering ownership of assets and entities.
A typical shell company may have a number of owners, partners or shareholders, depending upon whether it is organized as a corporation or a partnership.
These owners, continue reading, or shareholders may be located in different U.
In addition, shell companies structured as partnerships and their close cousin, limited liability companies LLCswhich are treated like partnerships in the U.
That is, the partners in one LLC may https://veronsmeatmarket.com/gambling/gambling-winner.html of other individuals, partnerships, LLCs, or even C corporations.
These complex ownership structures—while in and of themselves not illegal—can be used to evade taxes and facilitate financial crimes, including sanctions evasion, bribery, or, as the Panama Trump Ocean Club case study has illustrated, potential laundering of drug money.
Even though, prior to January 2017, Trump was based in New York, three-fourths of his companies are registered in Delaware, a state with among the least stringent transparency requirements in the country, where many international criminals come to launder and hide their assets.
This has allowed alleged kleptocrats such as former President of Ukraine Viktor Yanukovych to hide billions of dollars obtained through bribery schemes and abuse of power.
Several layers of shell companies allowed Ross to obscure the fact that he was financially benefiting from business with a company that is an appendage of the Russian government with significant exposure to U.
As news of foreign intrusions in elections and referendums mounts and investigations unfold, it is critical to remember that shell companies also obfuscate the sources of funds, making it easy for outside state actors to make anonymous financial contributions to domestic campaigns.
Campaign finance laws can be enforced only in so far as there is transparency.
Shell companies do away with it.
To understand how billions of dollars can secretly snake into the U.
Well before he met Paul Manafort, Jared Kushner, and Donald Trump Jr.
Kaveladze has denied any wrongdoing.
In October 2000, following a lengthy investigation commissioned by Sen.
Carl Levin D-MIthe General Accounting Office GAO released a report detailing how Kaveladze had worked as an intermediary to incorporate 2,000 shell companies in Delaware on behalf of anonymous Russian brokers.
He was then able to set up U.
In recent years, the USA Patriot Act and other enactments have strengthened the anti-money laundering regime in the United States.
Presumably, had this rule been in place when Kaveladze opened bank accounts using the Delaware entities he created, the banks would have had to confirm the ultimate beneficiaries behind each of these companies used to set up the accounts.
Covered financial institutions are required to comply with this rule by May 2018.
The efficacy of its implementation and enforcement remains to be seen.
The Kaveladze example also illustrates that evaluating intermediaries is important not only from the standpoint of the physical meetings they can broker, but also the transactions and financial pathways they can structure.
While typically low-profile, intermediaries can also be prominent operators on the geopolitical stage, as Paul Manafort the former Trump campaign chairman demonstrates.
His public ridicule of anti-corruption norms and seeming indifference to the sources of money flowing into his properties could have emboldened meddling attempts.
This is a dramatic range that points to a problem of opacity and lack of accountability.
While such ranges in estimates of net worth may be common with other wealthy individuals, none of them hold the highest office in the country.
The president and other politicians who represent interests of the electorate, ought to be held to a higher standard of transparency to avoid conflicts of interest.
What is the source of the unaccounted wealth?
Speculation is all the public can do as long as Trump refuses to embrace a more transparent mode of operation and release his tax documents, as other public servants have done.
This, in turn, reinforces the need to take proactive steps to better enhance financial crime, economic and trade sanctions, and anti-corruption efforts as a step toward preventing future incursions.
The following recommendations urge policymakers and relevant law enforcement agencies to crack down on money laundering and corruption, thereby mitigating future attempts at interference in American democracy.
Curb abuse of shell companies by requiring greater transparency Congress should pass legislation like the Corporate Transparency Act and the TITLE Act On a federal level, Congress should take concrete steps to curb abuse of shell companies for illicit ends by setting a regulatory floor for minimum disclosure requirements.
These should include accurate reporting with respect to beneficial owners of corporations, or other legal business entities such as limited liability companies that are registered across states, including in more secrecy-prone jurisdictions such as Delaware, Wyoming, and Nevada.
The aim of the proposed transparency policy is to make reliable and up-to-date beneficial ownership information available to regulatory, tax, and other law enforcement authorities, but not to create a public beneficial ownership registry as has been proposed in the European Union.
In June 2017, Sen.
Sheldon Whitehouse D-RI introduced the TITLE Act, proposing greater transparency in how U.
Ron Wyden D-OR and Marco Rubio R-FL introduced bipartisan legislation, the Corporate Transparency Act of 2017, also to prevent individuals from using anonymous shell corporations to facilitate illicit activities.
Carolyn Maloney D-NY and Peter King R-NY introduced a companion bill in the House of Representatives.
Passing these bills will significantly aid the fight against financial crimes.
It is important to report the actual individuals exerting control over legal entities, and not merely nominees standing in for anonymous owners and directors.
One way to do this is to encourage and fund the digitization of foreign corporate registries, at the very least making them accessible to law enforcement.
At present, many country-specific registries are not accessible online and require physical retrieval of relevant records, a process logistics and bureaucratic customs often hinder.
States should improve Know Your Customer regulations At the state level, registered agents and attorneys incorporating legal entities should be regulated, licensed, and mandated to conduct due diligence on their clients.
These facilitators can play an important role in identifying anomalous activity and should be required to adhere to Know Your Customer KYC compliance standards similar to banks and financial institutions.
Combat money laundering in real estate through legislative and executive actions Congress and the Treasury Department should introduce policies aimed at curtailing systemic money laundering through anonymous purchases of domestic real estate The Financial Crimes Enforcement Network of the Treasury Department has already taken steps in the right direction with the introduction of the geographic targeting orders GTOs that have temporarily required U.
FinCEN should require the real estate industry to do due diligence on prospective clients FinCEN should expand its Customer Due Diligence CDD rule to include real estate brokers, real estate investment funds, title insurance companies, and escrow agents among the institutions required to conduct rudimentary and enhanced due diligence on the ultimate beneficiaries of their corporate clients.
The CDD was issued to amend the existing Bank Secrecy Act of 1970 regulations in order to strengthen customer vetting of financial institutions.
Congress should reform the Bank Secrecy Act BSA to cover the real estate industry In the longer term, Congress should amend the BSA and portions of the Money Laundering Control Act of 1986 to include real estate institutions and brokers among the designated financial institutions required to assist the government in detecting and preventing money laundering through instituted Anti-Money Laundering AML controls and reporting requirements.
However, soon after the introduction of these provisions, the Treasury Department temporarily exempted real estate actors from the requirements.
One proposed solution then is to repeal this exemption, which would promote greater transparency and bring the United States in line with the Financial Action Task Force FATF recommendations on real estate due diligence.
Fight global corruption with strong enforcement and economic incentives Congress should ensure strong enforcement of the Foreign Corrupt Practices Act FCPA It remains unknown how rigorously the Department of Justice and the Securities and Exchange Commission will enforce the FCPA under the current administration.
To preempt a reduction in investigation and enforcement, the relevant divisions of both agencies must be sufficiently staffed and funded.
Furthermore, the investigative powers of both agencies must not be hindered.
Congress should provide the United States Agency for International Development USAID with more resources earmarked for fighting corruption USAID should receive additional funding dedicated specifically to anti-corruption programs in vulnerable countries.
Moreover, it should have sufficient internal controls and oversight to ensure the allocated funds are not misappropriated and are used for the intended purposes upon reaching the recipient countries.
To this end, any foreign incorporated entity receiving funds to, for example, implement a program or advance a construction project, should be required to disclose its ultimate shareholders and executives.
Such transparency requirements ought to be the norm to identify and prevent corruption, conflicts of interest, and abuse of power.
The United States should support other countries to enforce anti-bribery norms The United States helped establish an international architecture to enforce anti-corruption norms across the globe; however, in practice, only a few countries, including the United Kingdom and Germany, have actively enforced these in recent years.
To root out corruption, the United States must continue to work with other countries to ensure their internal enforcement mechanisms are consistently implemented.
One incentive-based recommendation would be to include anti-corruption clauses in bilateral and multilateral trade agreements.
Address gaps in campaign finance disclosure regulations Congress should pass the DISCLOSE Act The corrupting potential of lenient reporting laws surrounding anonymous shell companies is only exacerbated by the lax disclosure laws related to campaign finance.
Passing the DISCLOSE Act of 2017 would enhance campaign finance transparency generally and expose and deter foreign influence in the U.
Among other requirements, the act would expand the timeframe during which broadcast ads that reference a candidate must be reported to the Federal Election Commission FEC —currently limited to the 60 days prior to a general election or the 30 days prior to a primary election.
The DISCLOSE Act would expand that time period to cover the entire calendar year in which the election takes place, so that candidate-related broadcast ads could not be funded anonymously.
Other provisions of the DISCLOSE Act crack down on the use of LLCs and anonymous organizations that donors may use to obscure their identities and the provenance of funds.
The DISCLOSE Act requires organizations that serve as conduits for large amounts of money to report information that can be used to help determine the original source of the funds.
The DISCLOSE Act also carefully defines the circumstances under which U.
The Honest Ads Act would close this serious gap, requiring those who purchase and publish online political advertisements to report those ads to the FEC and to include the same disclaimers that appear on other ads.
Furthermore, the Honest Ads Act would require social media companies to maintain a public file of political advertisements and to exercise reasonable diligence in preventing foreign nationals from purchasing campaign ads through their platforms.
This would undermine the ability of foreign governments to anonymously propagate online ads aimed at influencing U.
The FEC should vigorously enforce the law An equally important element of transparency in campaign finance is enforcement of laws and regulations.
A former chairwoman click here the FEC, Ann M.
Congress should appoint new FEC commissioners who are willing to enforce the law and to take measures necessary to prevent foreign influence in our elections.
Expose and resolve conflicts of interest and violations of the emoluments clauses Congress should enforce a greater separation between Trump and his businesses Two sections of the U.
Constitution, commonly known as the emoluments clauses, bar the president from receiving financial benefits or other things of value from representatives of foreign governments without the consent of Congress or from individual states at all.
Congress must take all necessary steps to prevent these abuses of power.
Congress should pass a law to require the president, vice president, and their families to either resolve their conflicts of interest by selling or otherwise divesting their assets or disclose them Current regulations exempt the president and vice president from the disclosure and divestiture requirements to which other executive-branch employees are held.
Congress should fix this oversight by passing a law requiring that the president, vice president, and their families resolve their conflicts of interest by selling or otherwise divesting their assets, or else clearly disclose any and all material conflicts.
Beyond the aforementioned consideration of the emoluments clauses, the present national discussion offers an opportunity to reexamine the financial disclosure requirements for other federal officials and ensure they are sufficiently strict and effective in exposing any possible conflicts of interest inherent to foreign and domestic commercial ventures.
What is more, the identified regulatory gaps can well be exploited by any foreign adversary to undermine future U.
Fortunately, by tackling illicit finance—which fuels and facilitates these operations—it is possible to stymie and counter any such aggression.
Confronting foreign aggression alone is not sufficient.
It is also critical to recognize the threat conflicts of interest and corruption can pose to democratic institutions and practices in the United States.
To this end, Congress must act to ensure that public officials disclose and divest any business interests that may undermine their decision-making in office.
Doing so will, in part, require turning longstanding norms into law, such as by mandating that candidates for high public office release their tax returns and by amending current law to no longer exempt the president and vice president from divestiture requirements.
About the author Diana Pilipenko is the associate director for anti-corruption and illicit finance at the Center for American Progress.
Prior to joining American Progress in June 2017, she managed corporate investigations and analysis at Deloitte, a Big Four accounting firm.
Specializing in anti-corruption, anti-money laundering, sanctions, and export controls compliance, see more led numerous investigations and assessments on behalf of commercial, federal, and nonprofit organizations.
Acknowledgments The author would like to thank the following for reading the earlier iterations of the report and providing comments and recommendations: Anders Aslund, Sam Berger, Max Bergmann, Andy Green, Seth Hanlon, Adam Jentleson, Liz Kennedy, James Lamond, Scott Nathan, Ben Olinsky, Grand age gambling newport casino Schmidt, Trevor Sutton, Alex Tausanovitch, Alex Thornton, and Michael Zeldin.
And she would especially like to thank her incredible research analysts, Talia Dessel and Jeremy Venook, as well as communications maven, Morgan Finkelstein.
Appendix: A select cast of characters Roman Abramovich Roman Abramovich is a Russian billionaire and reportedly a close ally of President Vladimir Putin.
He made his fortune in the Russian energy industry, eventually selling his stake in the oil firm Sibneft to Gazprom in 2005.
He retains stakes in major Russian steel companies.
From 2000 to 2008, he served as gambling against armageddon governor of the Russian region of Chukotka.
In a 2015 interview with Vedomosti, Agalarov said that Crocus had not taken any bank loans to finance the construction project; everything until that point has been financed by the state.
Emin Agalarov Emin Agalarov, the son of Aras Agalarov, is a Russian pop star who reportedly helped arrange the June 9 meeting in Trump Tower between Natalia Veselnitskaya and Donald Trump Jr.
Until 2015, he was married to Leyla Aliyeva, the daughter of the former president of Azerbaijan, Ilham Aliyev.
He once stated that he considered Trump to be his friend and that they saw each other several times a year.
Tevfik Arif Tevfik Arif is a Kazakh-born real estate developer and founder of the Bayrock Group.
He has extensive business ties to Russia and the former Soviet Union, where he worked for 17 years in the Ministry of Commerce and Trade.
Arif has repeatedly partnered with the Trump Organization, most notably alongside his business partner Felix Sater in the Trump SoHo development.
The Bayrock Group and the Trump Organization also reportedly sought spots in florida in Turkey, Poland, and Ukraine.
According to Malcolm Nance, the author of The Plot to Hack America, Arif helped connect Trump to Russian investors who, in turn, helped finance or purchased Trump Organization properties.
The charges against him were ultimately dropped; he has claimed they were politically motivated.
Chaika is a vocal critic of the Magnitsky Act, a U.
Bill Browder of Hermitage Capital, who alleged to have been victimized by the scheme, had hired Magnitsky as an auditor.
Chaika is linked to Natalia Veselnitskaya, the Russian lawyer who attended the June 9 meeting in Trump Tower.
Veselnitskaya purportedly brought a memo to this meeting containing anti-Magnitsky Act talking points, which were strikingly similar to ones given by Chaika to U.
Dana Rohrabacher R-CA during his April 2016 trip to Moscow.
Manafort has disputed these claims, and the lawsuit in New York—the most recent of the two—appears to be ongoing.
The status of the Cayman Islands lawsuit is unclear.
To date, there has been no evidence that Deripaska received or replied to this offer.
Sergey Gorkov Sergei Gorkov, also deemed close to the Kremlin, currently serves as the chairman of the U.
Treasury-sanctioned Vnesheconombank VEBa state-controlled bank.
He also appeared in pictures with Trump—along with Emin and Aras Agalarov—during the planning of the 2013 Miss Universe pageant in Las Vegas.
Khrapunov has done business with Felix Sater and the Bayrock Group.
He and other members of his family are defendants in civil lawsuits, filed against them in New York and Los Angeles, which allege that Khrapunov used his position to sell state-owned real estate to companies linked to his own family and that he laundered the money through U.
Both lawsuits appear to be ongoing, with Khrapunov maintaining his innocence in the matter.
As Russian ambassador, he personally met with Donald Trump and several Trump campaign officials, including former National Security Advisor Michael Flynn, former Trump campaign Foreign Policy Adviser Carter Page, Attorney General Jeff Sessions, former campaign Policy Adviser J.
These phone conversations ultimately led Flynn to first resign and later plead guilty to lying to the FBI.
According to The New York Times, Millian had reportedly contacted Papadopoulos in the summer of 2016, suggesting that they form an energy-related business backed by Russian russian gambling ring busted california />Peskov has confirmed that he received the email, but says he did not respond.
Sergei Polonsky Sergei Polonsky is a Russian real estate mogul and the founder of Mirax Group, a conglomerate Felix Sater joined as an executive in 2008.
In July 2017, Polonsky was convicted of fraud by a Moscow court.
Rotem Rosen Rotem Rosen is a real estate developer and the brother-in-law of Alex Sapir, head of the Sapir Organization.
Rosen worked with Sapir in attempting to develop a Trump Tower in Moscow in 2013, and both men reportedly accompanied Trump to Russia in 2013 for the Miss Universe pageant.
Giorgi Rtskhiladze Giorgi Rtskhiladze is a Georgian businessman who was involved in the failed Trump Tower Batumi project in Georgia.
Rtskhiladze reportedly facilitated a 2015 proposition for a Trump Moscow development from Russian billionaire Sergei Gordeev, which was turned down by Michael Cohen; he also proposed developing a Trump Tower in Astana, Kazakhstan, although this deal never materialized.
On February 9, 2018, Sen.
Secretary of Commerce Wilbur Ross once served as vice chairman.
Mikheil Saakashvili Mikheil Saakashvili is the former president of Georgia and the former governor of the Odessa region of Ukraine.
Saakashvili met with Trump on multiple occasions and took Trump on a tour of Georgia in 2012.
Capitol in the background.
Alex Sapir Alex Sapir—the son of Tamir Sapir—is a Georgian American real estate developer and the head of the Sapir Organization, a real estate company that partnered with the Trump Organization in the development of Trump SoHo and actively pursued a deal to develop a Trump Tower in Moscow in 2013.
Sapir also accompanied Trump to Moscow for the 2013 Miss Universe pageant, during which Sapir and his business partner Rotem Rosen reportedly attempted to finalize plans to develop a Trump Tower in Moscow.
Tamir Sapir Tamir Sapir, who passed away in August 2014, was a Georgian billionaire who co-founded the Sapir Organization—a real estate company that worked with the Trump Organization to build a Trump Tower in Moscow and develop Trump SoHo in Manhattan.
Sater has repeatedly declined to comment for articles related to allegations of his involvement in this matter.
Natalia Veselnitskaya Natalia Veselnitskaya is a Russian attorney who, along with Irakly Kaveladze and Rinat Akhmetshin, attended the June 9 meeting in Trump Tower.
She represented Cyprus-based Prevezon Holdings, a defendant in a civil asset forfeiture action filed by the U.
Department of Justice to resolve claims but admitting no wrongdoing.
Viktor Yanukovych Viktor Yanukovych is an ousted former Ukrainian president who employed Paul Manafort as a political adviser for almost a decade.
Yanukovych has been sanctioned by the U.
Goldman, Petrostate: Putin, Power, and the New Russia Oxford and New York: Oxford University Press, 2008.
Russia tycoons would rather ship themselves off shore.
Not every oligarch carries the same level of importance, nor do they all enjoy equal proximity to the Kremlin.
New York: Simon and Schuster, 2014.
Ledeneva, Can Russia Modernize?
Sistema, Power Networks and Informal Governance Cambridge, England: Cambridge University Press, 2013.
His case appears to be ongoing.
In December 2017, he was found guilty of bribery and sentenced in a Moscow court to eight years in prison and a 130 million ruble fine.
Igor Sechin, head of Rosneft and close Putin ally, led the charge against Ulyukayev, who has denied the allegations, claiming he is being framed.
Goldman, The Piratization of Russia: Russian Reform Goes Awry New Continue reading Routledge, 2003.
The term has been heavily politicized, as Russian influence—and interference—in the former Soviet republics of Georgia and Ukraine has become increasingly overt.
New York: Simon and Schuster, 2014.
New York: Simon and Schuster, 2014.
Department of the Treasury, Money Laundering in the Commercial Real Estate Industry, Financial Crimes Enforcement Network, 2006available at.
House of Representatives, Washington, D.
Bullish on Russia and Few Emerging Markets.
BayRock Group LLC et al, U.
District Court for the Southern District of New York 1:10-cv-03959originally filed on May 10, 2010.
They prosecute people for going over to China and Mexico and other countries and getting business and creating jobs in this country, because we do make some product that goes out, but I see them prosecuting all the time.
Let Mexico or let China or let these other countries prosecute.
What, are we prosecuting people to keep China honest now?
Every other country goes into these places and they do what they have to do.
The world is laughing at us, for this country to prosecute because something took place in India is outrageous.
Mukhtar Ablyazov, et al.
District Court for the Southern District of New York 1:15-cv-05345originally filed on July 9, please click for source />BayRock Group LLC et al, U.
District Court for the Southern District of New York 1:10-cv-03959originally filed on May 10, 2010.
The mirror trading scheme relied on anonymous offshore shell companies, thus obscuring the orchestrators and the beneficiaries of these transactions.
§ 30104 f 3.
National Security, January 10, 2018, available at.
District Court for the Southern District of New York, Opinion and order signed on May 10, 2017, available at. russian gambling ring busted california russian gambling ring busted california russian gambling ring busted california russian gambling ring busted california russian gambling ring busted california russian gambling ring busted california

How Chinese gangs are laundering drug money through real estate around the world



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The gambling ring which was busted in 2016 was said to be running 70% of all illegal.. Russian police would bombard the illegal rings brandishing. 58 – were based across New York state and California and employed an.
We also were first to reveal that alleged Russian mobsters played in. account in California “in connection with operating an illegal poker. York — played in the busted Hollywood poker ring previously linked to a. One of Bloom's other co-conspirators in the poker ring is Eugene Trincher, Illya's brother.
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