Bloomberg published an article today entitled, “Behind Trump’s Russia Romance, There’s a Tower Full of Oligarchs.”  It seeks to provide an explanation for Donald Trump’s friendly attitude toward Russia.  It provides evidence the answer is that Russians buy a lot Donald Trump’s apartments and they do it with money that is often dirty.

The Bloomberg article just begins to pull the curtain on this story.  This essay attempts to bring together the investigative reporting from several different sources.  What we find is that the relationship between Trump’s businesses and money laundering goes back to the 1980’s.  This relationship helps us understand why the Russians would be interested in helping Trump get elected.

Who Buys Apartments in the Trump Towers?
The Bloomberg article begins,

On the 78th floor: a Russian who once was accused of mob ties and extortion by an oligarch. On the 79th, an Uzbek jeweler investigated for money laundering who was eventually executed on the street in Manhattan. And four floors higher, a pro-Moscow Ukrainian politician whose party hired a Donald Trump adviser.

When Trump World Tower at 845 United Nations Plaza began construction two decades ago as the tallest residential building in the country (90 stories), its most expensive floors attracted wealthy people getting their money out of what had been the Soviet Union. Trump needed the big spenders. He was renegotiating $1.8 billion in junk bonds for his Atlantic City resorts, and the tower was built on a mountain of debt owed to German banks. As Trump wrote in The Art of the Comeback, “It crushed my ego, my pride, to go hat in hand to the bankers.”

Trump’s soft spot for Russia is an ongoing mystery, and the large number of condominium sales he made to people with ties to former Soviet republics may offer clues. “We had big buyers from Russia and Ukraine and Kazakhstan,” says Debra Stotts, a sales agent who filled up the tower. The very top floors went unsold for years, but a third of units sold on floors 76 through 83 by 2004 involved people or limited liability companies connected to Russia and neighboring states, a Bloomberg investigation shows. The reporting involved more than two dozen interviews and a review of hundreds of public records filed in New York.

The article describes one specific case that raised suspicions of money laundering:  The case of Eduard Nektalov.

Eduard Nektalov, an Uzbekistan-born diamond dealer, purchased a 79th-floor unit directly below (Kellyanne) Conway’s for $1.6 million in July 2003. He was being investigated by federal agents for a money-laundering scheme, which involved smelting gold to make it appear like everyday objects that were then hauled to drug cartels in Colombia. Nektalov sold his unit a month after he bought it for a $500,000 profit. Less than a year later, Nektalov, rumored to have been cooperating with authorities, was gunned down on Manhattan’s Sixth Avenue.

The Miami Herald published a great article last October.  It provides a breakdown of who or what owns the apartments in the Trump Towers.  It turns out that 62% of his units are owned by “shell companies” that do not disclose ownership.  This makes it easy to launder dirty money.

Money Laundering Investigations and Fines
An article Time magazine published on August 15th on Trump’s ties to Russia is taking on a whole new significance now that Trump won the election.[i] Jeff Nesbit wrote the article. He is the former communications director to the former Vice President Dan Quayle (R-IN) while he was in the White House.

Nesbit notes that Trump states, “For the record, I have ZERO investments in Russia.”[i] In Trump’s first press conference as president-elect, he stated he has “no Russian loans.” Any time Trump tells the truth about an important issue in a flagrant fashion like this, we might be suspicious. Nesbit writes “Tax evasion and money-laundering are the core of Bayrock’s business model” and “(Trump) didn’t just partner with Bayrock; the company embedded with him.” You do not need to invest in Russia or borrow money from Russians to launder dirty Russian money.

On March 6^th, 2015 The Financial Crimes Enforcement Network (FinCEN) imposed a $10,000,000 civil penalty against Trump Raj Mahal Casino Resort for significant and long-standing anti-money laundering violations.[ii] In 1988 the U. S. attorney’s office opened an investigation in to Trump for laundering the money of Robert Hopkins, the head of Atlantic City’s largest gambling ring.[iii] Hopkins was connected to the mob. Trump attended the closing of the sale himself. Hopkins came with a briefcase loaded with $200,000 in cash for a deposit.

Wayne Barret of the New York Daily News explains how things proceeded from there,

     The government subsequently nailed Hopkins’ mortgage broker, Frank LaMagra, on an unrelated charge and he offered to give up Donald, claiming Trump “participated” in the money-laundering – and volunteering to wear a wire on him.

Instead, Lombardi [federal agent], who discussed the case with Giuliani personally (and with me for a 1993 Village Voice piece called “The Case of the Missing Case”), went straight to Donald for two hour-long interviews with him. Within weeks of the interviews, Donald announced he’d raise $2 million in a half hour if Rudy ran for mayor. Lamagra got no deal and was convicted, as was his mob associate, Louis (Louie HaHa) Attanasio, who was later also nailed for seven underworld murders. Hopkins was convicted or running his gambling operation partly out of the Trump Tower apartment, where he was arrested.[iv]

From 1988 to the present, Trump businesses have been associated with money laundering.

This relationship between Trump and money laundering is hinted at in a report done by Brian Ross’s investigative team on ABC News in September.[v] It is developed in more detail in an article in the Financial Times.[vi] While he tweets about having no investments in Russia and he talks about having no Russian loans, Trump does acknowledge, “Will I sell condos to Russians on occasion? Probably. I mean I do that. I have a lot of condos. I do that. But I have no relationship to Russia whatsoever.”[vii] ABC News reports,

“The level of business amounts to hundreds of millions of dollars — what he received as a result of interaction with Russian businessmen,” said Sergei Millian, who heads a U.S.-Russia business group and who says he once helped market Trump’s U.S. condos in Russia and the former Soviet states. “They were happy to invest with him, and they were happy to work with Donald Trump. And they were happy to associate—[and] be associated with Donald Trump.[viii]

ABC News reviewed hundreds of pages of property records and found that “Trump-branded developments catered to large numbers of Russian buyers.”

     At the same time, wealthy Russians accounted for significant profits at Trump projects in the U.S.. Throughout the 2000s, records show Russians were buying into Trump branded real estate.

…This was most notable at the Trump licensed condo towers in Hollywood and Sunny Isles, Florida. Local real estate agents credited the Russian migration for turning the coastal Miami community into what they called “Little Moscow.”

ABC News describes how Trump met with a group of Russian journalists at his New York office to help boost interest in the Trump Soho project.

     Eric Trump and Donald Jr. were also present, and were quoted praising the importance of Russian condo buyers, many of whom have purchased units in Trump buildings in seven-figure, cash-only deals.

“As the experience of the past few years shows, the best property buyers now are Russian,” Eric Trump is quoted as saying. “They’re different in that they can go around without a mortgage loan from American banks, that require income checks and they can buy apartments with cash.”

This ability of Russians to invest in high-end real estate increased in the 1990’s. The Christian Science Monitor reported in 1995 that the Russian mafia was expanding into new areas and it was using the US to launder dirty money.^[ix] In the early 2000s Russian started to accrue wealth and began looking for places to invest their money.

The Trump brand has a particular appeal to Russians apparently. The ABC News report described it as being associated with Luxury.

Daniel Pansky, a Florida broker who specializes in Russian buyers, said the Trump branded was uniquely suited to Russian buyers, who equated his name with luxury. As sales piled up, “Sunny Isles developed into a Little Moscow,” he said. “A lot of local dry cleaners, restaurants, stores having menus and signs in Russian.”

The ABC News report does not mention the Treasury Department concluded in 2015 the Trump Taj Mahal Casino Resort had engaged in “significant and long-standing anti-money laundering violations.” It does not mention “money laundering”; it just quotes Eric Trump saying Russians can buy apartments “with cash.”

Financial Times Investigation
The Financial Times published an article October 19^th entitled, “Dirty Money: Trump and the Kazakh connection. FT probe finds evidence a Trump venture has links to alleged laundering network.”[x] The article states,

A Financial Times investigation has found evidence that one Trump venture has multiple ties to an alleged international money-laundering network. Title deeds, bank records and correspondence show that a Kazakh family accused of laundering hundreds of millions of stolen dollars bought luxury apartments in a Manhattan tower part-owned by Mr. Trump and embarked on major business ventures with one of the tycoon’s partners.

The article reports the Director of the US Financial Crimes Enforcement Network warned in January “corrupt foreign officials, or transnational criminals, may be using premium US real estate to secretly invest millions in dirty money.”

The article focuses on one particular case of money laundering involving the family of Viktor Khrapunov.

     Now the details of Bayrock’s association with the family of Viktor Khrapunov, a former Kazakh energy minister and ex-mayor of the city of Almaty, show it was connected to an alleged laundering scheme at the same time as it was collaborating with Mr. Trump.

Lawyers for Almaty told a US court in March that Mr. Khrapunov and his family “conspired to systematically loot hundreds of millions of dollars of public assets . . . and to launder their ill-gotten gains through a complex web of bank accounts and shell companies . . . particularly in the United States”.

…Among the dozens of companies the Almaty lawyers say the Khrapunov laundering network used were three called Soho 3310, Soho 3311 and Soho 3203. Each was a limited liability company, meaning their ownership could easily be concealed.

These companies were created in New York in April 2013.   A week after they were created, property records show these companies paid $3.1 million to buy the apartments that correspond with their names in the Trump Soho, a luxury hotel-condominium complex in Manhattan.

The Financial Times article provides an interesting graphic that depicts how the money laundering scheme worked.

The scheme was setup to benefit Mr. Khrapunov’s daughter, Elvira Kudryashova. According to the Kazakh government, she and her brother are key links to the family’s laundering network.   The Financial Times reports,

Shortly before the Soho companies bought the apartments, more than $3.1m flowed out of Ms. Kudryashova’s Wells Fargo account to the firm of Martin Jajan, a New York lawyer. Mr. Jajan proceeded to sign purchase documents for the Trump Soho apartments as buyer’s agent. Other bank records show further links between Ms. Kudryashova and her relatives and the Soho shell companies. Mr. Jajan did not respond to a request for comment.

The Financial Times article demonstrates how through sales like this money that is acquired through illegal means can be made clean.

The article notes the Trump Soho is an early example of a building that bore the Trump name but was built by someone else. The partners in Bayrock were prepared to pay to license his name. Trump Soho was just the beginning.

     As work on Trump Soho got under way in 2007, the partnership between Mr. Trump and Bayrock was gathering momentum. Another tower, in Fort Lauderdale, was rising. A 2008 Bayrock presentation includes a picture of Mr. Trump grinning beside Mr. Arif and names him as a referee. Bayrock had its office on the 24th floor of Trump Tower and calls the Trump Organization a “strategic partner”.

The same presentation says Bayrock was one of the backers of the redevelopment of the 101-year-old Hotel du Parc on the shores of Lake Geneva, owned by Swiss Development Group, a Geneva-based company. In May this year, Nicolas Bourg, a Belgian businessman who says he worked with Viktor Khrapunov’s son Ilyas on US real estate deals, claimed in a separate dispute that Swiss Development Group was “owned and controlled by Ilyas and his family and used to conceal the movement and investment of his family’s money”.

Trump and Bayrock were both associated with money laundering before they began working together. The projects they have worked on together have all involved luxury real estate.

The Financial Times article describes how the laws regulating real estate leave room for a lot of questionable activity.

     The laws regulating US real estate deals are scant, experts say. Provisions against terrorism financing in the Patriot Act, passed in the aftermath of the September 11 2001 attacks, obliged mortgage lenders to conduct “know your customer” research. But money launderers pay in cash. Sales such as those of the Trump Soho apartments have passed through this loophole, which was partially closed only this year.

In January, the US launched a pilot programme designed to identify the ultimate owners of shell companies used to buy premium property in Manhattan and Miami. In July officials reported that the new rules had corroborated concerns that “all-cash luxury purchases of residential property by a legal entity are highly vulnerable to abuse for money laundering”.

The ability to pay in cash obviously makes purchasing real estate an appealing way to launder money. Luxury real estate also has a value that is largely arbitrary. Is this apartment in the Trump Soho worth $2 million or 3$ million? If one LLC with undisclosed ownership is paying another LLC with undisclosed ownership, they can set the price they want. The arbitrary nature of the value of luxury real estate provides a great deal of latitude for those attempting to launder large amounts of dirty money. High-end real estate is also a more efficient way to launder large amounts of dirty money. Purchasing one Trump Soho apartment for $3.1 million provides less exposure than purchasing five different less expensive homes.

Trump and Bayrock are meeting a demand. There is dirty money all around the world. The PBS News Hour reported in June of 2016,

     WASHINGTON — Six months before he entered the presidential race, Donald Trump announced a new real estate project in Baku, Azerbaijan. His partner was the son of a government minister suspected by U.S. diplomats of laundering money for Iran’s military and described as “notoriously corrupt.”

Eighteen months later, and only weeks after daughter Ivanka Trump released a publicity video of the nearly finished project, references to the Baku project have disappeared from Trump’s website. Trump’s general counsel, Alan Garten, told The Associated Press that it was on hold for economic reasons.[xi]

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

When you take a look at the history of Trump’s businesses practices there is a recurring theme: his association with money laundering.

In fact, the evidence suggests running successful casino or hotel/condominium enterprises for investors has never been Trump’s core business. The stocks for Trump businesses have been a terrible investment: he is described as a “stock market disaster.”[xii] His businesses have however successfully provided unprecedented opportunities for people around the world to launder dirty money. The fine the Trump Taj Mahal received for “substantial and long standing” money laundering violations was the largest ever levied against a casino.[xiii] This is where Trump has distinguished himself. Perhaps those who view Trump as a failed businessman simply do not understand his core business.

The concerns about Trump’s involvement with money laundering were given an exclamation point with his appointment of Wilbur Ross to be Commerce Secretary.  The National Memo notes that Ross served as the Vice Chair and leading investor in the Bank of Cyprus,

the largest bank in Cyprus, one of the key offshore havens for illicit Russian finance. Ross has been Vice Chairman of this bank and a  major investor in it since 2014. His fellow bank co-chair evidently was appointed by none other than Vladimir Putin…since the 1990s Cyprus has served as one the top three offshore destinations for Russian and former Soviet Union flight capital, most of it motivated by tax dodging, kleptocracy, and money laundering.

The Implications
Let’s put these relationships between Trump and these Russian investors in context. Right now the European Union (EU) has economic sanctions in place against Russia for its military annexation of Crimea. This move into Crimea is the first time the world map was changed by force since WWII.

Trump has advocated allowing the Russians to annex Crimea, questioned whether NATO is really necessary in the 21 century, and suggested we should consider lifting the sanctions on Russia. ABC News reports the flow of Russian money into Trump Towers began to dramatically slow down after the EU placed sanctions on Russia,

     … Pansky and Shtainer told ABC News that purchases from Russian buyers in New York and Miami began to drop precipitously in 2014, when the U.S. imposed economic sanctions on Russia in response to the Russian military incursion into Crimea.

To Russian buyers looking to move money out of their home country, Shtainer explained, the sanctions “basically cut off their oxygen.”

The economic sanctions on Russia have cut off the oxygen to Trump’s businesses around the world.

Time magazine published an article November 18th by Simon Shuster entitled, “The West Can’t Stand Up to Russia in the Donald Trump Era.”[xiv] Shuster argues the positions Trump has advocated on NATO, Crimea, Russia, and Putin fundamentally change the balance of power in the 21st century in ways that undermine the strength of all Russia’s enemies. This helps us understand why Putin would go to such trouble to influence the US election to help Trump. He knows Trump’s brand has been saved by Russian money and therefore sanctions on Russia are also sanctions on Trump.

Articles discussing Trump Businesses and Money Laundering

Behind Trump’s Russia Romance, There’s a Tower Full of Oligarchs, March 16, 2017, Bloomberg. https://www.bloomberg.com/news/articles/2017-03-16/behind-trump-s-russia-romance-there-s-a-tower-full-of-oligarchs
The Trump Towers are filled with Russians that launder dirty money.

Donald Trump’s Worst Deal, The New Yorker, 03/13/2017
http://www.newyorker.com/magazine/2017/03/13/donald-trumps-worst-deal

The Troubling Russian Connections Of Trump Nominee Wilbur Ross, February 27, 2017 5:17 pm  James S. Henry, The National Memo
http://www.nationalmemo.com/ross-russian-connections/
“After all, as discussed below, since the 1990s Cyprus has served as one the top three offshore destinations for Russian and former Soviet Union flight capital, most of it motivated by tax dodging, kleptocracy, and money laundering.”

Trump, Putin and the new Cold War, The New Yorker, 3/6/2017
http://www.newyorker.com/magazine/2017/03/06/trump-putin-and-the-new-cold-war
“Some officials believe that one reason the Russians compiled information on Trump during his 2013 trip was that he was meeting with Russian oligarchs who might be stashing money abroad—a sign of disloyalty, in Putin’s eyes.”

Exclusive: Big U.S. banks to push for easing of money laundering rules, Reuters, Februrary 16, 2017.
http://www.reuters.com/article/us-usa-banks-moneylaundering-exclusive-idUSKBN15V1E9

Will Trump end federal crackdown on dirty cash in luxury real estate?, Nicholas Nehamas, Miami Herald. January 22, 2017.
http://www.miamiherald.com/news/business/biz-monday/article127809744.html
Demonstrates FinCEN regulations do not include wire transfers, “the most common way buyers pay for pricey homes.”

Before Donald Trump attacked foreigners, he helped sell them condos, Miami Herald, October 14 2016.
http://www.miamiherald.com/news/politics-government/article108150442.html
Provides a breakdown of who or what owns the apartments in the Trump Towers, including Attie, Brazilian Mayor.

The Curious World of Donald Trump’s Private Russian Connections, JAMES S. HENRY, The American Interest.
http://www.the-american-interest.com/2016/12/19/the-curious-world-of-donald-trumps-private-russian-connections/

Trump, The Russian Connection, And The Future Of Ultra Luxury Real Estate, Peter Lane Taylor, Forbes.
http://www.forbes.com/sites/petertaylor/2017/02/21/trump-the-russian-connection-and-the-future-of-ultra-luxury-real-estate/#285926fd31cb
The future looks good for ultra luxury real estate since Trump was elected.

Trump’s SoHo Project Was Co-Financed by Dirty Kazakh Money, Financial Times, Geoffrey Smith, Fortune, Oct 19, 2016.
http://fortune.com/2016/10/19/trump-soho-kazakh-money-laundering/

Dirty money: Trump and the Kazakh connection, Financial Times.
https://www.ft.com/content/33285dfa-9231-11e6-8df8-d3778b55a923

FinCEN Fines Trump Taj Mahal Casino Resort $10 Million for Significant and Long Standing Anti-Money Laundering Violations, FinCEN. 3/6/2015
https://www.fincen.gov/news/news-releases/fincen-fines-trump-taj-mahal-casino-resort-10-million-significant-and-long

Wayne Barrett: Donald Trump and Rudy Giuliani, peas in a pod, Daily News.
http://www.nydailynews.com/opinion/wayne-barrett-donald-trump-rudy-giuliani-peas-pod-article-1.2776357
Trump was investigated for money laundering in the late 1980’s.   Then he became a Giuliani supporter.

Money Laundering & Terrorist Financing Through the Real Estate Sector, Financial Action Task Force.http://www.fatf-afi.org/media/fatf/documents/reports/ML%20and%20TF%20through%20the%20Real%20Estate%20Sector.pdf
U.S. expands investigation into money laundering by foreign cash buyers.

Government finds evidence of suspicious activities in high-end real estate, Housingwire, July 27, 2016, Ben Lane.
http://www.housingwire.com/articles/37637-us-expands-investigation-into-money-laundering-by-foreign-cash-buyers

FinCEN Expands Reach of Real Estate “Geographic Targeting Orders” Beyond Manhattan and Miami, FinCEN, July 27, 2016.
https://www.fincen.gov/news/news-releases/fincen-expands-reach-real-estate-geographic-targeting-orders-beyond-manhattan

Feds expand controversial tracking of secret home buyers to Broward, Palm Beach and more: Feds say more than 25 percent of reported transactions were suspect in Miami and Manhattan, July 27, 2016 02:15PM, By Sean Stewart-Muniz.
https://therealdeal.com/miami/2016/07/27/feds-expand-controversial-tracking-of-secret-home-buyers-to-broward-palm-beach-and-more/

ENDNOTES

[i] Nesbit, Jeff. “Donald Trump’s Many, Many, Many Ties to Russia.” Time. Time Inc.,
02 August 2016. Web. 03 January 2017. http://time.com/4433880/donald-trump-ties-
to-russia/

[i] Trump, Donald (@ realDonaldTrump). “For the record, I have ZERO investments in
Russia.” 26 Jul. 2016, 5:50 PM. Tweet.

[ii] Hudak, Steve. “FinCEN Fines Trump Taj Mahal Casino Resort $10 Million for
Significant and Long Standing Anti-Money Laundering Violations.” Financial
Crimes Enforcement Network. United States Department of Treasury, 06 March
2015. Web. 13 January 2017. https://www.fincen.gov/news/news-releases/fincen-
fines-trump-taj-mahal-casino-resort-10-million-significant-and-long

[iii] Barrett, Wayne. “Donald Trump and Rudy Giuliani, peas in a pod.” Daily News. Daily
News L.P., 04 September 2016. Web. 14 January 2017.
http://www.nydailynews.com/opinion/wayne-barrett-donald-trump-rudy-giuliani-
peas-pod-article-1.2776357

[iv] Ibid.

[v] Mosk, Matthew, Brian Ross and Patrick Reevell. “From Russia With Trump: A
Political Conflict Zone.” ABC News. Disney—ABC Television Group, 22 September
2016. Web. 13 January 2017. http://abcnews.go.com/Politics/russia-trump-political-
conflict-zone/story?id=42263092

[vi] Burgis, Tom. “Dirty money: Trump and the Kazakh connection.” Financial Times.
Nikkei Inc., 19 October 2016. Web. 13 January 2017.
https://www.ft.com/content/33285dfa-9231-11e6-8df8-d3778b55a923

[vii] Mosk, Matthew, Brian Ross and Patrick Reevell. “From Russia With Trump: A
Political Conflict Zone.” ABC News. Disney—ABC Television Group, 22 September
2016. Web. 13 January 2017. http://abcnews.go.com/Politics/russia-trump-political-
conflict-zone/story?id=42263092

[viii] Mosk, Matthew, Brian Ross and Patrick Reevell. “From Russia With Trump: A
Political Conflict Zone.” ABC News. Disney—ABC Television Group, 22 September
2016. Web. 13 January 2017. http://abcnews.go.com/Politics/russia-trump-political-
conflict-zone/story?id=42263092

[ix] Tanner, Adam, Wendy Sloan, Justin Burke, David Rohde, Peter Grier. “Russian Mafia
Expands into New Areas, Using the US to Launder Dirty Money.” The Christian
Science Monitor. Christian Science Publishing Society, 11 January 1995. Web. 13
January 2017. http://www.csmonitor.com/1995/0111/11011.html

[x] Burgis, Tom. “Dirty money: Trump and the Kazakh connection.” Financial Times.
Nikkei Inc., 19 October 2016. Web. 13 January 2017.
https://www.ft.com/content/33285dfa-9231-11e6-8df8-d3778b55a923

[xi] Horwitz, Jeff. “Trump OK’d business partner with alleged Iran laundering ties.”
Associated Press. PBS News Hour. The Public Broadcasting system, 04 June 2016.
Web. 13 January 2017. http://www.pbs.org/newshour/rundown/trump-okd-business-
partner-with-alleged-iran-laundering-ties/

[xii] Arends, Brett. “Donald Trump was a stock market disaster.” Market Watch. Dow
Jones Company, 22 July 2015. Web. 13 January 2017.
http://www.marketwatch.com/story/donald-trump-was-a-stock-market-disaster-2015-
07-22

[xiii] Ensign, Rachel Louise. “Fincen Hits Trump Taj Mahal With Record AML Penalty.”
The Wallstreet Journal. News Corp., 11 February 2015. Web. 14 January 2017.
http://blogs.wsj.com/riskandcompliance/2015/02/11/fincen-hits-trump-taj-mahal-
casino-with-record-aml-penalty/

[xiv] Shuster, Simon. “The West Can’t Stand Up to Russia in the Donald Trump Era.”
Time. Time Inc., 18 November 2016. Web. 04 January 2017.
http://time.com/4576950/russia-donad-trump-vladimir-putin/