Democratic leaders call for investigation into Trump’s business dealings

By Stephanie K. Mann, J.D.

Leading Democrats on the Senate Banking Committee, Foreign Relations Committee, and Judiciary Committee have called for a federal investigation into whether President Donald Trump’s business dealings in Azerbaijan may have violated anti-corruption and sanctions laws, and served as a channel for money-laundering and other illicit activities tied to Iran’s Islamic Revolutionary Guard Corps (IRGC), an elite military force that wields significant economic and political power in Iran.

Senators Sherrod Brown (D-Ohio), Ben Cardin (D-Md), and Dianne Feinstein (D-Calif) outlined their concerns in a letter to Treasury Secretary Steven Mnuchin, Attorney General Jeff Sessions, and FBI Director James Comey. According to the letter, the senators’ concerns stem from a recent New Yorker investigative article that details the Trump Organization’s relationship with Azerbaijan’s Mammadov family in their joint development of the Trump Tower in Baku. According to the article, the Mammadovs have ties to IRGC actors.

In their letter, the legislators raise questions about whether the Trump Organization may have violated the Foreign Corrupt Practices Act, and the possibility that one of the construction entities involved with the Azerbaijani developers of the project may have been a front organization for the IRGC. The New Yorker article claims that the IRGC may have been the source of payments made to the Trump Organization, which would be a direct violation of U.S. sanctions law, claims the letter.

“It appears that the lack of due diligence by the Trump Organization described in the article exposed President Trump and his organization to notoriously corrupt Azerbaijani oligarchs, and may also have exposed the Trump Organization to the IRGC,” the senators wrote. “Even though the Trump Organization appears to have withdrawn from the Baku Tower deal, serious questions remain unanswered about the Trump Organization’s potential criminal liability.”

Investigations warranted. As a result of these allegations, the senators have asked the Justice Department to investigate whether:

• the Trump Organization violated anti-corruption laws by failing to conduct due diligence into its relationship with the Mammadovs;
• the company acted with “willful blindness” regarding its business partners' illicit activity in the Baku dealings; and 
• the Trump Organization could face criminal prosecution. 

The legislators have also asked Treasury to examine the Trump Organization’s foreign partners in the Baku deal, its internal compliance controls, and whether the company may have violated sanctions laws by doing business with those linked to the IRGC.

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