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Rohrabacher violated Magnitsky Act

John E. Smith Director Office of Foreign Assets Control U.S. Department of the Treasury 1500 Pennsylvania Ave, N.W. Washington, D.C. 20220 21 July 2017 VIA EMAIL @treasury.gov and ofac feedback@trasuryov Dear Mr. Smith Re Notice of Apparent Violations of Magnitsky Act Sanctions by U.s. Persons Services to SDN Viktor Grin Providing This letter is to notify OFAC of apparent violations of the Sergei Magnitsky Rule of Law Accountability Act of 2012 ("Magnitsky Act") by two U.s. persons, Rep. Dana Rohrabacher ("Rohrabacher") and the Congressman's staff director, Paul Behrends "Behrends"), who reportedly provided services to Viktor Grin ("Grin"), who is a Russian official and became a Specially Designated National ("SDN") under the Magnitsky Act as of December 29, 2014.1

John E. Smith Director Office of Foreign Assets Control U.S. Department of the Treasury 1500 Pennsylvania Ave, N.W. Washington, D.C. 20220 21 July 2017 VIA EMAIL @treasury.gov and ofac feedback@trasuryov Dear Mr. Smith Re Notice of Apparent Violations of Magnitsky Act Sanctions by U.s. Persons Services to SDN Viktor Grin Providing This letter is to notify OFAC of apparent violations of the Sergei Magnitsky Rule of Law Accountability Act of 2012 ("Magnitsky Act") by two U.s. persons, Rep. Dana Rohrabacher ("Rohrabacher") and the Congressman's staff director, Paul Behrends "Behrends"), who reportedly provided services to Viktor Grin ("Grin"), who is a Russian official and became a Specially Designated National ("SDN") under the Magnitsky Act as of December 29, 2014.1

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The fight over Magnitsky Act

Bill Browder, founder of Hermitage Capital, has been fighting to restore Magnitsky's name ever since his death. Browder has given impetus to further global investigations over the last few years and has documente Moscow based investigators and tax officials. It is also Browder's doing that U.S. President Barack Obama signed the Magnitsky Act in 2012 which froze accounts of Russians who were, according to the U.S. Senate, involved in Magnitsky's death. The legislation also prevents these individuals from travelling to the United States. d the incredible wealth of several Russia's reaction to the Magnitsky Act was swift: A law was passed in early 2013 that prohibited Americans from adopting Russian children. Meanwhile, Magnitsky was posthumously found guilty of tax evasion in July 2013 by a Russian court. Browder, though absent, was also found guilty. Research by the OCCRP and Suddeutsche Zertung in the Panama Papers now reveals the connection between the Magnitsky case and the Roldugin network. The same network that was used to divert hundreds of millions of dollars from the Russian State can now be linked to the network of shell

Bill Browder, founder of Hermitage Capital, has been fighting to restore Magnitsky's name ever since his death. Browder has given impetus to further global investigations over the last few years and has documente Moscow based investigators and tax officials. It is also Browder's doing that U.S. President Barack Obama signed the Magnitsky Act in 2012 which froze accounts of Russians who were, according to the U.S. Senate, involved in Magnitsky's death. The legislation also prevents these individuals from travelling to the United States. d the incredible wealth of several Russia's reaction to the Magnitsky Act was swift: A law was passed in early 2013 that prohibited Americans from adopting Russian children. Meanwhile, Magnitsky was posthumously found guilty of tax evasion in July 2013 by a Russian court. Browder, though absent, was also found guilty. Research by the OCCRP and Suddeutsche Zertung in the Panama Papers now reveals the connection between the Magnitsky case and the Roldugin network. The same network that was used to divert hundreds of millions of dollars from the Russian State can now be linked to the network of shell

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Deutsche Bank providing records to Mueller

VYI reported Deutsche Bank is under investigation by regulators for their lending relationship with Trump. The bank is also likely to have to provide information to Mueller as part of the Trump-Russia probe. Week 36: Experts in authoritarianism advise to .. Amy Siskind

VYI reported Deutsche Bank is under investigation by regulators for their lending relationship with Trump. The bank is also likely to have to provide information to Mueller as part of the Trump-Russia probe. Week 36: Experts in authoritarianism advise to .. Amy Siskind

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State priority to remove sanctions

Jamison Firestone, the founder of the Russian law firm that employed Magnitsky at the time that he exposed the fraud, said that Veselnitskaya clearly intended to use the Trump Tower meeting to lobby against the Magnitsky sanctions. "They really made it a state priority to get rid of these sanctions," he said.

Jamison Firestone, the founder of the Russian law firm that employed Magnitsky at the time that he exposed the fraud, said that Veselnitskaya clearly intended to use the Trump Tower meeting to lobby against the Magnitsky sanctions. "They really made it a state priority to get rid of these sanctions," he said.

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Magtnitsky's role in this is important

Magnitsky's death led to a political backlash in the US that in turn spawned tough sanctions on Russia, known as the Magnitsky Act. Russian individuals associated with the lawyer's demise and other human rights abuses were banned entry to the US. Veselnitskaya not only acted as Prevezon's Russian counsel in the money- laundering case, she also was a leading lobbyist against the Magnitsky sanctions. She raised the subject prominently at the meeting in Trump Tower with Don Jr and Kushner, though according to Veselnitskaya the president's son-in-law left after 10 minutes. By the time of the Trump Tower meeting, Veselnitskaya was already personally acquainted with Russia's powerful prosecutor general, Yuri Chaika, and her lobbying against the Magnitsky sanctions had drawn significant attention irn government circles. Natalia's main role was coordinating, including regular coordination with Chaika, whom she knew personally" said a source acquainted with the Prevezon case Veselnitskaya told the Guardian: "My meeting with Trump's son was a private meeting; nobody in the government had anything to do with it." She declined to answer a follow-up question about whether and how she knew Chaika.

Magnitsky's death led to a political backlash in the US that in turn spawned tough sanctions on Russia, known as the Magnitsky Act. Russian individuals associated with the lawyer's demise and other human rights abuses were banned entry to the US. Veselnitskaya not only acted as Prevezon's Russian counsel in the money- laundering case, she also was a leading lobbyist against the Magnitsky sanctions. She raised the subject prominently at the meeting in Trump Tower with Don Jr and Kushner, though according to Veselnitskaya the president's son-in-law left after 10 minutes. By the time of the Trump Tower meeting, Veselnitskaya was already personally acquainted with Russia's powerful prosecutor general, Yuri Chaika, and her lobbying against the Magnitsky sanctions had drawn significant attention irn government circles. Natalia's main role was coordinating, including regular coordination with Chaika, whom she knew personally" said a source acquainted with the Prevezon case Veselnitskaya told the Guardian: "My meeting with Trump's son was a private meeting; nobody in the government had anything to do with it." She declined to answer a follow-up question about whether and how she knew Chaika.

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Magnitsky didn't die in vain

The pursuit of Prevezon Holdings for alleged money laundering took on enormous political significance as it unfolded. For the prosecutors, it was a test case over suspicious Russian money flows designed to show the US was serious about going after money launderers. For the Russians, it was an opportunity to push back against stringent US sanctions that had long infuriated the Kremlin In court documents, US prosecutors accused Prevezon and its sole shareholder, Denis Katsyv, of participating in the laundering of proceeds of the vast tax fraud that stole $230m from the Russian treasury and moved it out of the country in chunks. Prevezon was alleged to have received some of the fraudulent spoils through a network of shell companies, hiding the money by investing in Manhattan real estate including the Leviev condominiums in 20 Pine Street. Prevezon and Katsyv have consistently denied any involvement in money laundering and have dismissed the lawsuit as "ill-conceived". In a statement released at the time of the settlement, they said they had "no involvement in or knowledge of any fraudulent activities". Magnitsky discovered the massive tax fraud, said to be one of the largest in Vladimir Putin's Russia, in 2007. After he blew the whistle on the scam, he was arrested by the same officials whom he had accused of covering up the racket and imprisoned, dying in jail having been denied medical treatment.

The pursuit of Prevezon Holdings for alleged money laundering took on enormous political significance as it unfolded. For the prosecutors, it was a test case over suspicious Russian money flows designed to show the US was serious about going after money launderers. For the Russians, it was an opportunity to push back against stringent US sanctions that had long infuriated the Kremlin In court documents, US prosecutors accused Prevezon and its sole shareholder, Denis Katsyv, of participating in the laundering of proceeds of the vast tax fraud that stole $230m from the Russian treasury and moved it out of the country in chunks. Prevezon was alleged to have received some of the fraudulent spoils through a network of shell companies, hiding the money by investing in Manhattan real estate including the Leviev condominiums in 20 Pine Street. Prevezon and Katsyv have consistently denied any involvement in money laundering and have dismissed the lawsuit as "ill-conceived". In a statement released at the time of the settlement, they said they had "no involvement in or knowledge of any fraudulent activities". Magnitsky discovered the massive tax fraud, said to be one of the largest in Vladimir Putin's Russia, in 2007. After he blew the whistle on the scam, he was arrested by the same officials whom he had accused of covering up the racket and imprisoned, dying in jail having been denied medical treatment.

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Kushner and Leviev

In Manhattan, Leviev's firm also sold condominiums to Prevezon Holdings from one of its landmark developments at 20 Pine Street, just a few blocks from Wall Street Real estate brochures describe the lavish interior decor of the condominiums, replete with bathrooms bedecked in stone and exotic woods, and boasting "the ultimate in pampering; a sybaritic recssed rain shower". The 20 Pine Street apartments that Leviev sold to Prevezon were later frozen by US prosecutors seeking to block the flow of what they alleged to be money stolen from the Russian treasury and laundered through New York real estate. Prevezon's 20 Pine Street apartments and e3m in assets were all released as part of the settlement in May. The Guardian contacted both Kushner and Leviev for comment, but they did not immediately respond.

In Manhattan, Leviev's firm also sold condominiums to Prevezon Holdings from one of its landmark developments at 20 Pine Street, just a few blocks from Wall Street Real estate brochures describe the lavish interior decor of the condominiums, replete with bathrooms bedecked in stone and exotic woods, and boasting "the ultimate in pampering; a sybaritic recssed rain shower". The 20 Pine Street apartments that Leviev sold to Prevezon were later frozen by US prosecutors seeking to block the flow of what they alleged to be money stolen from the Russian treasury and laundered through New York real estate. Prevezon's 20 Pine Street apartments and e3m in assets were all released as part of the settlement in May. The Guardian contacted both Kushner and Leviev for comment, but they did not immediately respond.

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Jared's purchase of old NYT building

Among the overlapping connections is the 2015 deal in which Kushner paid $295m to acquire several floors of the old New York Times building at 43rd street in Manhattan from the US branch of Leviev's company, Africa Israel Investments (AFI), and its partner Five Mile Capital. The sale has been identified as of possible interest to the Mueller investigation as Kushner later went on to borrow $285m in refinancing from Deutsche Bank, the German financial house that itself has been embroiled in Russian money laundering scandals and whose loans to Trump are coming under intensifying scrutiny.

Among the overlapping connections is the 2015 deal in which Kushner paid $295m to acquire several floors of the old New York Times building at 43rd street in Manhattan from the US branch of Leviev's company, Africa Israel Investments (AFI), and its partner Five Mile Capital. The sale has been identified as of possible interest to the Mueller investigation as Kushner later went on to borrow $285m in refinancing from Deutsche Bank, the German financial house that itself has been embroiled in Russian money laundering scandals and whose loans to Trump are coming under intensifying scrutiny.

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Veselnitskaya important to this plot

Four Russians attended the meeting, led by Natalia Veselnitskaya, a lawyer with known Kremlin connections who acted as legal counsel for Prevezon in the money laundering case and who called the $6m settlement so slight that "it seemed almost an apology from the government". Sixteen Democratic members of the House judiciary committee have now written to the justice department in light of the Trump Tower meeting demanding to know whether there was any interference behind the decision to avoid trial Constitutional experts are also demanding an official inquiry. "We need a full accounting by Trump's justice department of the unexplained and frankly outrageous settlement that is likely to be just the tip of a vast financial iceberg," said Laurence Tribe, Harvard University professor of constitutional law.

Four Russians attended the meeting, led by Natalia Veselnitskaya, a lawyer with known Kremlin connections who acted as legal counsel for Prevezon in the money laundering case and who called the $6m settlement so slight that "it seemed almost an apology from the government". Sixteen Democratic members of the House judiciary committee have now written to the justice department in light of the Trump Tower meeting demanding to know whether there was any interference behind the decision to avoid trial Constitutional experts are also demanding an official inquiry. "We need a full accounting by Trump's justice department of the unexplained and frankly outrageous settlement that is likely to be just the tip of a vast financial iceberg," said Laurence Tribe, Harvard University professor of constitutional law.

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Magnitsky uncovered Jared's deal, was killed for it

Leviev, a global tycoon known as the "king of diamonds", was a business partner of the Russian-owned company Prevezon Holdings that was at the center ofa multimillion-dollar lawsuit launched in New York. Under the leadership of US attorney Preet Bharara, who was fired by Trump in March, prosecutors pursued Prevezon for allegedly attempting to use Manhattan real estate deals to launder money stolen from the Russian treasury. The scam had been uncovered by Sergei Magnitsky, an accountant who died in 2009 in a Moscow jail in suspicious circumstances. US sanctions against Russia imposed after Magnitsky's death were a central topic of conversation at the notorious Trump Tower meeting last June between Kushner, Donald Trump Jr, Trump campaign manager Paul Manafort and a Russian lawyer with ties to the Kremlin

Leviev, a global tycoon known as the "king of diamonds", was a business partner of the Russian-owned company Prevezon Holdings that was at the center ofa multimillion-dollar lawsuit launched in New York. Under the leadership of US attorney Preet Bharara, who was fired by Trump in March, prosecutors pursued Prevezon for allegedly attempting to use Manhattan real estate deals to launder money stolen from the Russian treasury. The scam had been uncovered by Sergei Magnitsky, an accountant who died in 2009 in a Moscow jail in suspicious circumstances. US sanctions against Russia imposed after Magnitsky's death were a central topic of conversation at the notorious Trump Tower meeting last June between Kushner, Donald Trump Jr, Trump campaign manager Paul Manafort and a Russian lawyer with ties to the Kremlin

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Jared's secret deal with Russian oligarch

Jared Kushner, the son-in-law of Donald Trump, who acts as his senior White House adviser, secured a multimillion-dollar Manhattan real estate deal with a Soviet-born oligarch whose company was cited in a major New York money laundering case now being investigated by members of Congress. A Guardian investigation has established a series of overlapping ties and relationships involving alleged Russian money laundering, New York real estate deals and members of Trump's inner circle. They include a 2015 sale of part of the old New York Times building in Manhattan involving Kushner and a billionaire real estate tycoon and diamond mogul, Lev Leviev. The ties between Trump family real estate deals and Russian money interests are attracting growing interest from the justice department's special counsel, Robert Mueller, as he seeks to determine whether the Trump campaign collaborated with Russia to distort the outcome of the 2016 race. Mueller has reportedly expanded his inquiry to look at real estate deals involving the Trump Organization, as well as Kushner's financing.

Jared Kushner, the son-in-law of Donald Trump, who acts as his senior White House adviser, secured a multimillion-dollar Manhattan real estate deal with a Soviet-born oligarch whose company was cited in a major New York money laundering case now being investigated by members of Congress. A Guardian investigation has established a series of overlapping ties and relationships involving alleged Russian money laundering, New York real estate deals and members of Trump's inner circle. They include a 2015 sale of part of the old New York Times building in Manhattan involving Kushner and a billionaire real estate tycoon and diamond mogul, Lev Leviev. The ties between Trump family real estate deals and Russian money interests are attracting growing interest from the justice department's special counsel, Robert Mueller, as he seeks to determine whether the Trump campaign collaborated with Russia to distort the outcome of the 2016 race. Mueller has reportedly expanded his inquiry to look at real estate deals involving the Trump Organization, as well as Kushner's financing.

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New York Daily News

London· Evening Sex on the beach Love Island is tame compared with the steamy ancient world Pages 20&21 Standard Monday 24 July 2017 FREE standard.couk WEST END FINAL EXTRA AFTER THE WATERSHED ENGLAND HEROINE ANYA SHRUBSOLE SAYS WORLD CUP VICTORY WILL INSPIRE A NEW GENERATION OF CRICKETERS Sport PAGES 54-56 5 TRUMP SON-IN-LAW REVEALS MORE CONTACTS WITH RUSSIANS BUT INSISTS: I DID NOT HAVE CORRUPT RELATIONS WITH THAT COUNTRY Senate over alleged Russian interference in the Nicholas Cecil Deputy Poltical Editor and David Gardner US Correspondent election, issued an ll-page statement denying collusion with any Russians during the cam- Denial: Jared Kushner with DONALD TRUMP'S son-in-law Jared Kushner paign and the transition period after Mr today revealed details of contacts with a Trump's victory last November. Herejected Russian ambassador, a Russian banker and a claims that he had sought to set upa "back Russian lawyer before the tycoon moved into channel" to Moscow. Echoing President the White House. The US president's senior adviser, who is due to be questioned by the Continued on Page 8 his wife lvanka, daughter of Trump, at the 1 White House UK FALLS BEHIND EUROZONE IN GROWTH FORECAST PAGE 2 POLICE GET KITS TO TREAT ACID VICTIM

London· Evening Sex on the beach Love Island is tame compared with the steamy ancient world Pages 20&21 Standard Monday 24 July 2017 FREE standard.couk WEST END FINAL EXTRA AFTER THE WATERSHED ENGLAND HEROINE ANYA SHRUBSOLE SAYS WORLD CUP VICTORY WILL INSPIRE A NEW GENERATION OF CRICKETERS Sport PAGES 54-56 5 TRUMP SON-IN-LAW REVEALS MORE CONTACTS WITH RUSSIANS BUT INSISTS: I DID NOT HAVE CORRUPT RELATIONS WITH THAT COUNTRY Senate over alleged Russian interference in the Nicholas Cecil Deputy Poltical Editor and David Gardner US Correspondent election, issued an ll-page statement denying collusion with any Russians during the cam- Denial: Jared Kushner with DONALD TRUMP'S son-in-law Jared Kushner paign and the transition period after Mr today revealed details of contacts with a Trump's victory last November. Herejected Russian ambassador, a Russian banker and a claims that he had sought to set upa "back Russian lawyer before the tycoon moved into channel" to Moscow. Echoing President the White House. The US president's senior adviser, who is due to be questioned by the Continued on Page 8 his wife lvanka, daughter of Trump, at the 1 White House UK FALLS BEHIND EUROZONE IN GROWTH FORECAST PAGE 2 POLICE GET KITS TO TREAT ACID VICTIM

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Russian oligarchs take root in US real estate

Two decades ago, as the Russian president set about consolidating power on one side of the world, he embarked on a project to supplant his country's existing Jewish civil society and replace it with a parallel structure loyal to him. On the other side of the world, the brash Manhattan developer was working to get a piece of the massive flows of capital that were fleeing the former Soviet Union in search of stable assets in the West, especially real estate, and seeking partners in New York with ties to the region. Their respective ambitions led the two men-along with Trump's future son-in-law, Jared Kushner-to build a set of close, overlapping relationships in a small world that intersects on heard of.

Two decades ago, as the Russian president set about consolidating power on one side of the world, he embarked on a project to supplant his country's existing Jewish civil society and replace it with a parallel structure loyal to him. On the other side of the world, the brash Manhattan developer was working to get a piece of the massive flows of capital that were fleeing the former Soviet Union in search of stable assets in the West, especially real estate, and seeking partners in New York with ties to the region. Their respective ambitions led the two men-along with Trump's future son-in-law, Jared Kushner-to build a set of close, overlapping relationships in a small world that intersects on heard of.

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"He's just a poor boy..."

Kushner defends himself ahead of Senate intel meeting:'I did not collude' He describes himself as a loyal, overworked, under-experienced senior adviser to Trump during a novice campaign that was never staffed up to win

Kushner defends himself ahead of Senate intel meeting:'I did not collude' He describes himself as a loyal, overworked, under-experienced senior adviser to Trump during a novice campaign that was never staffed up to win

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"I did not have treasonous communications with that country!"

The Ambassador expressed similar sentiments about relations, and then said he especially wanted to address U.S. policy in Syria, and that he wanted to convey information from what he called his "generals." He said he wanted to provide information that would help inform the new administration. He said the generals could not easily come to the U.S. to convey this information and he asked if there was a secure line in the transition office to conduct a conversation. General Flynn or l explained that there were no such lines. I believed developing a thoughtful approach on Syria was a very high priority given the ongoing humanitarian crisis, and l asked if they had an existing communications channel at his embassy we could use where they would be comfortable transmitting the information they wanted to relay to General Flynn. The Ambassador said that would not be possible and so we all agreed that we would receive this information after the Inauguration. Nothing else occurred. I did not suggest a "secret back channel." I did not suggest an on-going secret form of communication for then or for when the administration took office. I did not raise the possibility of using the embassy or any other Russian facility for any purpose other than this one possible conversation in the transition period. We did not discuss sanctions.

The Ambassador expressed similar sentiments about relations, and then said he especially wanted to address U.S. policy in Syria, and that he wanted to convey information from what he called his "generals." He said he wanted to provide information that would help inform the new administration. He said the generals could not easily come to the U.S. to convey this information and he asked if there was a secure line in the transition office to conduct a conversation. General Flynn or l explained that there were no such lines. I believed developing a thoughtful approach on Syria was a very high priority given the ongoing humanitarian crisis, and l asked if they had an existing communications channel at his embassy we could use where they would be comfortable transmitting the information they wanted to relay to General Flynn. The Ambassador said that would not be possible and so we all agreed that we would receive this information after the Inauguration. Nothing else occurred. I did not suggest a "secret back channel." I did not suggest an on-going secret form of communication for then or for when the administration took office. I did not raise the possibility of using the embassy or any other Russian facility for any purpose other than this one possible conversation in the transition period. We did not discuss sanctions.

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Before Election Day?

On November 16, 2016, my assistant received a request for a meeting from the Russian Ambassador. As I mentioned before, previous to receiving this request, I could not even recall the Russian Ambassador's name, and had to ask for the name of the individual I had seen at the Mayflower Hotel almost seven months earlier. In addition, far from being urgent, that meeting was not set up for two weeks - on December 1. The meeting occurred in Trump Tower, where we had our transition office, and lasted twenty- thirty minutes. Lt. General Michael Flynn (Ret.), who became the President's National Security Advisor, also attended. During the meeting, after pleasantries were exchanged, as I had done in many of the meetings I had and would have with foreign officials, I stated our desire for a fresh start in relations. Also, as I had done in other meetings with foreign officials, I asked Ambassador Kislyak if he would identify the best person (whether the Ambassador or someone else) with whom to have direct discussions and who had contact with his President. The fact that I was asking about ways to start a dialogue after Election Day should of course be viewed as strong evidence that I was not aware of one that existed before Election Day.

On November 16, 2016, my assistant received a request for a meeting from the Russian Ambassador. As I mentioned before, previous to receiving this request, I could not even recall the Russian Ambassador's name, and had to ask for the name of the individual I had seen at the Mayflower Hotel almost seven months earlier. In addition, far from being urgent, that meeting was not set up for two weeks - on December 1. The meeting occurred in Trump Tower, where we had our transition office, and lasted twenty- thirty minutes. Lt. General Michael Flynn (Ret.), who became the President's National Security Advisor, also attended. During the meeting, after pleasantries were exchanged, as I had done in many of the meetings I had and would have with foreign officials, I stated our desire for a fresh start in relations. Also, as I had done in other meetings with foreign officials, I asked Ambassador Kislyak if he would identify the best person (whether the Ambassador or someone else) with whom to have direct discussions and who had contact with his President. The fact that I was asking about ways to start a dialogue after Election Day should of course be viewed as strong evidence that I was not aware of one that existed before Election Day.

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