1.Summary

The information contained this website, Our Criminal President, is presented by patriotic Americans who fear for our future of our Nation’s democracy and the wellbeing of its citizens. Donald Trump has many faults and is unfit to be Commander in Chief. What is not as well known and understood by the American people is Donald Trump’s and his family member’s suspect real estate dealings in Panama and relations with criminal actors involved in these activities dating back to 2005.

We believe this information illustrates who Donald Trump really is and what he really stands for. It is vital that this information be shared and understood now as America nears perhaps the most important election in its history. With so much on the line Americans will be able to better judge for themselves whether our country’s best interests are served by a second Trump term in office.

We have prepared a succinct report that reviews real estate deals made by the Trump Organization in Panama and key players involved in these business arrangements. It details how many Trump Organization business partners are highly compromised, including ties to terrorist organizations, drug cartels, human traffickers, kidnappers, money laundering, fraudsters, and the Russian mafia. This paper also documents the professional opinion of leading anti-corruption specialists who conclude the Trump Organization didn’t conduct proper due diligence before entering into business with such criminals/criminal enterprises.

The report raises serious questions about: (1) whether it was and may still be proper for Donald Trump and the Trump Organization to profit from such blatant real estate fraud at the expense of others, and from criminal activity enabled by construction of Panamanian real estate; (2) did the Trump Organization and Trump family principals take the requisite measures to learn the background and activities of the questionable individuals/organizations they were dealing with; and (3) was it appropriate for the Trump Organization and Trump family principals to conduct multi-million dollar international business ventures with business partners who have been identified as financiers of terrorism, human traffickers, and organized crime?

In addition to our reporting we have included relevant photos that may be more damning than anything else. We have also included internal memos from the Trump Organization and their associate’s criminal dealings in Panama. Finally, we have included a link analysis chart with back up detail concerning those individuals and organizations discussed in our report.

We view what we have presented as a first step and hope others will conduct further investigation of the Trump Organization’s Panama business dealings, along with its involvement with questionable people in and around these projects.

2.Scope

Reporters from three organizations (Reuters, NBC News, and Global Witness) published three quality reports on the Panama real estate projects of the Trump Organization. We have provided key points of their excellent reporting into a single framework, and quoted extensively from their writing, with precise end noting throughout this document. Our own investigation collected more granular details from other sources, including social media, and local news reports from Panama and Brazil. For example, we have included relevant photos from Instagram and other platforms. We include our own analysis or perspective, distinguishable from the output of others by the lack of endnotes. Next, 16 internal memos and conference call transcripts were made available and we include them as archival material for further scrutiny. Finally, we have included a link analysis chart with back up detail concerning those individuals and organizations discussed.

We believe the work presented here warrants further investigation of the Trump Organization’s Panama business dealings, along with its involvement with questionable people in and around these projects.

3.Property Name

Trump International Hotel & Tower Panama
(formerly Trump Ocean Club International Hotel & Tower)
Address: Panama City 0833-00321, Panama
Phone: +507 215-8800
Geocoordinates: 8.9755403, -79.5095009

The Trump International Hotel & Tower Panama, now known as the JW Marriott Panama, is a 70-story, 2,500,000 sq. ft. (230,000 m2), and mixed-use waterfront condominium tower development in Panama City, Panama. The project includes 369 hotel units, 700 condominium units, 1500 parking spaces, retail shops, casino, and  a private beach club.[1] An interesting side note: The hotel opened on July 6, 2011. The similar design to Jumeirah Hotels and Resorts’ very famous five-star hotel Burj Al Arab in Dubai, UAE, its development and construction landed the Trump Organization in court.[2]

  The result was that the Panamanian government intervened in April 2008, through a protective order to prevent the owners of the Burj al-Arab from threatening a lawsuit.[3] The Trump Organization accredits the design of the building to the Colombian firm Arias Serna Saravia.[4] The Trump Ocean Club Hotel is 15 km from Tocumen International Airport.[5]

4. Introduction

The Trump Ocean Club International Hotel and Tower was Trump’s first international real estate deal,[6] and it followed a by now familiar formula, in which the Trump Organization does not own the property but licenses the Trump name to a third party. That arrangement limits the Trump family’s legal and financial exposure in a development deal, but still allows them to reap handsome profits. It also allows them to avoid directly overseeing the sales process, even when there are several obvious warning signs that criminals could use a property like the Ocean Club to launder money.

Donald Trump put his name to the development and stood to make up to $75 million from it, according to a bond prospectus for the project. He did not exert management control over the construction and was under no direct legal obligation to conduct due diligence on other people involved.[7] Nevertheless, the question is whether the Trump Organization, including the Trump children and Donald Trump himself understood or took measures to conduct due diligence on who they were dealing with, or if they did, why did they conduct or consider conducting business with such questionable individuals/organizations.

5.Key Individuals

Roger Khafif

 

The plan was for Newland International Properties Corp, where Khafif was president and which owned the development, to finance construction with a bond underwritten by the US investment bank Bear Stearns. That company collapsed in 2008 and was acquired by JPMorgan.[9]

The Trump Organization asked condominium purchasers to pay 10 percent up front; the average price was about $350,000. Buyers had to pay 30 percent within a year, according to the bond prospectus, and Homes Real Estate Investment & Services (see below) organized the investment by setting up Panamanian companies for customers to enter pre-sales agreements with Khafif’s company, Newland International Properties.[10]

Khafif later filed for bankruptcy and disappeared from sight. He was last seen in the Balkan country of Montenegro opening a GNC food supplements store in October 2016.[11]

 

Alexandre Ventura Nogueira

One of the principal players in the Panama Ocean Club real estate deal was Alexandre Ventura Nogueira. Prior to this, in September 2005, the Spanish Economy Ministry had fined Nogueira for an alleged “serious violation” of money-laundering laws. The proceedings in Spain ended about nine months later when officials could not locate Nogueira.[12]

Nogueira said he first got involved with the Trump Ocean Club project during 2006 at a meeting in Panama arranged by Khafif, whom he knew already.

Ivanka Trump and other real estate brokers were there, he said. He remembered listing condominiums starting at $120,000. Nogueira said he stood up and said the price was at the level charged in ordinary developments. “Here, it is Trump selling. You have to give a value to that name. Make it $220,000!”[13]

Nogueira added that, “The agreement was, I had a week to sell 100 units. I said, ‘I’m going to do better, I’m going to sell without telling (the buyers) the price.” Nogueira sold the initial units, and later hundreds more.[14]

The Trump Organization’s legal counsel, Alan Garten, told reporters, “No one at the Trump Organization, including the Trump family, has any recollection of ever meeting or speaking with this individual.”[15] The provided photos of Donald Trump and Ivanka Trump posing with Nogueira establish that they had in fact met. However, these do not provide definitive proof they were close. For that, we turn to Justine Pasek, whom Trump had crowned her Miss Universe in 2002.

She explained that the Trump Organization selected a Brazilian, Alexandre Ventura Nogueira, to be a principal business partner. Following her Miss Universe crowning, she became the company spokesperson of Nogueira’s Homes Real Estate Investment & Services organization. She explained that, “Mr. Nogueira was an outgoing and lively young man. Everybody was so impressed with Homes as they seemed to be riding the top of the real estate boom.”[16]

 On May 28, 2009, Panamanian officials arrested Nogueira for fraud and the falsifying documents. The Panamanian businessman Lazar Jamal complained that Nogueira had swindled $700,000 from him on an apartment in Punta Pacifica in 2008.[17] Independently of this charge, Nogueira was also connected to David Murcia Guzman, the head of the DMG Grupo Holding SA and a known FARC narco-terrorist financier.[18]

Released on bail for $1.4 million, Nogueira continued to live in Panama until 2012 when, despite a ban on leaving the country, he fled to his native country, Brazil.[19] Nogueira then fled Brazil in October 2014.[20] Karen Kahn, a federal prosecutor based in Sao Paulo, said Nogueira is under a federal investigation for international money laundering, an inquiry triggered by several large bank transfers that arrived in his accounts from Panama.[21] Immigration reports show Nogueira has been hiding in Dominican Republic since 2014.[22]

Igor Anopolskiy

Igor Anopolskiy, a Ukrainian national was the Homes representative in Kiev, Ukraine.[23] Anopolskiy’s involvement with the project shows the reach of the Ventura Nogueira network into powerful and questionable political and business circles internationally. Records list him as a director or shareholder of at least 19 Panamanian companies linked to real estate, including four apparently relating to Trump Ocean Club units. In his interview with NBC and Reuters, Ventura Nogueira confirmed Anopolskiy’s role in marketing Trump Ocean Club units in Ukraine.

Since 2005, Anopolskiy has been a shareholder in a travel agency in Ukraine whose earlier shareholders include a woman named Oxana Marchenko. She is believed to be the wife of the former Ukrainian presidential chief of staff Viktor Medvedchuk, a vehement critic of the pro-European protests that led to the downfall of President Yanukovych. Medvedchuk was one of Ukraine’s first post-Soviet oligarchs. Medvedchuk later became very close with Putin’s number-two, Russian Prime Minister Dmitry Medvedev. However, he is even closer with Putin himself, who is godfather to Medvedchuk’s and Marchenko’s daughter (Medvedev’s wife is the godmother).[24]

Ukrainian police records state they arrested Anopolskiy in March 2007 for suspected human trafficking. Released a year later on bail, he was re-arrested in 2013. In 2014 a Ukraine court handed Anopolskiy a five-year suspended jail sentence with three years probation for offenses including human smuggling and forgery, unrelated to the Trump project. Interviewed in Kiev, Anopolskiy blamed the case on police corruption and denied committing any crime.[25] 

Louis Pargiolas Castaño

One early investor in the Ocean Club project was a man named Louis Pargiolas . Pargiolas was arrested in April of 2009. At this arraignment, his lawyer claimed that the money sent to convicted drug trafficker Gabriel Afanador Solano was not for a drug shipment but rather to pay off an extortion demand by the 52nd Front of the guerrilla Revolutionary Armed Forces of Colombia (FARC).[26] In 2009, he pleaded guilty in a Miami federal court to conspiracy to import cocaine.[27]

The Trump property ownership structure is complicated. The condo and hotel complex, which cost $300 million, was built by Newland International Properties Corp., which is was owned by the Panama Ocean Point Development Corp., both based in Panama. Ocean Point is owned by Arias Serna y Saravia (SAS) and Espacios Urbanos, both Colombian firms, which invested 30 percent of the total through a Costa Rican firm, Upper Deck Properties. Serna said the remaining 70 percent came from Panama businessman Roger Khafif (see above). The Colombian companies needed to find more investors, Serna said, and that’s where Pargiolas came into the picture. During one of his US court sessions, his lawyer said Pargiolas helped to sell Trump Ocean Club properties to others, which required that he travel to Colombia, Venezuela, Spain and Switzerland.[28]

Colombian businessman Rodrigo Serna Londoño initially joined Pargiolas in the company that was to develop the Trump Ocean Club. He said Pargiolas was initially “considered to be an impeccable businessman, up and coming and respected in Colombia as well as the United States, with contacts at the top levels of both countries.” According to Londoño, he cut off all links with Pargiolas after learning of his legal problems in the U.S.[29] 

Londoño and his brother, Carlos Alberto, persuaded Trump to invest in Panama in 2005 after Trump’s daughter, Ivanka, showed a lack of enthusiasm for the Ocean Club project. The Colombian newspaper El Espectador reported the brothers went to New York and persuaded Trump of “the virtues of Panamanian real estate.”[30]

The ownership structure of the Trump Club is complicated. The condo and hotel complex, which cost $300 million, was developed by Newland International Properties Corp., which is in turn owned by the Panama Ocean Point Development Corp., both based in Panama. Ocean Point is owned by Arias Serna y Saravia (SAS) and Espacios Urbanos, both Colombian firms, which invested 30 percent of the total through a Costa Rican firm, Upper Deck Properties.

Serna said the remaining 70 percent came from Panama businessman Roger Khafif.  The Colombian companies needed to find more investors, Serna said, and that’s where Pargiolas came into the picture. During one of his U.S. court sessions, his lawyer said he also helped to sell Trump Ocean Club properties to others, which required that he travel to Colombia, Venezuela, Spain and Switzerland.[31]

Andrey Bogdanov and
Ivan Kazanikov

During the July 2011 Trump Ocean Club opening in Panama, Donald Trump posed for a photo with two Russian men named Andrey Bogdanov and Ivan Kazanikov who bought at least six units in the property worth $4.4 million.

Aspects of the duo’s background and activities in Panama suggest connections with money laundering. Andrey Bogdanov’s career began with Russia’s Master-Bank soon after they established it in 1992. According to Bogdanov’s LinkedIn profile, he worked in the bank’s credit department. A few years after Master-Bank’s founding, Bogdanov became a director and shareholder of a company called ZAO Makmar, alongside Master-Bank principal Boris Bulochnik.

By 2013, Master-Bank had lost its operations license, for not observing Russian anti-money laundering laws, false accounting and loans to connected parties, though it continues to conduct private banking.

In 2015, Russian authorities opened a criminal investigation into allegations that directors of the bank, including Boris Bulochnik, had deliberately bankrupted Master-Bank. The Russian press has reported that Bulochnik had left Russia by this point, but that in 2016 the authorities arrested him “in absentia” intending to raise an Interpol notice.

Prior to this time Bogdanov had spent the early 2000s moving from country to country, arranging purchases of real estate, before arriving in Panama. In 2009, he registered what purported to be a Panamanian Internet advertising agency called Ads and PR. The company appeared to do almost no business, according to sources that worked in the same building in Panama.

According to Toronto-based Financial Crimes analyst Monte Friesner, a “convicted money launderer and former Central Intelligence Agency contractor”[32] who reportedly knew both Bogdanov and his business associate Ivan Kazanikov, told Global Witness that “Ads and PR was a front – their business was moving money and only for Russians.” Friesner also claimed that “at one point they asked me to move money for them, they were talking about laundering money.” Friesner reports that Bogdanov and Kazanikov were significant investors in the Trump Ocean Club project – Kazanikov bought “a good dozen” after bringing money into Panama to buy units.

Kazanikov said they bought units through Ventura Nogueira’s company: “Homes was the biggest company in Panama. We bought from Homes.” Of note, one of their purchases entitled Kazanikov to a position on the Trump Ocean Club’s “committee of merchants”, where he has served for five years as the vice-president and, alongside a Trump representative, as a member of the management team.[33]

David Murcia Guzmán

 

Another key player in the Trump Panama real estate project was David Murcia Guzmán. Guzmán had been selling pirated videos on the streets of Santa Marta, Colombia. But shortly after the US-backed Plan Colombia offensive displaced the FARC rebel and terror group from their position of being able to tax the drug trade in the Putumayo Department, Guzmán moved there, where he suddenly became wealthy and influential.  This was enabled through his company, DMG, an investment scheme that looked an awful lot like a Ponzi-style pyramid swindle. Eventually the Colombian authorities called it that. It should have collapsed under the weight of demands from later investors, but never did. There was always a lot of cash coming in. US authorities called it a drug money laundering scheme. Various Colombian media identified Murcia Guzmán as laundering funds for both the FARC and the Norte del Valle Cartel (AUC), leading to an even greater income for Guzmán.[34]

It should be noted that by that time the AUC had gained such an odious international reputation from a string of massacres that had placed it on the US list of terrorist organizations.[35]

According to Colombian media reports, a member of FARC, known for trafficking cocaine, invested in DMG. At that time, the US had labeled FARC as a terrorist organization. Colombian police had even announced that Guzmán himself had direct ties to the FARC.[36]

Since he couldn’t bring drug money to a bank, Guzmán did what many drug criminals do: He invested the cash in real estate, which makes illicit money much harder to track. One of his investments was in the Trump Ocean Club.

Guzmán is also known as the “Bernie Madoff of Colombia,”[37] having scammed 500,000 people, leading to the Colombian government forcing the closure of DMG on November 18, 2008.[38] On November 17, 2008, the Colombian authorities raided sixty DMG offices in 20 Colombian cities and ordered the company closed, because it was a pyramid scheme and a money laundering operation. Colombia’s attorney general said that DMG was run with “resources of illicit origin”. Colombian President Alvaro Uribe gave a television interview in which he accused DMG of “money laundering in relation to drug trafficking.” By the end of November, authorities had arrested Murcia Guzmán in Panama and his pyramid scheme at once collapsed, sparking protests across Colombia.[39]

On July 11, 2011 the New York Field Division of the Drug Enforcement Agency and Preet Bharara, the United States Attorney for the Southern District of New York sentenced Guzmán to nine years in prison for laundering money from narcotics trafficking.[40]

After serving six years of that sentence, Murcia Guzmán returned to Colombia, for another 22 years in prison.[41]

Guzmán bought his units at the Trump property with money smuggled into Panama by Colombian drug mules. Guzmán used DMG as a cover to launder millions of dollars from narcotics sales, some of which was concealed by real estate investments and secret companies, according to prosecutors. “Murcia Guzmán wove an intricate web of deception across continents to disguise his dirty drug money and support his lavish lifestyle,” said Preet Bharara in a 2009 announcement of his arrest.[42]

In 2013 Nogueira, in conversations secretly recorded by a former business partner, said he had performed money laundering as a service, moving tens of millions of dollars mainly through contacts in Miami and the Bahamas. “More important than the money from real estate was being able to launder the drug money – there were much larger amounts involved,” he said in the recording. “When I was in Panama, I was regularly laundering money for more than a dozen companies.” The recordings were heard by Reuters and authenticated by five people who know Nogueira.[43]

Salomón Shamah

Salomón Shamah, Panama’s tourism minister, worked with Trump and his family to help make the Panama Ocean Club a reality. Former US ambassador to Panama Barbara Stephenson said about Shamah, that he’s “suspected of links to drug traffickers” and those suspicions were such that Shamah, even when he held a high post in the Panamanian government, has been denied a visa to enter or travel through the United States. [94]

6.Russian Mob Back  Panama Project

In March, a Reuters review found that at least 63 individuals with Russian passports or addresses had bought $98.4 million worth of property in seven Trump-branded luxury towers in southern Florida. The buyers included well-connected businessmen and people from the second and third tiers of Russian power.[44] Donald Trump, Jr. told a real estate conference in 2008, “The emerging world in general attributes such brand premium to real estate that we are looking all over the place, primarily Russia. We are currently looking at potential deals… In Russia, I really prefer Moscow over all cities in the world… In Russia, if one has made money anywhere in the country, you would want your place in Moscow… over there because it is a question of who knows who, whose brother is paying off who, etc. It really is a scary place… And in terms of high-end product influx into the US, Russians make up a pretty disproportionate cross-section of a lot of our assets… We see a lot of money pouring in from Russia. There’s indeed a lot of money coming.”[45]

Nogueira’s Homes Real Estate Investment & Services accounted for up to half of the 666 Trump Ocean club apartment sales before the bond prospectus, according to people involved in the project. Eleanora Michailov, a Russian who settled in Toronto, Canada, was the international sales director for Homes. She recalled that Nogueira handled the sale of a third of the building, about 200 apartments. Another Homes sales agent, Jenny Levy, a relative by marriage to the developer, Khafif, said she alone sold 30 apartments. “We sold half the building, baby! Homes sold half,” Levy said in a phone interview. Nogueira said that he and his agents across the world sold between 350 to 400 apartment and hotel units. Khafif said he was unsure of the exact number, but Nogueira had sold up to 300 units. “Everybody was lining up to work with him … During those days he was the hottest real estate agency in town,” he said. Homes found a ready market in Russia. “Russians like to show off,” said Khafif, who went on several sales trips to Moscow. “For them, Trump was the Bentley” of real estate brands.[46]

In early 2007, they held a party at Trump’s Mar-a-Lago resort in Palm Beach, Florida to celebrate the Panama project. Donald Trump and his children, Donald Jr., Eric and Ivanka hosted guests that included Regis Philbin. Nogueira was also there and met Trump.[47]

Other guests included Russian investors, such as Alexander Altshoul, a foreign partner of Guzmán’s DMG,[48] who stated “Russians like their brand names,” referring to Trump. Altshoul, who holds Canadian citizenship, was listed on the Homes company website in 2007 as a “partner” and an “owner” of the firm. He became involved in Homes after moving to Panama from Toronto and investing with family and friends in the Trump project, paying deposits on 10 apartments and one hotel unit.

Police in Toronto filed charges in April 2007 against Altshoul, at the time he was promoting the Trump project. He was accused of involvement in a mortgage fraud scheme, unrelated to the Panama project that involved sending funds through Latvia. The criminal case was dropped a year later. In a statement, the Canadian government said it was “duty bound to withdraw charges where there is no reasonable prospect of conviction or if it is not in the public interest to proceed.” It did not elaborate further on the case. Altshoul said the decision showed he was innocent.[49]

Among Altshoul’s business partners was Arkady Vodovosov from Moscow, who was sentenced to five years in prison in Israel in 1998 for kidnapping, and for threats to kill and torture. Among his partners in that investment, according to Altshoul and Panamanian corporate records, was Arkady Vodovosov, from Moscow, who is a relative of Altshoul. Contacted by telephone, Vodovosov said inquiries about his involvement with the Trump project were nonsense. “We were in Panama for a very short time, and got out of there a long time ago,” he said, declining to answer further questions.[50]

Another Homes partner, Stanislau Kavalenka, invested in the Trump Panama project. Kavalenka was also a Canadian émigré from the former Soviet Union. At different times, Altshoul and Kavalenka each faced accusations of connections to organized crime, but prosecutors dropped the charges. Legal documents describe Kavalenka as a former pimp, arrested for kidnapping prostitutes. According to Ontario court documents,[51] Kavalenka was charged in Canada with several offenses, including “compelling” and “procuring” women to engage in prostitution. The case was withdrawn when the two women did not appear in court to give evidence against him.[52] In 2004, Canadian prosecutors had accused Kavalenka of pimping and kidnapping Russian prostitutes. Prosecutors dropped the case in 2005 after the alleged prostitutes, who were the main witnesses, did not show up in court. Kavalenka’s whereabouts are unknown. He did not respond to questions about his role in the Trump project sent to him through his family in Canada.[53]

7.Trump’s Panama Project: Double and Triple Selling the Same Real Estate

Following the Mar-a-Lago party, the Panama project “pre-sold 64% of the building’s condominium and commercial units” for profits of $278.7 million. The problem was that Nogueira was not just selling property to individuals. He was often selling the same condominiums to two or three different people.

Roniel Ortiz, the former lawyer for Murcia Guzmán and Nogueira, said of the Trump-branded project: “When the building was completed and people arrived to seek out their apartments, they ran into each other – two, three people who were fighting for the same apartment.”

Complaints against Nogueira, including allegations of fraud in Trump Ocean Club sales, resulted in four criminal cases against him in Panama and culminated in his arrest on fraud charges in May 2009. Nogueira said double sales occurred because of changes in the building specifications or clerical error. He said he never sold an apartment twice. He said that not everyone lost money from their investments, and most who did lost out because of poor or unlucky investment decisions. “If you are looking to make easy money from speculation, then you have to accept there is a risk,” he said.[54]

According to Nogueira, “I didn’t know the money was coming from anything illegal. As long as they were doing wire transfers and not cash, I wasn’t worried about the source…Nobody ever asked me. The banks didn’t ask. The developers didn’t ask. The Trump Organization didn’t ask me. Nobody asked me: Who are the customers? Where did the money come from? Anything I would say could also damage a lot of powerful people. I am not sure I should do that.”[55]

Mauricio Ceballos, a former financial crimes prosecutor in Panama who investigated Noguiera called the Trump property “a vehicle for money laundering.”[56] The disclosure forms Donald Trump filed with the Office of Government Ethics show he was earning management fees and royalties from the Trump Ocean Club. As of 2017, the documents show, he was paid as much as $13.9 million.[57]

By the time the Trump Ocean Club project was complete in 2011, many investors had withdrawn and lost their deposits rather than pay the 70 percent balance. Bond holders lost, too, after Khafif’s company, Newland, defaulted on payments and the bond was restructured. There was one person who still profited: Donald Trump. Whatever the losses investors might suffer, under Trump’s licensing deal, detailed originally in the bond prospectus, the Trump Organization was guaranteed to receive payment. Court records from Newland’s bankruptcy in 2013 indicate Trump agreed to reduce his fee, but that he still earned between $30 million and $50 million from lending his name to the project.[58]

8.Legal Experts on Due Diligence

Abraham Wallach, who worked for Donald Trump until 2002 as the Trump Organization’s executive vice president for development and acquisitions explained in an interview, that “anyone can become a Trump partner, as long as they’re willing to pay his fee.” Wallach himself is a testimony to that assertion. He had been arrested at least 15 times in five states, with four separate felony convictions — for crimes including forgery, grand larceny, and making false statements to prosecutors — and three jail sentences before being hired by Trump. He worked for the Trump Organization from 1990 to about 2001 or 2002.[59] Wallach added, “Donald doesn’t do due diligence on anything, no matter what it is,” Wallach said. “He works by his gut – his gut directs him on projects, on whatever he’s working on.” Wallach As far as Donald’s concerned, screw the partner as much as you can and don’t think about the future, just think about the present. Maximize what I get out of the deal, and go on from there.”[60]

Several legal experts say the episode raises questions about what steps Trump and the Trump Organization did to check the source of any income from the Ocean Club project. The Trumps do not to appear to have checked their business associate’s backgrounds. Eric Trump told Univision in 2011 that the company did not review each investor’s and broker’s past because involvement was limited to franchising the project under the Trump name. However, the Trumps also manage the hotel in Panama. “Why would we do a background check? If we did a background check, we could have a background check of every real estate broker in, all of Panama, and beyond,” replied Eric Trump.[61]

Arthur Middlemiss, a former Manhattan assistant district attorney and head of JPMorgan’s global anti-corruption program, says since Panama was “perceived to be highly corrupt,” and “any in business there should conduct due diligence on business partners. If not, they risked being liable for turning a blind eye to wrongdoing.”[62]

Jimmy Gurulé, a professor of law at the University of Notre Dame, Indiana, and a former under-secretary for enforcement at the U.S. Treasury Department (2001-2003), former Assistant Attorney General, US Department of Justice (1990-1992), and author of “Unfunding Terror: The Legal Response to the Financing of Terror,”[63] agreed. He also said any businessman should avoid working with “anyone with a potential link to criminality” as a matter of good ethics.[64]

Miguel Antonio Bernal, a professor of constitutional law at the University of Panama and a campaigner against corruption, said many buildings in Panama City were built specifically to be vehicles for money laundering; the Trump Ocean Club fits the mold. “There are more than 500 buildings like this,” he said. “But this – the difference of this – is that this has the name of the actual president of the United States.”[65]

Sarah Chayes, a corruption expert working with a group of lawyers trying to bring an unrelated case against the president for violating the Emoluments clause of the Constitution, found it troubling that the Trump Organization seemed to pay no attention to the shady backgrounds of its partners and clients. “Anyone who thinks members of FARC, that drug dealers, Russian oligarchs who have been looting their own country, represent normal business partners,” she said, “doesn’t quite understand the free enterprise system that I think is central to a healthy America.”[66]

Money laundering expert Alberto Ávila and Executive Director of COMLAFT in Mexico said that while Donald Trump is right to deny legal responsibility, he should be more careful about his investors “because at the end of the day it’s his name or his brand that is at play. … His lawyers at least should be telling him how to be careful.”[67]

Money laundering was a major focus of Robert Mueller’s investigation. Not only were most of the charges brought against Paul Manafort and Robert Gates connected to money laundering, expertise in the area was also the first thing that Mueller sought when assembling his team.[68]

Records show that more than 1,300 Trump condominiums were bought not by people, but by shell companies, and that the purchases were made without a mortgage, avoiding inquiries from lenders. Those two characteristics signal that a buyer may be laundering money, the Treasury Department has said in a series of statements since 2016. Treasury’s financial-crimes unit has, in recent years, launched investigations around the country into all-cash shell-company real-estate purchases amid concerns that such sales may involve money laundering. The department is considering requiring real-estate professionals to adopt anti-money-laundering programs. However, all-cash purchases by shell companies do not by themselves show illegal or improper activity, and they have become more common in recent years in both Trump buildings and other luxury home sales across the United States. Developers such as Trump have no obligation to scrutinize their purchasers or their funding sources[69].

9.Attempts to Distance Away From the Panama Project

The White House referred Reuters’ questions about the Trump Ocean Club development to the Trump Organization. Alan Garten, the Trump Organization’s chief legal officer said the Trump Organization’s role in the project “was at all times limited to licensing its brand and providing management services. As the company was not the owner or developer, it had no involvement in the sale of any units at the property.” [70] 

“You know Donald Trump. First it’s we, we, we, we, but after a while it’s me, me, me, me,” said Roger Khafif, who had the vision for the project and ran the company that developed the Trump resort. “That’s the art of the deal.”[71]

Khafif recalls that Trump wanted Ivanka to head the project.[72] Both Eric and Ivanka Trump went to Panama at least four or five times to promote the development, and conducted quality control and site inspections, according to a broker who worked for a real estate company doing business at the Trump Ocean Club. They attended marketing parties for the Trump Ocean Club, and Ivanka met with project brokers.[73]

While Donald Trump was not the owner of the Panama project, the Trump Organization took part in many details down to “choosing the furniture and fittings,” said Nogueira. Day-to-day they assigned the project to Ivanka, he said, adding: “I spoke to her a lot of times, a lot of times.” He also met Donald Jr. and Eric Trump.[74]  “The Trump Organization has to approve everything because of his name on the project.”[75]

The Trump Organization told NBC News “the company was not responsible for the financing of the project and had no involvement in the sale of units or the retention of any real estate brokers.”[76] However, to make sure the hotel meets Trump’s quality standards, Delaware-based Trump Panama Hotel Management LLC manages the hotel operations. And K Group owned by developer Newland, pays Trump Marks Panama about $5 million annually for the Trump name, the then candidate’s financial disclosures show.[77]

According to news reports, Ivanka Trump did not respond to requests for her comments on Nogueira. Alan Garten characterized any contact between Nogueira and the Trump family as “meaningless.” He said such meetings and events “may have been memorable” for Nogueira, but for the Trump family it would have been “just one of literally hundreds of public appearances they were asked to make that year.” He added that, “No one at the Trump Organization, including the Trump family, has any recollection of ever meeting or speaking with this individual.”[78] 

Despite efforts to distance the Trump family from Nogueira, by trying to cast any meetings as “meaningless” the fact remains that Ivanka and both of Trump’s sons appeared at multiple public launch events for the Panama property. Ivanka herself filmed promotional videos for the project, including one that features both Nogueira and Ivanka. According to Nogueira, Ivanka helped arrange access to Trump Tower in New York for the video sequences, adding, “In this video we made, I was talking and she was talking.”[79] In a promotional video Ivanka praises “the beautiful pool decks” and “our 10,000-square-foot” spa. “Buenos días,” she says in the video. “Hello, I’m Ivanka Trump. Welcome to Trump Ocean Club International Hotel and Tower, Panama, rising 70 stories above the glistening Panama Bay. We’ve taken inspiration from the beauty that surrounds us to create a new landmark for Panama.” She discussed such details as the “tropical color palette” and the carvings on the guestroom headboards.[80]

Panama’s President Ricardo Martinelli attended the grand opening. Photographers captured the moment, showing Donald Trump grinning alongside President Martinelli at the Trump property in Panama.

By 2014, Juan Carlos Varela succeeded Martinelli. Martinelli had taken up residence in Miami, Florida. In May 2017, INTERPOL issued a warrant for Panama’s former president, suspected of embezzling $45 million. US Marshals arrested him on June 12, 2017.[81]

In a promotional video ahead of the opening on July 6, 2011, Trump said he fell in love with the country during one of the Miss. Universe contests he owned. “And we’re now doing a great, great project in Panama that’s selling like hotcakes, and I think it’s one of the most beautiful buildings in the world,” Trump said, speaking in the collective and sounding like an investor. “So I’m really honored to be involved in Panama.”[82]

Garten also stated that the Trump Organization “never had any contractual relationship or significant dealings” with Nogueira. However, Nogueira eventually sold nearly half the condos in the property. Eric Trump responded that Nogueira had been an unaffiliated salesman. “I looked and I’ve never heard the name, nor does it appear in our database. What I found out was [Nogueira] owns a real estate agency in Panama that sells apartments in our building as a third party.” Asked in November 2017 about Eric Trump’s response, the Trump Organization said the company never had any ties to Nogueira or awareness of him.[83] Many of the tenants were Russian criminals and other shadowy individuals. Garten said the scrutiny of Trump’s business ties with Russia was misplaced and that the story was “overblown.”[84]

Worst of all, the Trump Organization received a percentage of the financing it helped secure, and a cut on the sale of every unit at the development.[85] So ultimately, it is highly likely that Donald Trump made millions of dollars from the Panama property, from cash being laundered by drug cartels and the criminal underworld of both South America and Russia. If this had been a used car dealership in the US that brought a fortune by double and triple selling vehicles, the police would become very interested. Had investigators found most of the inventory was stolen or obtained from illegal drug sales, it is difficult to see how anyone making millions from such a business would be immune from prosecution. If the fictitious car dealership’s adult children helped design and promote the operation, and also pocketed millions, they too would be seen as complicit in the criminal operation. [86]

What we know is that the deal was very lucrative. The Trump Organization was entitled to an upfront $1.2 million licensing fee and one percent of any financing it helped to secure. The Newland bonds sales prospectus shows that the Trump Organization was in line for a cut of every unit sold. Overall, the Trump Organization stood to gain $75.4 million from the Trump Ocean Club by the end of 2010.[87]

10.Trump’s Panama Property Listed in Panama Papers

The Panama Papers are 11.5 million leaked documents detailing financial and attorney–client information for over 200,000 offshore entities. Some documents some date to the 1970s, were created by, and taken from, Mossack Fonseca, a Panamanian law firm, and were leaked in 2015 by an anonymous source. The documents contain personal financial details on wealthy individuals and public officials that were private. While offshore business entities are legal, reporters found some shell companies were used illegally, including fraud, tax evasion, and evading international sanctions.

Despite being a third party, Nogueira and his partners played a major part in the Trump project’s success, according to interviews with former key staff at Homes, developers, investors and lawyers, and an analysis of Panama corporate records and other public documents. The Trump name shows up on 3,540 of the leaked Panama Papers documents (see sidebar), many highlighting what has become a business model. Some Trump’s associates and business partners are also in the files.  However, the Trump Organization does not appear to be the direct owner of any offshore company formed by Mossack Fonseca, the Panamanian law firm now subject to multiple investigations after its documents were leaked.

Over decades Trump has built a sprawling global real-estate empire, along with clothing lines and even a now-defunct university program that bears his name. So it’s no surprise that his business partners might appear in the documents that leaked from Mossack Fonseca. Trump’s ties to people in the documents or their offshore companies are often indirect, associations with people who turn up in the offshore world.[88]

An industrial engineer, Carlos Saravia was Newland’s chief operating officer for the Trump-named Panama resort project. Reached by phone, the Colombian businessman first denied ever working with the Panama Papers law firm. But when confronted with his email exchanges with Mossack Fonseca lawyer Ramses Owens, Saravia offered that maybe the Panamanian firm pitched its services to the Trump-named project. “Because they offered, and we received them, and we heard them out and that’s it,” he said. “We solicited bids from various Panamanian firms.” The emails show Saravia reached out to Mossack Fonseca, even agreeing to pay travel expenses up to $2,500 for each of two Mossack Fonseca lawyers.[89]

In 2006 and 2007, Panama corporate records show, at least 131 holding companies having various combinations of the words “Trump” and “Ocean” in their name – for example, the Trump Ocean 1806 Investment Corp – was registered in Panama for pre-sales deals, and by the Homes group. 

Most times the identity of the buyers was not clear. Nogueira and other Homes staff involved said Panamanian law imposed no obligation to verify the identity of owners.

Nogueira said most of his clients never intended to live in the Trump Ocean Club.[90]

Trump partners or customers who appear in the leak of Mossack Fonseca documents now avoid association with the beleaguered Panamanian law firm. Khafif, the resort developer, appears by name 118 times in the leak, in contracts to buy specific units. Khafif worked on the other side of Mossack Fonseca lawyers to close sales. “That’s it. We have no relationship with Mossack Fonseca,” Khafif insisted, “I don’t know them.” However buyers of these units, some of them Americans, were often using offshore companies set up by Mossack Fonseca. They sometimes made payments through the firm’s trust service. One such offshore company was Trump Ocean Club Unit 2710 Inc., registered on May 7, 2007. Its shareholders included Connecticut lawyer Carlton Hume, who couldn’t remember why he and partners tapped Mossack Fonseca to create his offshore company before they built the project. “They were obviously pitching stuff to folks in the U.S. to buy in their development,” Hume said. “If I had to guess, I would guess that it was the developer who recommended them to us.” While the documents show they formed an offshore company in Panama to buy the unit, Hume said they backed out when the project appeared to be in trouble.[91]

Two of the complaints seen by Reuters were in the “Panama Papers,” documents from a local law firm that were leaked to the Süddeutsche Zeitung and the International Consortium of Investigative Journalists.[92]

They bought and sold many of the units through anonymous shell companies, according to Panamanian office of public records office documents. Norugiera says he set up hundreds of those corporations, charging roughly $1,000 each.[93]

11. Internal Memos and Conference Call Transcripts

(01) Conference Call Results, June 2009 – August 2009

(02) Firman Enmienda Garantia octubre 2015

(03) Republica de Panama Superintenencia de Mercado de Valores, December 31, 2010

(04) Republica de Panama Superintenencia de Mercado de Valores, October 11, 2000

(05) Republica de Panama Superintenencia de Mercado de Valores, October 11, 2000

(06) Republica de Panama Superintenencia de Mercado de Valores, October 11, 2000

(07) Republica de Panama Superintenencia de Mercado de Valores, October 11, 2000

(08) Trump Organization, Management Discussion on Results and Operations, December 31, 2009

(09) Republica de Panama Superintenencia de Mercado de Valores, December 31, 2017

(10) Republica de Panama Superintenencia de Mercado de Valores, October 11, 2000

(11) Newland_International_Properties_Memo, September 19, 2011

(12) Trump Organization Quarterly Conference Call for Investors, March 31, 2009

(13) Trump Organization Quarterly Conference Call for Investors, June 30, 2010

(14) Trump Organization Quarterly Conference Call for Investors, September 30, 2009

(15) Newland International Properties Group: Hechto de Importantancia

(16) Hecho De Importancia Newland International Properties, Corp.

12. Link Analysis

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