The New York Post’s recent revelations (sourced from emails, files, and other documents on Hunter Biden’s laptop) pointing to a massive behind-the-scenes influence-peddling operation involving members of the Biden family (as reported hereherehere, and here) were dramatically confirmed by Tony Bobulinski during an interview with Tucker Carlson on Oct. 27.

Bobulinski Speaks to Tucker Carlson

Bobulinski, one of Hunter Biden’s business partners, stated that he was vetted by Joe Biden to run the Biden’s China business in two separate meetings. Bobulinski further stated that as part of the initial deal, the Chinese company CEFC which is involved in the partnership with the Bidens, sent $10 million to JP Morgan-Chase to capitalize on the new joint company BHR Partners. Half of the money was the Chicoms’ capitalization investment in BHR, and the other $5 million was provided as an unsecured loan direct to the Biden family. After the money was transferred, BHR was founded to include two U.S. entities: Thornton Group LLC and Rosemont Seneca Partners. (Hunter Biden was a founding partner of the latter.) Bobulinski also stated that his partners James Gilliar and the Biden family also had business dealings in Oman, Luxembourg, Romania, France, and Kazakhstan and that the only qualification they had in those dealings was trading on the Biden name.

Follow the Money

Many independent journalists are examining the obvious corruption and influence-peddling aspects of the scandal as well as Joe Biden’s past denial of knowledge of those activities and their potential impact on the 2020 election. Others, such as Bob Anderson at The Federalist, have been attempting to find out where all the money went. As Anderson reported on Oct. 28:

  • While former Vice President Biden did release his federal tax returns from 2016-2019, these are essentially shell documents with no detail regarding the majority of his income earned since leaving office. In total, $13.5 million of Joe and Jill Biden’s $17 million flowed to their tax returns via upstream S corporations CelticCapri Corp (his), and Giacoppa Corp (hers), with more than 90 percent from his entity.
  • Prior news reports rationalized the Bidens’ use of S corporations as a means of reducing their Social Security and Medicare taxes, a common tactic of taxpayers with substantial income from non-W-2 sources. At this time, however, we can’t determine if any foreign income was reported through CelticCapri.
  • We also don’t know how much income from foreign sources has flowed through Hunter Biden’s bank accounts.
  • Multiple law enforcement sources recently confirmed that the FBI seized Hunter Biden’s laptop in late 2019 as part of a federal money laundering investigation, although the agency declined to move forward reportedly based on how the material was obtained.

Where did all the money go from these various Biden family (and associates) foreign business adventures? Did some of that foreign money flow into Joe Biden’s own S corporations? What is the status of the federal money-laundering investigation now that Bobulinski has come forward with his own evidence and files to augment the information found on Hunter Biden’s laptop? Does the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) have records of some of the relevant financial transactions that would be direct evidence of money laundering?

The FinCEN

Here is the original purpose of the FinCEN from the agency’s history posted here as stated in 1970:

Our overall aim is to build a system to combat organized crime and white-collar crime and to deter and prevent the use of secret foreign bank accounts for tax fraud and their use to screen from view a wide variety of criminally related financial activities, and to conceal and cleanse criminal wealth.
Statement of Eugene T. Rossides, former Assistant Secretary of the Treasury for Enforcement and Operations
Senate Hearing on Foreign Bank Secrecy June 9, 1970

The agency was not formally established until 1990 when the mission functions that were dispersed in various Treasury Dept. organizations were consolidated into the FinCEN. The mission was later modified by the 2001 Patriot Act to include requirements to track terrorist funding worldwide. Here is today’s FinCEN mission statement:

The mission of the Financial Crimes Enforcement Network is to safeguard the financial system from illicit use, combat money laundering and its related crimes including terrorism, and promote national security through the strategic use of financial authorities and the collection, analysis, and dissemination of financial intelligence.

The FinCEN derives its authority through enforcement of the Bank Secrecy Act of 1970, which was originally passed “to prevent financial institutions from being used as tools by criminals to hide or launder their ill-gotten gains.”

The law requires banks and other financial institutions to provide documentation, such as currency transaction reports, to regulators. Such documentation can be required from banks whenever their clients deal with suspicious cash transactions involving sums of money in excess of $10,000. The act grants authorities the ability to more easily reconstruct the nature of the transactions.

Two key tools are used by the FinCEN to track large and/or suspicious financial transactions: The Currency Transaction Report (CTR), and the Suspicious Activity Report (SAR). CTRs are standard reports by banks and other financial institutions of all transactions over $10,000. SARs are filed when banks and other financial institutions suspect suspicious activity in a given account. The SAR initiates an investigation by the FinCEN, with a goal of identifying bank customers who are involved in money laundering, fraud, or terrorist funding. Banking customers are not required to be informed that CTRs are filed (the CTR is common knowledge and common practice), but a SAR is filed if a customer is informed and then declines to complete the transaction. Here is where it gets interesting:

Not all transactions greater than $10,000 need to be reported with a CTR. Recent legislation has identified certain groups known as “exempt persons.”

The three categories of “exempt persons” are:

  • Any bank in the United States.
  • Departments or agencies that fall under federal, state, or local governments, including any organization that exercises government authority.
  • Any corporation whose stock is traded on the NYSE, Nasdaq, and American Stock Exchange (excluding stocks listed on the Emerging Company Marketplace and under the Nasdaq Small-Cap Issues heading).

Speculation

That “exempt persons” business means that a lot of financial transactions of greater than $10,000, made by customers like the Bidens and their business associates through the exempted groups, are simply not reported. What is the likelihood that SARs are ever initiated by banks doing business with and for U.S. politicians? Probably only those transactions to and from foreign banks known for or suspected of money laundering in countries like those mentioned by Bobulinski in his interview with Tucker Carlson. Luxembourg is a red flag in that regard. Hunter Biden has also been linked to financial transactions with Ukrainian, Russian, Kazakh, and Chinese nationals. Are there other SARs being examined by the FinCEN as part of the FBI-led joint task force investigating Hunter Biden’s money laundering? Almost certainly. Look for past Latvian and Cyprus bank transactions to be discovered, too.

Then there is this bank transaction record from April 2014 that includes Privat Bank (Ukraine/Burisma). Morgan-Stanley is an investment bank focusing on “capital investments and wealth management” that handled Rosemont Seneca (Hunter Biden’s company). These payments from Privat were recorded monthly.

Here’s a statement from April 2014 showing transactions received from Privat (Hunter’s monthly Burisma retainer fee) and also Deutsche Bank (Germany). Note the latter transaction is more than $3 million. What was the original source of those funds? Kazakhstan? Or was that part of the $3.5 million received from the wife of the former mayor of Moscow?

What other bank records are there that show Hunter Biden’s financial transactions with different foreign banks? What previously filed SARS on Chinese financial transactions with the Bidens does the FinCEN have in hand? There is an active investigation currently underway to unravel the money laundering operations that may have supported the Bidens’ overseas business empire. And the FinCEN has everything.

In reality, the FinCEN collects ALL financial data: holdings, transfers, income, outflow, savings account data (virtually EVERYONE’S savings and expenditures). It was being collected worldwide long before NSA started vacuuming up phone and internet data. How is this information collected? Some is cooperative through treaties via CTRs and SARs while others are collected through NSA general collections, which are automatically scoured for banking data. In hostile or non-cooperative countries, the monthly data is turned over via recruited assets and forwarded to the receiving U.S. agencies. This kind of collection is important and is one of the reasons HUMINT (human intelligence) will never be obsolete. The financial collections run alongside collections of phone/cell data. (Referred to as “tapes” due to the media when the programs started, but now usually hard drives or via insertion of Trojan Horse “taps.”) Correlating the two collection streams is undoubtedly the kind of investigative action that is well underway by that joint FBI task force with FinCEN participation.


The 2016 movie The Accountant, starring Ben Affleck as an autistic hitman, provided a stylized Hollywood version of FinCEN operations and capabilities. Some $2 trillion worth of FinCEN files from 2000-2017, however, were recently leaked that gave a real glimpse into how criminals move and launder money through the international banking system. There is a high probability that some of those files contained information linked to key figures in the U.S. political class. But those 2,500 or so files that were leaked are only a tiny fraction of what the FinCEN has in its databases. What else does the FinCEN have that can connect the dots on the financial transactions of the Biden family’s overseas businesses? Did Joe Biden’s S corporations receive any of that foreign money?

The Bottom Line

There is a LOT of financial transaction information available at the FinCEN, and the real task is compiling it in a way that correlates those transactions and associated personal communications to illuminate the scheme and plan(s) being executed by the perpetrators. The status of the money laundering investigation involving the Bidens must be publicly pursued by the Senate Banking, Homeland Security, and Judiciary Committees after the election. After the nearly year-long investigation by the FBI’s joint task force, some conclusions should be available and forthcoming to the public. (Developing)

 

Stu Cvrk served 30 years in the U.S. Navy in a variety of active and reserve capacities, with considerable operational experience in the Middle East and the Western Pacific. An oceanographer and systems analyst through education and experience, Stu is a graduate of the U.S. Naval Academy, where he received a classical liberal education. This functions as the key foundation for his political commentary. He threads daily on Twitter on a wide range of political topics, such as the military, foreign policy, government, economics, and world affairs. Twitter: @STUinSD

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