Even without obstruction of justice, the money laundering, and the self-dealing that seems to be evident in so many places, the fall of the house of Trump could come down to violations of the FCPA.
"I have thought for a very long time that the President, as a real estate developer, had violated what's called the Foreign Corrupt Practices act," says Rep. @JackieSpeier.
— New Day (@NewDay) February 7, 2019
Adam Davidson’s story may yet come back to haunt Individual-1 on violations of the The Foreign Corrupt Practices Act, because like the joke about sharks and lawyers, Trump ignoring signs of corruption was a professional courtesy.
(2017) Trump, at the time, was obligated to do due diligence to ensure that the Mammadov company was not corrupt. Trump either did not do the due diligence or ignored the results. The circumstances of the contracts, alone, should have given rise to suspicion. As Davidson writes, “given the Trump Organization’s track record, it seems reasonable to ask whether one of the things it was selling to foreign partners was a willingness to ignore signs of corruption.” In his summary, Davidson notes: “The best way to determine if a crime was committed in the Baku deal would be a federal investigation, which could use the power of subpoena and international legal tools to obtain access to the contracts, the due diligence, internal e-mails and financial documents. The Department of Justice routinely sends investigators to other countries to pursue possible F.C.P.A. and sanctions violations.”
(2018) Trump has repeatedly denied having any business deals inside Russia, but money from the former Soviet Union was used to finance some of his branded properties, including the Trump Soho in New York and the Trump International Hotel and Tower in Toronto. (Both properties have since changed their names.)
In addition, the Trump Organization has marketed and sold numerous properties to wealthy people from the former Soviet Union.