do City project, including a Trump International Resort, Trump International Golf Club, and Trump Residences Lido.[11]  Documents show that the Trump Organization and President Trump’s sons were directly involved in planning the project and the Trump Organization was paid almost $3.7 million in licensing and consulting payments by MNC.[12] 

 

These circumstances raise the specter that the Trump Organization may have leveraged the Office of the President and the diplomatic relationship between the United States and China to advance the company’s private interests in Indonesia and elsewhere.  We note that President Trump never divested his holdings in the Trump Organization, and that the company continues to be managed by members of the President’s family.  Any use of public office for private gain may violate both federal law and ethics regulations,[13] and would certainly merit further investigation.

 

MNC’s 2017 Annual Report highlights the importance of the Lido City project’s association with President Trump’s brand. The project is described as “an exclusive community bearing the prestigious Trump name synonymous with quality and luxury” and “a collaboration between MNC Land and Trump Hotel Collection to deliver the first resort in Asia bearing the Trump brand.”[14] 

 

In light of these concerns, we respectfully request you provide, in a timely manner and in any event no later than June 14, 2018, answers and supporting documentation to the following questions:

 

§  Has the Commerce Department communicated with the President of China or any other political figures in China, with regards to Trump Organization projects in Indonesia or China, including MNC Lido City and MNC Bali Resort?  If so please provide copies or describe the nature and context of any such communications.

§  Has the Commerce Department communicated with the President of China or any other political figures in China, with regards to any other of the Trump Organization’s overseas projects?  If so please provide copies or describe the nature and context of any such communications.

§  Has the Commerce Department communicated with the President of Indonesia or any other political figures in Indonesia, with regards to Trump Organization projects in Indonesia, including MNC Lido City and MNC Bali Resort?  If so please provide copies or describe the nature and context of any such communications.

§  Has the Trump Organization, any individual or organization representing the Trump Organization, communicated with the Commerce Department since the funding for the MNC Lido City project was secured in May 2018?  If so please provide copies or describe the nature and context of any such communications.

§  Has the Trump Organization, any individual or organization representing the Trump Organization, communicated with the Commerce Department on matters related to MNC Lido City or MNC Bali Resort?  If so please provide copies or describe the nature and context of any such communications.

§  Has the President, any employee of the White House, or any official or unofficial adviser to the President communicated with any Commerce Department employee regarding MNC Lido City or MNC Bali Resort?  If so please provide copies or describe the nature and context of any such communications.

 

We would appreciate your prompt attention to this matter.

 

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[1] Jack Crowe, China contributing $500 million to Trump-linked project in Indonesia, Nat’l Rev., May 14, 2018.

[2] Deirdre Tynan, Chinese telecoms may be spying on large numbers of foreign customers, The Atlantic, Feb. 16, 2012.

[3] Worldwide Threats Hearing: Hearing before the S. Select Comm. on Intelligence, 115th Cong. (Feb. 2018) (statement of Christopher Wray, Director of the Fed. Bureau of Investigation) (“The capacity [of Huawei or ZTE] to exert pressure or control over our telecommunications infrastructure, it provides the capacity to maliciously modify or steals information and provides the capacity to conduct undetected espionage.”).

[4] Hearing to review the FY2019 Budget Request for the Federal Bureau of Investigation before the S. Comm. on Appropriations, Subcomm. on Commerce, Justice, Science, and Related Agencies, 115 Cong. (May 2018) (statement of Christopher Wray, Director of the Fed. Bureau of Investigation).

[5] Nomination of William R. Evanina to be Director of National Counterintelligence and Security Center: Hearing before the S. Select. Comm. on Intelligence, 115th Cong. (May 15, 2018) (Mr. Evanina, when questioned on ZTE stated he would never use a ZTE device nor would he recommend senior government officials to use them.); see also Martin Matishak, Counterintelligence chief warns against using ZTE products, Politico, May 15, 2018.

[6] Hamza Shaban, Pentagon tells U.S. military bases to stop selling ZTE, Huawei phones, Wash. Post, May 2, 2018.

[7] Damian Paletta et al., Penalties against China telecom giant ZTE become a bargaining chip as White House, Chinese officials discuss potential trade deal, Wash. Post, May 13, 2018.

[8] David Meyer, One of the world’s biggest phone firms is stopping operations because of a ban on buying U.S. parts, Fortune, May 10, 2018 (“as a result of the U.S. ‘denial order, the major operating activities of the company have ceased’”).

[9] S.V. Date, Trump orders help for Chinese phone-maker after China approves money for Trump project, Huffington Post, May 14, 2018.

[10] Ben Dooley & Albee Zhang, Trump Indonesia project is latest stop on China’s Belt and Road, Agence France-Presse, May 11, 2018 (updated May 15, 2018).

[11] Id. See also MNC Land, Annual Report 2017 (Apr. 6, 2018), http://www.mncland.com/beta/en/investor-relations/annual-report/.

[12] Id.

[13] See 18 U.S.C. § 208 and 5 C.F.R. § 2635.702.

[14] MNC Land, Annual Report, pp. 31-33.