Secret Side Iran Deals Revealed and Confirmed

Note: Further side deals may occur and hat tip to Reuters. Expect immediate hearings when Congress returns. There is no shame with this administration including Barack Obama, John Kerry and Ben Rhodes.

JCPOA Exemptions Revealed

INSTITUTE FOR SCIENCE AND INTERNATIONAL SECURITY

REPORT

By David Albright and Andrea Stricker

September 1, 2016

The Joint Comprehensive Plan of Action (JCPOA) placed detailed limitations on facets of Iran’s nuclear program that needed to be met by Implementation Day, which took place on January 16, 2016.1 Most of the conditions were met by Iran. However, we have learned that some nuclear stocks and facilities were not in accordance with JCPOA limits on Implementation Day, but in anticipation the Joint Commission had earlier and secretly exempted them from the JCPOA limits. The exemptions and in one case, a loophole, involved the low enriched uranium (LEU) cap of 300 kilograms (kg), some of the near 20 percent LEU, the heavy water cap, and the number of large hot cells allowed to remain in Iran. One senior knowledgeable official stated that if the Joint Commission had not acted to create these exemptions, some of Iran’s nuclear facilities would not have been in compliance with the JCPOA by Implementation Day.

1 The Institute for Science and International Security was neutral on whether or not the JCPOA should be implemented.

Recently the Joint Commission created a Technical Working Group to consider further exemptions to Iran’s stock of 3.5 percent low enriched uranium. This cap is set at 300 kg of LEU hexafluoride but Iran apparently has or could exceed the cap if no further exemptions are granted by the Joint Commission.

The decisions of the Joint Commission have not been announced publicly. The Obama administration informed Congress of key Joint Commission decisions on Implementation Day but in a confidential manner. These decisions, which are written down, amount to additional secret or confidential documents linked to the JCPOA. Since the JCPOA is public, any rationale for keeping these exemptions secret appears unjustified. Moreover, the Joint Commission’s secretive decision making process risks advantaging Iran by allowing it to try to systematically weaken the JCPOA. It appears to be succeeding in several key areas.

Given the technical complexity and public importance of the various JCPOA exemptions and loopholes, the administration’s policy to maintain secrecy interferes in the process of establishing adequate Congressional and public oversight of the JCPOA. This is particularly true concerning potentially agreement-weakening decisions by the Joint Commission. As a matter 2 | P a g e

of policy, the United States should agree to any exemptions or loopholes in the JCPOA only if the decisions are simultaneously made public.

Exemptions

The exemptions in effect on Implementation Day include:

1) Allowing more than 300 kg of about 3.5 percent low enriched uranium hexafluoride or equivalent mass if the LEU was in the following forms:

 Low level solid waste;

 Low level liquid waste; and

 Sludge waste.

The amount of LEU hexafluoride equivalent involved in this exemption is unknown, although these amounts if not exempted would have placed Iran over the 300 kg cap, according to one knowledgeable senior official.

2) Near 20 percent LEU in “lab contaminant” that was judged as unrecoverable. Iran had agreed in the JCPOA that all near 20 percent LEU would be in fuel elements; subsequently modified to irradiated fuel elements, albeit in many cases only lightly irradiated. The amount of LEU in the lab contaminant is unknown. The basis for judging the near 20 percent LEU unrecoverable is not known.

3) A number of large hot cells. Under the JCPOA, Iran committed for 15 years to only develop, acquire, build, or operate hot cells (containing a cell or interconnected cells), shielded cells or shielded glove boxes with dimensions less than 6 cubic meters.2 The reason is that hot cells with these dimensions could not in practical terms be used in plutonium separation efforts involving irradiated fuel. The JCPOA also stated that larger hot cells could be operated with the approval of the Joint Commission. However, prior to Implementation Day, the Joint Commission agreed to allow Iran to continue operating 19 large hot cells in three Tehran locations and one Karaj location which are in excess of the six cubic meter limitation. Although the hot cells are used in the production of medical radionuclides they can be misused for secret, mostly small-scale plutonium separation efforts and raise serious questions over the rigorousness of this JCPOA exemption on hot cells. A related question is whether the International Atomic Energy Agency (IAEA) regularly inspects all these exempted hot cells. Moreover, Iran is

2 According to the JCPOA, “For 15 years, Iran will only develop, acquire, build, or operate hot cells (containing a cell or interconnected cells), shielded cells or shielded glove boxes with dimensions less than 6 cubic meters in volume compatible with the specifications set out in Annex I of the Additional Protocol. These will be co-located with the modernised Arak research reactor, the Tehran Research Reactor, and radio-medicine production complexes, and only capable of the separation and processing of industrial or medical isotopes and non-destructive PIE. The needed equipment will be acquired through the procurement mechanism established by this JCPOA. For 15 years, Iran will develop, acquire, build, or operate hot cells (containing a cell or interconnected cells), shielded cells or shielded glove boxes with dimensions beyond 6 cubic meters in volume and specifications set out in Annex I of the Additional Protocol, only after approval by the Joint Commission.” 3 | P a g e

 

believed to be seeking to exploit this exemption as a precedent to further increase its number of hot cells with volumes greater than six cubic meters.

Heavy Water Loophole

The Joint Commission also decided on or prior to Implementation Day that Iran would be allowed to export heavy water in excess of the JCPOA’s 130 tonnes cap for sale on the open market even though Iran did not have a buyer for this heavy water. The Joint Commission allowed Iran to store large amounts of heavy water in Oman that remained under Iran’s control, effectively allowing Iran to exceed its cap of 130 tonnes of heavy water as it continues to produce heavy water at its Arak facility.3 As discussed in an earlier Institute report, this heavy water loophole in the JCPOA was poorly considered.4 As discussed in the report, the Institute learned that the Department of Energy’s purchase of 32 tonnes of this heavy water unfairly disrupted and negatively affected a nascent, needed North American supply chain of heavy water. The Institute warned that the loophole also risked legitimizing Iran as a nuclear supplier when it had done nothing yet to prove it would abide by international norms relating to nuclear trade or halt illicit nuclear procurements. Moreover, the deal will only encourage Iran to continue exceeding the JCPOA heavy water cap for financial gain. One surprising development is that the Arak heavy water production plant produced significantly more heavy water than expected during several months following Implementation Day. Arak produced at a rate exceeding 25 tonnes per year, compared to the expected rate of 16 tonnes per year expected prior to Implementation Day.

3 One reviewer raised the question of whether this precedent could be applied to LEU, where it would be located outside of Iran even though no buyer had been found.

4 Albright and Stricker, “U.S. Purchase of Iran’s Heavy Water: Discouraging a Dangerous Nuclear Supplier,” Institute Report, May 23, 2016. http://isis-online.org/uploads/isis-reports/documents/Heavy_Water_Purchase_23May2016_final.pdf

5 David Albright, “Update on Iran’s Stocks of 3.5 Percent Low Enriched Uranium: Blocking unjustified exemptions to the 300 kilogram cap,” Institute Report, May 23, 2016, Rev. May 27, 2016. http://isis-online.org/uploads/isis-reports/documents/Update_on_Irans_Stocks_of_35_Percent_LEU_May_23_2016_Final_rev_may_27_2016.pdf

Newly Formed LEU Exemption Working Group

In July 2016 the Joint Commission established a Technical Working Group to evaluate, apparently among other stocks, the fate of approximately 100-200 kg of less than 3.67 percent LEU in the Enriched UO2 Powder Plant (EUPP).5 This plant converted LEU hexafluoride into uranium oxide and has been mothballed under the JCPOA. Although almost all of the LEU oxide produced at this plant was shipped out of Iran, a fraction was left in the process lines and tanks on Implementation Day. This LEU was not exempted on Implementation Day and was counted as part of the 300 kg LEU cap.

Russian Permanent Representative to the International Organizations in Vienna Vladimir Voronkov told TASS in July 2016 prior to an impending Joint Commission meeting: “There are two issues that need to be addressed. These are the difficulties with enriched uranium 4 | P a g e

accumulated during the enrichment in the pipes and other devices. What has been discovered exceeds the allowed limit of 300 kilograms. And the second issue is heavy water.”6

6 “Meeting of Iran-P5+1 commission on nuclear deal to be held in Vienna July 19,” TASS Russian News Agency, July 14, 2016. http://tass.ru/en/world/888165

7 With regard to domestic fuel fabrication, the JCPOA states: “Enriched uranium in fabricated fuel assemblies and its intermediate products manufactured in Iran and certified to meet international standards, including those for the modernised Arak research reactor, will not count against the 300 kg UF6 stockpile limit provided the Technical Working Group of the Joint Commission approves that such fuel assemblies and their intermediate products cannot be readily reconverted into UF6. This could for instance be achieved through impurities (e.g. burnable poisons or otherwise) contained in fuels or through the fuel being in a chemical form such that direct conversion back to UF6 would be technically difficult without dissolution and purification. The objective technical criteria will guide the approval process of the Technical Working Group. The IAEA will monitor the fuel fabrication process for any fuel produced in Iran to verify that the fuel and intermediate products comport with the fuel fabrication process that was approved by the Technical Working Group.”

It is unknown if the Joint Commission has decided to allow Iran to exceed the 300 kg cap while the Technical Working Group evaluates this issue. However, the pattern that appears to have emerged is that Iran will likely move to violate the cap if it is not granted an exemption.

The JCPOA is silent on the issue of exempting from the 300 kg cap already existing LEU that had been produced in Iran. In fact, US officials told Institute staff in the summer of 2015 that Iran was fully expected to empty the EUPP of LEU and send it all out of the country or dilute it to natural uranium.

Although the JCPOA explicitly created exemptions to the 300 kg cap, such as Russian designed, fabricated and licensed fuel assemblies for use in Russian-supplied reactors in Iran, these exemptions do not appear to cover the exemption of any remaining LEU in the EUPP. According to the JCPOA, “All enriched uranium hexafluoride in excess of 300 kg of up to 3.67% enriched UF6 (or the equivalent in different chemical forms) will be down blended to natural uranium level or be sold on the international market and delivered to the international buyer in return for natural uranium delivered to Iran.”

The JCPOA envisions that Iran may make LEU fuel domestically in the future and contains a mechanism to exempt that LEU from the cap as long as Iran meets stringent conditions. To that end, the JCPOA states: “The Joint Commission will establish a Technical Working Group with the goal of enabling fuel to be fabricated in Iran while adhering to the agreed stockpile parameters (300 kg of up to 3.67 % enriched UF6 or the equivalent in different chemical forms).” However, the exemptions specified in the JCPOA are intended for future fuel fabrication, and do not appear applicable to LEU processed in the EUPP prior to Implementation Day.7 The JCPOA intended that existing, domestically produced LEU enriched up to 3.67 percent would be subject to the 300 kg cap and not exempted.

However, the Joint Commission has taken a different approach and has already exempted existing LEU as part of bringing Iran into compliance with the JCPOA on Implementation Day. Moreover, it did so without relying on the Technical Working Group as called for in the JCPOA. 5 | P a g e

Now, there is concern that the newly formed Technical Working Group will lay the basis to exempt more LEU from the cap. Moreover, the intention appears to be to conduct these discussions and the associated decision making about LEU exemptions in secret, without any public scrutiny.

These exemptions matter because the LEU may be recoverable by Iran in a breakout to produce highly enriched uranium, thereby lowering breakout times. Separating LEU from its chemical constituents in such products is typically straightforward.

While Iran and its allies may today view the LEU as non-recoverable, that view does not appear to be a sufficient standard to meet the JCPOA conditions or prevent the LEU’s use in a breakout. A country intent on breaking out and making highly enriched uranium as national priorities may make an entirely different calculation about the LEU’s worth and devote considerable effort to recovering the LEU, such as during a push to acquire nuclear weapons in a crisis.

Any discussion of such an important issue as exempting LEU from the 300 kilogram cap or from export should be public and subject to more rigorous oversight. The exemption process and the Joint Commission decisions should be transparent; the current arrangement has been overly secret and amounts to the generation of additional secret or confidential arrangements directly linked to the JCPOA that do not have adequate oversight and scrutiny. Moreover, the process in general raises the question of whether Iran is exploiting the exemption mechanism, outside of any public oversight, to systematically weaken as many JCPOA limitations as possible. The US administration should insist that the exemption process and decisions be public and transparent.

 

Russia Blocking UN Sanctions on Syrian Chemical Attacks

Russia blocks UN move to sanction Syria for chemical attacks

Russia’s UN ambassador questioned whether a UN report had provided evidence of President Assad’s chemical weapons attacks

MiddleEastEye: Russia blocked a move by the United Nations on Tuesday to sanction Syria for the government’s alleged use of chemical weapons in the country’s brutal civil war.

Britain and France called for UN sanctions after a UN-led investigation found that President Bashar al-Assad’s forces had carried out at least two chemical attacks, one in 2014 and one in 2015.

Following a closed-door Security Council meeting the Russian ambassador, Vitaly Churkin, said he had “very serious questions” about the findings and suggested the panel should continue its work.

“There are a number of questions which have to be clarified before we accept all the findings of the report,” Churkin said.

Previous reports from the Organisation for the Prohibition of Chemical Weapons (OPCW) had concluded that toxic gases have been used as weapons in Syria’s five-year war, but stopped short of identifying the perpetrators.

The panel of inquiry, known as the Joint Investigative Mechanism (JIM), for the first time pointed the finger of blame at the Assad government for chemical weapons use after years of denial from Damascus.

The British and French ambassadors described the use of chemical weapons against civilians as a war crime, while US ambassador Samantha Power called for quick action to ensure those responsible “pay a price.”

Churkin, however, made clear he was unconvinced by the JIM report.

“There is nobody to sanction in the report,” Churkin said. “It contains no names, no specifics, no fingerprints.”

“Clearly there is a smoking gun. We know that chlorine was most likely used, but there are no fingerprints on the gun,” he said.

The panel found that the Syrian government had dropped chemical weapons on two villages in northwestern Idlib province: Talmenes on 21 April, 2014 and Sarmin on 16 March, 2015.

In both instances, Syrian air force helicopters dropped “a device” on houses that was followed by the “release of a toxic substance,” which in the case of Sarmin matched “the characteristics of chlorine.”

Chlorine use as a weapon is banned under the Chemical Weapons Convention, which Syria joined in 2013, under pressure from Russia, Assad’s ally.

No evidence

Syrian ambassador Bashar Jaafari rejected the findings, saying the panel lacked “physical evidence” to support its conclusions that chlorine barrel-bombs were dropped on civilians.

The report was “totally based on witnesses presented by terrorist armed groups,” Jaafari told reporters.

French ambassador Francois Delattre called for a “quick and strong Security Council response” that would include “imposing sanctions on those who are responsible for these acts.”

The council will be “looking at the imposition of sanctions and some form of accountability within international legal mechanisms,” said British Ambassador Matthew Rycroft.

The report also found that the Islamic State had used mustard gas in an attack on the town of Marea in northern Aleppo province in August 2015.

Human Rights Watch called on the council to refer Syria to the International Criminal Court for war crimes and to urgently impose sanctions.

Britain, France and the United States said such a step remained an option, even though Russia and China blocked ICC referral in 2014.

“Russia and China don’t have a leg to stand on by continuing to obstruct the Security Council on Syria sanctions and ICC referral,” said Louis Charbonneau, UN director at Human Rights Watch.

“The Security Council diminishes its importance if it doesn’t take strong action against demonstrated use of chemical weapons by the Syrian government.”

****

Syria’s ambassador to the United Nations has dismissed as flawed the findings of a UN-mandated investigation blaming Syrian forces for the use of chemical weapons, saying the report is based on “false testimonies.”  Per the Iran Project 

Last week, a report carried out by the Joint Investigative Mechanism of the UN and the OPCW claimed that Syrian forces had used chlorine in two separate attacks against militants in 2014 and 2015.

The investigation was launched based on the UN Security Council’s Resolution 2235, which called for determining which party used chemical arms in Syria.

Syria rejected the allegations, with Ja’afari saying on Tuesday that the conclusions of the report “lack any physical evidence, whether by samples or attested medical reports that chlorine was used.”

The Syrian diplomat also said the report was “totally based on witnesses presented by terrorist armed groups.”

Russia, which has been backing the Syrian government in its war against the terrorists, also cast doubt on the report.

****

Per the United Nations website:

24 August 2016 – United Nations Secretary-General Ban Ki-moon today submitted a joint UN-Organisation for the Prohibition of Chemical Weapons (OPCW) report to the Security Council outlining in-depth investigation into, as well as the findings, assessments and conclusions of, nine selected cases related to incidents involving the use of chemicals weapons in Syria.

According to a statement issued today by Mr. Ban’s spokesperson, the UN chief is looking forward to the Council’s consideration of the report.

The report will be available publicly shortly thereafter, the statement added.

The methods of work and the investigation of the specific cases are described in the report’s annexes.

According to the statement, the UN chief also expressed appreciation to the Joint Investigative Mechanism’s Leadership Panel and its staff, as well as to the OPCW and the Office for Disarmament Affairs for their continued support to the Mechanism.

He further thanked the Member States of the UN for their assistance to the Mechanism, including financial support.

The joint body, established by the Security Council in August 2015 for a period of one year with a possibility of future extension, is tasked with identifying “individuals, entities, groups, or governments involved in the use of chemicals as weapons, including chlorine or any other toxic chemical,” in Syria, according to the Council, which reiterated that those responsible must be held accountable.

That body differs from the OPCW-UN Joint Mission on the elimination of Syrian chemical weapons, and which was formally established in August 2013. It completed its mandate and wrapped up operations on 30 September 2014. From now on, the OPCW mission in Syria will continue to deal with the destruction of chemical weapon production facilities and clarification of certain aspects of the Syrian initial declaration under the Chemical Weapons Convention.

 

Taxpayer $’s Paid for the Clinton Server(s) and Bed Bug Problems

This is going to be a long item but stick with it and you will learn some disgusting facts.

Primer:

The Former Presidents Act (FPA; 3 U.S.C. §102 note) was enacted to “maintain the dignity” of the Office of the President. The act provides the former President—and his or her spouse—certain benefits to help him respond to post-presidency mail and speaking requests, among other informal public duties often required of a former President. Prior to enactment of the FPA in 1958, former Presidents leaving office received no pension or other federal assistance. The FPA charges the General Services Administration (GSA) with providing former U.S. Presidents a pension, support staff, office support, travel funds, and mailing privileges.

Pursuant to statute, former Presidents currently receive a pension that is equal to pay for Cabinet Secretaries (Executive Level I), which for calendar year 2015 was $203,700. Executive Level I pay was increased to $205,700 for calendar year 2016. In addition to benefits provided pursuant to the FPA, former Presidents are also provided Secret Service protection and financial “transition” benefits to assist their transition to post-presidential life. Pursuant to the FPA, former Presidents are eligible for benefits unless they hold “an appointive or elective office or position in or under the Federal Government or the government of the District of Columbia to which is attached a rate of pay other than a nominal rate.”

The President’s FY2017 budget request seeks $3,865,000 in appropriations for expenditures for former Presidents, an increase of $588,000 (17.9%) from the FY2016 appropriation level. The increase in requested appropriations for FY2017 anticipates President Barack Obama’s transition from incumbent to former President. For FY2016, President Obama requested and received appropriations of $3,277,000 for expenditures for former Presidents—an increase of $25,000 from FY2015 appropriated levels.

By the way, former Vice Presidents have the same privilege.

***** Now for the real disgusting Clinton thing….

 Getty

Great investigative reporting by Politico: Bill Clinton used a decades-old federal government program, originally created to keep former presidents out of the poorhouse, to subsidize his family’s foundation and an associated business, and to support his wife’s private email server, a POLITICO investigation has found.

Taxpayer cash was used to buy IT equipment — including servers — housed at the Clinton Foundation, and also to supplement the pay and benefits of several aides now at the center of the email and cash-for-access scandals dogging Hillary Clinton’s presidential campaign.

This investigation, which is based on records obtained from the General Services Administration through the Freedom of Information Act, does not reveal anything illegal. But it does offer fresh evidence of how the Clintons blurred the line between their non-profit foundation, Hillary Clinton’s State Department and the business dealings of Bill Clinton and the couple’s aides.

The thousands of pages of newly uncovered records reveal sometimes granular detail about how Bill Clinton’s representatives directed the spending of taxpayer cash allocated by the GSA under the Former President’s Act.

The Act authorizes the GSA to fund the pensions, correspondence, support staff and travel of ex-presidents. It was passed in 1958 to “maintain the dignity” of the presidency by helping former commanders in chief avoid hard times like those that befell Harry S. Truman. He complained that, without help from Uncle Sam, he would be forced to “go ahead with some contracts to keep ahead of the hounds.”

The Clintons did not have this problem.

After leaving the White House “dead broke”, in the words of Hillary Clinton, they quicklyraked in tens of millions of dollars from book deals, speaking fees and consulting gigs. At the same time, Bill Clinton was relying on his connections to some of the world’s deepest-pocketed donors, corporations and governments to seed a global philanthropy operation that overlapped with his consulting work and speaking fees and his wife’s work as Secretary of State — and served as a jumping off point for her presidential campaign.

But even as the Clintons got rich and grew their foundation into a $2 billion organization credited with major victories in the fights against childhood obesity and AIDS — while paying six figure salaries to top aides — Bill Clinton continued drawing more cash from the Former President’s Act than any other ex-president, according to a POLITICO analysis. The analysis also found that Clintons’ representatives, between 2001, when the Clintons left the White House, and the end of this year, had requested allocations under the Act totaling $16 million. That’s more than any of the other living former presidents — Jimmy Carter, George H. W. Bush and George W. Bush — requested during that span.

The program supplemented the income of Clinton’s staff, while providing them with coveted federal government benefits, alleviating the need for the Clinton Foundation or other Clinton-linked entities to foot the bill for such benefits. Similarly, Clinton aides got the GSA to pay for computer technology used partly by the foundation.

An analysis of the records provided by GSA, combined with Clinton Foundation tax returns, found that at least 13 of the 22 staffers who have been paid by GSA to work for Clinton’s personal office also worked for the Clinton Foundation.

A Clinton aide said his boss’s use of the GSA program is entirely consistent with the Former Presidents Act.

Generally, the aide explained that Clinton “wears several hats — among them being former President of the United States and the founder of the Clinton Foundation. His staffing reflects those roles.”

The aide added “there is no legal prohibition that would preclude the former president’s staff from receiving compensation from other sources or doing personal work for the former presidents. We are unaware of any legal prohibition that would preclude these activities.”

The aide wouldn’t discuss specific employees, or their sources of income, explaining “the Office of Former President Bill Clinton does not discuss personnel matters.”

But using the GSA records, POLITICO pieced together a list of Clinton loyalists who at various times have had their earnings supplemented by federal payments of about $10,000-a-year using funds from the Former Presidents Act.

The list reads like a field guide to Clinton World.

It includes longtime Bill Clinton aide Justin Cooper, who despite not having a security clearance, any apparent training in cyber-security or a job at the State Department, in early 2009 helped set up the private email account that Hillary Clinton would use to send and receive classified information as Secretary of State. Her use of that system was dubbed “extremely careless” by the FBI director. Cooper continued working to maintain Clinton’s private email system — including advising her top aides Huma Abedin and Cheryl Mills on attempted hacks — through at least 2012, according to emails released by the State Department.

During some of that period, Cooper was on the GSA payroll, drawing a federal government stipend from February 2011 through 2013, according to the records obtained by POLITICO.

At the same time, though, Cooper was working with Doug Band, a trusted Bill Clinton lieutenant, and Declan Kelly, a top Hillary Clinton fundraiser-turned-State Department official, to launch a global consulting firm called Teneo. It did lucrative work for foundation donors and entities with business before Clinton’s State Department. And it signed a contract reportedly worth $3.5 million with Bill Clinton to serve as a “honorary chairman” (though the former president ultimately kept only $100,000 of that, according to his tax returns and a source familiar with the arrangement). Teneo also paid Abedin as a “senior advisor.”

All the while, Band and Abedin were working together to broker meetings between Secretary of State Clinton and donors to the foundation, where Band served as an official until 2012, drawing a salary that in some years exceeded $111,000-a-year.

Yet, despite the profitable consulting business and his foundation compensation, Band continued drawing a taxpayer-funded stipend from the GSA until 2013.

Also receiving a salary from both the GSA and the Clinton Foundation was Laura Graham, who remained in extremely close contact with Clinton’s top aide at the State Department, swapping emails about sensitive foreign policy issues. During most of her time on the GSA payroll, Graham was earning a six-figure salary from the Clinton Foundation, which topped out at $190,000 per year in 2014.

Cooper, Band and Graham are no longer on the GSA payroll, nor are they working for the foundation. They all either declined to comment or did not respond to questions about the overlap between their taxpayer-funded work, the foundation and the State Department.

According to several people familiar with the former president’s operation, the rationale behind the interwoven payrolls is that they allow for a small team to assist Clinton in a variety of settings without having to do logistically complicated hockey-like line changes. In a given day, Clinton might deliver a paid private speech (during which time his employees’ salaries could be paid by the executive services corporation) and a public speech in his capacity as a former president (during which his staff could be paid by the GSA funds). And he could attend events for the foundation (where staff time would be paid by the foundation) as well as his wife’s presidential campaign (staff time would be paid by the campaign).

The records provided by GSA show that for each pay period, Clinton’s office submitted a list of personnel to GSA who were eligible to receive pay or reimbursement for travel done on behalf of the former president, along with the number of hours worked by each Clinton aide.

For many years, that list included two influential Clinton confidants who were listed as having worked zero hours each pay period — John Podesta, the former Clinton White House chief of staff who served as the foundation’s temporary CEO in 2011, and Bruce Lindsey, the Clintons’ Arkansas confidant who served as the foundation’s CEO from 2004 through mid-2013.

A spokesman for Hillary Clinton’s presidential campaign said Podesta, who is the campaign’s chairman, was on the list because, in 2001, he was paid less than $500 for helping “transition President Clinton from the White House to a DC-based personal office to the Harlem office. Beyond that, he received no compensation for his work.”

It’s unclear if Lindsey ever received GSA payments for work or travel on behalf of the former president. Neither he nor Podesta responded to requests for comment.

A GSA spokesperson declined to comment on specific employees, but said ex-presidents have broad discretion over how they choose to divvy up the $96,600 they are provided each year for staffing. They can give the entire sum to a single employee or divide it among multiple employees.

George H. W. Bush has four people on his taxpayer-funded staff, while Bill Clinton has 10, which has been roughly his staffing level for most of his post-presidency, according to the GSA documents. That means that each earned about $9,600 a year — far from a living wage in Manhattan, where both the Clinton Foundation and Clinton’s personal office are located.

But most Clinton aides on the GSA payroll also earned far more from other groups in the Clinton orbit — from the foundation to Teneo to an entity funded by the Clintons’ personal funds called the Clinton Executive Services Corporation or CESC.

The aide to Bill Clinton said that the former president “personally pays the costs over and above what is provided for by GSA,” adding that Clinton’s contribution “far exceeds the $96,000 provided by GSA.”

The key reason for adding staffers to the GSA payroll, according to two people familiar with the Clintons’ staffing arrangements, was that each employee became eligible for full federal employee benefits, including health and life insurance and pensions. The two people familiar with Bill Clinton’s staffing said the employees on his GSA payroll almost never received benefits from either the Clinton Foundation or the CESC.

Neither the CESC nor the Clinton Foundation are obligated to release their full payrolls, and GSA wouldn’t release the names of the staff being paid through the Former President’s Act.

So POLITICO in March 2015 filed a request under the Freedom of Information Act for GSA records detailing payments made through the Act to the offices of all former presidents between 1999 and the present. Nearly 18 months later, the agency partially fulfilled the request, this week delivering thousands of pages of emails, invoices and payroll documents covering 2009 through this year.

Correspondence related to Clinton’s payroll and requested purchases of computer equipment and other office gear through GSA under the Act comprise the overwhelming majority of the records provided in response to POLITICO’s FOIA request.

That could be a quirk of the FOIA search process.

But Clinton’s reimbursement requests also seem to generate far more back-and-forth with GSA about the justification for the spending (for instance, a GSA official asked in response to a request for a bed bug removal service, “is there currently a bed bug issue … or is the request for some type of on-going maintenance services.” The answer is not included in the documents). And Clinton’s requested purchases also prompted more debate about what’s allowable under the Act.

Part of that likely stems from Clinton’s approach to his ex-presidency, which is far more active and public than that of his former commander-in-chief peers — and that’s even before factoring in his wife’s history-making political career. But the GSA records also reveal just how tricky it can be to separate the various entities, players and controversies that have circulated for decades around Bill and Hillary Clinton.

In several cases, GSA officials raised questions about whether requested furniture and IT equipment including servers were intended for the Clinton Foundation, rather than Clinton’s personal office. In at least one instance, GSA paid to purchase and maintain a specialty Lockheed Martin database system called Intranet Quorom, the supporting systems for which were housed at one time at the Clinton Foundation’s offices, and used by both foundation staff and Bill Clinton’s personal office staff to store and process his correspondence.

The Clinton aide said servers supporting the Intranet Quorom system — which is used for data storage, not email — were the only pieces of equipment purchased by GSA that were housed at the Clinton Foundation at one point, but he said it was justified by the specific circumstances around it.

“As staff needs to have the full picture of all correspondence sent by President Clinton, both staff from the Office of the Former President and the Foundation have access to, and can input into, the Intranet Quorum database,” the aide said.

The Clinton Foundation’s website suggests that there’s a strict wall between the foundation and the ex-president’s personal office. “All Foundation employees are paid for work through the Foundation payroll,” the website says. “No Foundation staff are paid for Foundation work with taxpayer dollars.”

But the aide acknowledged “staff at the Foundation and staff at the Office of the Former President may have similar tasks, and need to coordinate this work — specifically staff that handles President Clinton’s correspondence.”

That shared work is facilitated by the Lockheed Martin IQ database system, the aide said.

But the system’s dual purpose raised questions among GSA officials, who pressed Clinton’s representatives when they submitted an invoice in September 2011 to the GSA to purchase a $7,700 Dell server and other IT equipment to support the Lockheed Martin IQ database.

Clinton Foundation officials explained to the GSA that they wanted the Dell server housed at foundation headquarters rather than at Clinton’s personal office. They explained in an email that the foundation office had better air conditioning, allowing it to support “about 10-15 more servers,” and also it was where IT staff were based, so “trouble shooting with the servers can be done ASAP.”

The GSA staff asked Graham, then serving as the foundation’s COO, to demonstrate that “safeguards are in place to ensure that the servers are solely for use by” Clinton’s personal office. A note affixed to the bottom of an email produced pursuant to POLITICO’s FOIA indicates that the GSA ultimately decided not to purchase the Dell server.

Asked about the reasoning this week, a GSA spokesman suggested that Clinton’s representatives failed to provide sufficient evidence that the Dell server was not for use by the foundation.

“Consistent with the support we provide to every former President, GSA does not approve purchases for entities other than the offices of former Presidents,” the spokesman said. “In this case, GSA staff sought clarification about the intended use of proposed purchases. Ultimately, the referenced server was not purchased.”

But, perhaps highlighting the confusion caused by the overlapping spheres in the Clinton’s universe, the Clinton aide offered a different recollection. “We believe that the information GSA provided you with is incomplete. Our files show that GSA purchased the Dell server that operates the IQ database in 2010.”

Rachael Bade, Cory Bennett and Eric Geller contributed to this report.