What is the Justice Department Investigating and Prosecuting Anyway?

Posted on October 6, 2016October 6, 2016 by Denise Simon

A sudden decision to drop the case against Marc Turi, the legitimate arms dealer approved by Hillary to move weapons to Libya, oh…no…then to Qatar and then not at all had his home raided. Why? Good question except Turi Defense was approved not never launched any shipments. The case against him fell apart mostly due to the notion the government would have to produce documents of the case and background for legal discovery and it would have further tainted Hillary Clinton’s actions regarding Qaddafi and her actions in Libya. Hummm okay….what else? All kinds of cases and questions, try a few of these below. Remember too that Obama issued a pardon for Iranians in the United States during the prisoner swap with Iran. Don’t forget those pesky 5 Taliban commanders released for Bowe Bergdahl.

Meanwhile:

Hamas On Campus, and Hamas is a terror organization, since 1997.

Introduction:

Across America college campuses are being flooded with pro-terrorist propaganda by groups supported by college administrators and student funds. These groups are led by Students for Justice in Palestine but they include the broad coalitions of the left which have become the breeding grounds for a new anti-Semitism. Boycott, Divest and Sanctions resolutions targeting the state of Israel for destruction are passed to chants of “Allahu Ahkbar,” while Jewish students are the targets of verbal and physical harassments which have reached epidemic proportions. This is a report on the 10 schools most supportive of the efforts of Students for Justice in Palestine and its allies, to demonize the state of Israel and bring about its destruction.

Students for Justice in Palestine (SJP) portrays itself as a typical student organization and multicultural group advocating for “social justice” in the Middle East, but this image is a cleverly constructed disguise. Students for Justice in Palestine is not concerned about justice in Palestine where the Hamas regime steals hundreds of millions of dollars earmarked for humanitarian aid and uses it to dig terror tunnels whose only purpose is to murder Jews. In truth, SJP is a pro-terror organization that is funded by anti-Israel Hamas terrorists for the purpose of destroying Israel, the world’s only Jewish state, and committing genocide against its Jewish population as prescribed in the Hamas charter.

Visit Stop the Jew-Hatred on Campus.

1. Brooklyn College (CUNY)

2. San Diego State University

3. San Francisco State University

4. Tufts University

5. University of California Berkeley

6. University of California Irvine

7. University of California Los Angeles

8. University of Chicago

9. University of Tennessee Knoxville

10. Vassar College

More here from Front Page.

**** Then there is Mosed Omar.

Federal prosecutors — acting abruptly and without public explanation — have moved to drop a controversial criminal passport fraud case that critics alleged stemmed from coercive interrogations at the U.S. embassy in Yemen.

Earlier this year, a grand jury in San Francisco indicted Mosed Omar on passport fraud charges linked to a statement he signed during a 2012 visit to the U.S. diplomatic post in the unstable Middle Eastern nation.

After signing the statement saying he’d used a false name when he was naturalized as a U.S. citizen in 1978, Omar’s U.S. passport was confiscated and a request for a passport for his daughter was denied. Omar eventually made it back to the U.S. on a temporary travel permit. More here from Politico.

There was the case of Huma Abedin not only working officially at the State Department for Hillary Clinton, but at the same time she was on the payroll of Teneo. Has this investigation and case advanced in any form? Not so much.

It seems that double dipping, meaning working for the Federal government and other outside organizations is actually quite common and this too includes staffers working for legislators in both houses of Congress. So, this does tell us there is nepotism perhaps and for sure conflicts of interest. How so you ask? Words matter and members of Congress figured out that the word ‘fellowship’ is best used to describe the work…..sheesh….

POGO: The U.S. Congress allows Members to staff their offices with Fellows who are paid by corporations, foundations, universities, non-profits, and other outside private entities.

The Fellows are required to abide by all the laws, rules, and standards governing permanent Congressional staff members. Indeed, they are often indistinguishable from permanent staff members. They work on writing legislation and Floor speeches, and represent the Member in meetings with other offices and constituents.

POGO reviewed 2,014 publicly available reports on Senate fellows and found several examples of the appearance of a conflict of interest, and that Senators did not consistently disclose fellows whose salary was paid by a third party. The House does not maintain records on Congressional Fellows at all.

On the Senate side, fellows and their supervisors are required to file reports detailing when they began their fellowship, how much money they’re making, what entity is paying their salary, and how many hours they’ve worked. Senate rules mandate that new fellows file their “Agreement to Comply with the Senate Code of Official Conduct,” known as form 41.4, at the beginning of their fellowship, at the end of each calendar quarter, and at the end of the fellowship. The fellow’s supervisor must file a “Report on Individuals Who Perform Senate Services,” known as form 41.6, which is often signed by the Senator. While these forms are available to the public, they are not electronically available and anyone interested in seeing them must visit the Senate Office of Public Records during business hours.

Is there a code of conduct, formal disclosures and rules that apply here? Yes….is there compliance? Not so much. Essentially, this is but another means to lobby members of Congress and to ensure earmarks are designated, and they are.

Require disclosure in the House of Representatives

The House Rules committee should introduce language into the Code of Official Conduct that would require Representatives to report when their office employs an individual who is compensated by any source outside of the United States Government. Such a report should include the identity of the source of the compensation and the amount or rate of compensation.

More oversight in the Senate

Senate reporting of Fellows who are paid by corporations, foundations, universities, non-profits, and other outside private entities is falling short. The Senate Ethics Committee needs to increase its oversight over the Congressional Fellows reporting requirements, actively checking with Member offices to make sure they don’t have any Fellows employed for years they don’t report any. The Senate Ethics Committee should also increase training for Member offices on what they are required to report, at the start of each Congress it should hold a series of trainings for all Member offices.

Both Chambers should require electronic filing of these disclosures, in a publically accessible format

The Senate, and House as it begins to require reporting on Fellows, should transition to an electronic filing system that can be accessed by the public. This will allow for more uniform participation by Member offices and more public oversight over the Congressional Fellowship programs. Read on here for further and exact details from POGO. Fabulous investigative work and causes for more questions to be asked and solutions to be applied.

We Cant Find 44 Afghani Military Members in USA, AWOL

Posted on October 6, 2016October 6, 2016 by Denise Simon

From last month: The missing soldiers were identified as Maj. Jan Mohammad Arash, Cpt. Mohammad Nasir Askarzada, and Cpt. Noorullah Aminyar.Earlier, two Afghan policemen identified as 22-year-old Mohammad Yasin Ataye and 24-year-old Mohd Naweed Samimi vanished during a training visit in United States last week.The two were among the 31 Afghan police officers who are on a visit in United States to work with the US Drug Enforcement Administration (DEA).

**** Some have been missing for as long as 2 years…note missing….in 2 years they have not been located…..sigh

Exclusive: Dozens of Afghan troops AWOL from military training in U.S.

Reuters: Forty-four Afghan troops visiting the United States for military training have gone missing in less than two years, presumably in an effort to live and work illegally in America, Pentagon officials said.

Although the number of disappearances is relatively small — some 2,200 Afghan troops have received military training in the United States since 2007 — the incidents raise questions about security and screening procedures for the programs.

They are also potentially embarrassing for U.S. President Barack Obama’s administration, which has spent billions of dollars training Afghan troops as Washington seeks to extricate itself from the costly, 15-year-old war. The disclosure could fuel criticism by supporters of Republican presidential nominee Donald Trump, who has accused the Obama administration of failing to properly vet immigrants from Muslim-majority countries and has pledged a much tougher stance if he wins.

While other foreign troops on U.S. military training visits have sometimes run away, a U.S. defense official said that the frequency of Afghan troops going missing was concerning and “out of the ordinary.”

Since September alone, eight Afghan troops have left military bases without authorization, Pentagon spokesman Adam Stump told Reuters. He said the total number of Afghan troops who have gone missing since January 2015 is 44, a number that has not previously been disclosed.

“The Defense Department is assessing ways to strengthen eligibility criteria for training in ways that will reduce the likelihood of an individual Afghan willingly absconding from training in the U.S. and going AWOL (absent without leave),” Stump said.

Afghans in the U.S. training program are vetted to ensure they have not participated in human rights abuses and are not affiliated with militant groups before being allowed into the United States, Stump said.

The defense official, who spoke on condition of anonymity, added there was no evidence any of those who had absconded had carried out crimes or posed a threat to the United States.

Go here for the photo collection by Reuters

The Afghan army has occasionally been infiltrated by Taliban militants who have carried out attacks on Afghan and U.S. troops, but such incidents have become less frequent due to tougher security measures.

Trump, whose other signature immigration plan is to build a wall on the U.S.-Mexico border, has proposed a temporary ban on Muslims seeking to enter the country, and has said that law enforcement officers should engage in more racial profiling to curb the threat of attacks on American soil.

After Omar Mateen, whose father was born in Afghanistan, killed 49 people at a gay nightclub in Orlando in June, Trump said an immigration ban would last until “we are in a position to properly screen these people coming into our country.”

BILLIONS OF DOLLARS IN TRAINING

Washington has allocated more than $60 billion since 2002 to train and equip Afghan troops, but security remains precarious and the Taliban are estimated to control more territory in Afghanistan than at any time since 2001 when the U.S. invaded.

Earlier this year Obama shelved plans to cut the U.S. force in Afghanistan nearly in half by year’s end, opting instead to keep 8,400 troops there through the end of his presidency in January.

The military training program brings troops to the United States from around the world in order to build on military relations and improve capabilities for joint operations.

In some cases, officials said, the Afghan students who went missing were in the United States for elite Army Ranger School and intelligence-gathering training. The officials did not identify the missing troops or their rank.

Even though the troops were in the United States for military training, they were not necessarily always on a military base.

If students under the military program are absent from training for more than 24 hours, they are considered to be “absent without leave” (AWOL) and the Department of Homeland Security is notified.

In one case the Pentagon confirmed that an Afghan student had been detained by Canadian police while attempting to enter Canada from the United States.

It was unclear how many others have been located by U.S. authorities, and the Department of Homeland Security did not immediately respond to a request for comment.

Experts said low morale and insufficient training to fight the Taliban could explain the troops leaving, in addition to a dearth of economic opportunities in the impoverished country.

“They face a formidable enemy, with very limited resources and many Afghan troops aren’t getting paid on time,” said Michael Kugelman, a South Asia specialist at the Woodrow Wilson Center, a Washington think-tank.

Obama’s New Policy on Intelligence Gathering and National Security

Posted on October 5, 2016October 5, 2016 by Denise Simon

Next it will be some climate change mandate….

The White House

Office of the Press Secretary

For Immediate Release

October 05, 2016

FACT SHEET: Presidential Memorandum on Promoting Diversity and Inclusion in the National Security Workforce

Since the beginning of his Administration, President Obama has deepened the commitment of the United States Government to draw upon the talents and skills of all parts of our society. Diversity has always been one of the Nation’s greatest strengths, and it is no different for the Federal workforce, which has a responsibility as the country’s largest employer to lead by example and to reflect the population that we serve. Inclusion has been key to ensuring that the investments we make to develop our workforce result in a more effective and skilled government for the American people.

The imperative to promote diversity and inclusion is also critical for our national security workforce. In a complex and interconnected world, the nature of our national security challenges and opportunities is more global than ever. As a society that can trace its roots to every region around the world, the American people are our greatest asset when it comes to the United States’ ability to build bridges to communities at home and abroad, address foreign threats and aggression, and lead coalitions to promote global peace and prosperity. Promoting diversity and inclusion ensures that national security departments and agencies can recruit their employees from the broadest possible pool of talent and bring a wide range of perspectives, skills, and backgrounds to bear to tackle our toughest problems.

Today, the President is issuing a new Presidential Memorandum that provides guidance on the implementation of policies to promote diversity and inclusion in the national security workforce. Currently, more than three million military and civilian personnel in the U.S. Government are engaged in protecting the country and advancing our interests abroad, through diplomacy, development, defense, intelligence, law enforcement, and homeland security. In broad comparison with the wider Federal Government, the federal workforce dedicated to our national security and foreign policy is – on average – less diverse, including at the highest levels.

While this data does not necessarily indicate the existence of barriers to equal employment opportunity, the Presidential Memorandum outlines a number of actions that will allow departments and agencies to better leverage the diversity and inclusion of the federal workforce, consistent with the existing merit system and applicable law, including:

Collection, analysis, and dissemination of workforce data: Data is an essential tool to help departments and agencies identify workforce talent gaps, assess the efficiency and effectiveness of their diversity and inclusion efforts, and promote transparency and accountability. The memorandum provides guidance for departments and agencies to make key workforce data available to the general public, provide an annual report to their leadership and workforce on the status of diversity and inclusion efforts, expand the use of applicant flow data to assess the fairness and inclusiveness of their recruitment efforts, and identify any additional demographic categories they recommend for voluntary data collection.
Provision of professional development opportunities and tools consistent with merit system principles: Providing access to professional development opportunities consistent with merit system principles is a key element to retaining and developing a diverse and inclusive workforce. The memorandum directs departments and agencies to engage their workforce through regular interviews to understand their views on workplace policies and why they choose to stay or leave, prioritize the expansion of professional development opportunities including programs specifically designed to develop the next generation of career senior executives, and implement a review process for decisions related to certain assignment or geographic restrictions.
Strengthening of leadership engagement and accountability: The memorandum recognizes the critical role that senior leadership and supervisors play in fostering a diverse and inclusive workforce and cultivating talent consistent with merit system principles. It encourages departments and agencies to reward and recognize efforts by senior leaders and supervisors to participate in mentorship, sponsorship, and recruitment; to disseminate voluntary demographic data for external committee and boards that advise the leadership of an agency; and to expand the provision of training on implicit or unconscious bias, inclusion, and flexible work policies.

The guidance in this Presidential Memorandum furthers the initiative that President Obama announced in 2011 in Executive Order 13583, “Establishing a Coordinated Government-wide Initiative to Promote Diversity and Inclusion in the Federal Workforce,” for departments and agencies to develop and implement a more comprehensive, integrated, and strategic focus on diversity and inclusion. It also complements the remarkable progress that the national security workforce has made over the past several years in recognizing the importance of diversity and inclusion to the success of their mission, including but not limited to:

The Department of Defense’s decisions to eliminate all remaining institutional barriers to service by opening all military occupations to women and transgender individuals;
The Central Intelligence Agency’s commissioning and public release of two studies on women and diversity in their leadership and its active implementation of the studies’ recommendations;
The Office of the Director of National Intelligence release of its annual Intelligence Community demographics report, the first time it has ever been publicly released; and
The Department of Justice announced that all law enforcement agents and prosecutors will receive training to recognize and address implicit bias.

The Presidential Memorandum also aligns with a number of congressional efforts to promote the diversity of the national security workforce. Over the past several decades, Congress has passed legislation mandating reforms to ensure that institutions including the Foreign Service, Intelligence Community, and U.S. military provide equal employment opportunity to all those who have the desire and qualifications to serve their country. Under this Administration, the Congress and President Obama have collaborated on important legislation on this issue, most notably on the Don’t Ask Don’t Tell Repeal Act of 2010.

DHS Officially Issues Alert on Election Hacking

Posted on October 5, 2016October 5, 2016 by Denise Simon

DHS Issues Alert on U.S. Election Hacking

The United States Department of Homeland Security has issued an Intelligence Assessment on the Cyber Threats and Vulnerabilities to U.S. Election Infrastructure. The report, which primarily downplays the risk of hacking election systems appears to conflict with recent FBI Director testimony stating that at least 20 states have been electronically probed with four suffering hacking related intrusions. The report does note that “multiple elements of US election infrastructure are potentially vulnerable to cyber intrusions. The risk to US computer-enabled election systems varies from county to county, between types of devices used, and among processes used by polling stations.”

The key judgments also include:

DHS has no indication that adversaries or criminals are planning cyber operations against US election infrastructure that would change the outcome of the coming US election. Multiple checks and redundancies in US election infrastructure—including diversity of systems, non-Internet connected voting machines, pre-election testing, and processes for media, campaign, and election officials to check, audit, and validate results—make it likely that cyber manipulation of US election systems intended to change the outcome of a national election would be detected.

We judge cybercriminals and criminal hackers are likely to continue to target personally identifiable information (PII), such as that available in voter registration databases. We have no indication, however, that criminals are planning theft of voter information to disrupt or alter US computer-enabled election infrastructure.

Other elements of the report, note the resiliency of the voting infrastructure, but also the potential for nation-state disruption.

No Indication of Cyber Operations to Change Vote Outcome

DHS has no indication that adversaries or criminals are planning cyber operations against US election infrastructure that would change the outcome of the coming US election. Multiple checks and redundancies in US election infrastructure—including diversity of systems, non-Internet connected voting machines, pre-election testing, and processes for media, campaigns and election officials to check, audit, and validate results—make it likely that cyber manipulation of US election systems intended to change the outcome of a national election would be detected.

We assess that successfully mounting widespread cyber operations against US voting machines, enough to affect a national election, would require a multiyear effort with significant human and information technology resources available only to a nation-state. The level of effort and scale required to change the outcome of a national election, however, would make it nearly impossible to avoid detection. This assessment is based on the diversity of systems, the need for physical access to compromise voting machines, and the security and pre-election testing employed by state and local officials.* In addition, the vast majority of localities engage in logic and accuracy testing, which work to ensure voting machines operate and tabulate as expected—before, during, and after the election.

We judge, as a whole, voter registration databases are resilient to systemic, nationwide cyber manipulation because of the diverse systems and security measures surrounding them. Targeted intrusions against individual voter registration databases, however, are possible. Additionally, with illicit access, manipulation of voter data, or disruptions to their availability, may impact a voter’s ability to vote on Election Day. Most jurisdictions, however, still rely on paper voter rolls or electronic poll books that are not connected in real-time to voter registration databases, limiting the possible impacts in 2016.

Voting precincts in more than 3,100 counties across the United States use nearly 50 different types of voting machines produced by 14 different manufacturers. The diversity in voting systems and versions of voting software provides significant security by complicating attack planning. Most voting machines do not have active connections to the Internet.

We assess the impact of an intrusion into vote tabulation systems would likely be contained to the manipulation of unofficial Election Night reporting results, which would not impact the certified outcome of an election, but could undermine public confidence in the results. In addition, local election officials, media organizations, and political campaigns carefully monitor local voting patterns, particularly in electorally significant jurisdictions, and are likely to detect and begin investigating potential anomalies quickly.

Non-State Actors Likely To Continue Targeting PII, Potentially Attempt Disruption

We judge cybercriminals and criminal hackers are likely to continue to target voter PII. We have no indication, however, that cybercriminals are planning theft of voter information to disrupt or alter computer-enabled US election infrastructure voting. Politically-motivated criminal hackers could attempt temporary disruptive cyber attacks, such as denial-of-service (DoS) attacks or web defacements against election-related websites, in the lead-up to or during the election process. Disruptive attacks could target public-facing state and local government websites, potentially including election infrastructure used to report election results to the general public and media; however, we judge this activity would likely have little impact on the voting process itself.

Unknown cyber actors in mid-July used an open-source scanning tool to identify and exploit a structured query language (SQL) injection vulnerability and exfiltrate PII from a Midwestern state board of elections website, according to FBI sources with excellent access and information provided by a cybersecurity organization supporting states. In at least three other states, voting and non-voting related websites during the same period observed unsuccessful SQL injection attacks from unknown actors, according to the same reporting.

Cybercriminals routinely attempt exploitation of misconfigured and vulnerable websites and webservers via SQL injection, brute force login attempts, cross-site scripting, and other publicly known vulnerabilities, according to DHS reporting from sources with direct access.

Criminal hackers routinely engage in disruptive attacks such as website defacement and DoS attacks, through exploiting publicly known vulnerabilities and for-hire DoS tools, according to DHS reporting from reliable sources with direct access.

Vulnerability of Computer-Enabled Election Systems

We assess multiple elements of US election infrastructure are potentially vulnerable to cyber intrusions. The risk to computer-enabled election systems, however, varies from county to county, between types of devices used and among processes used by polling stations.

Electronic Voting Systems: Security researchers have repeatedly demonstrated in laboratory testing environments that voting machines are vulnerable to compromise, usually with physical access, and such compromises could result in the manipulation of vote totals. Election outcomes would only be impacted if the compromise happened on a large scale across multiple machines or jurisdictions—which we judge to be beyond the capability of any adversary—or in cases of smaller local elections where the margin of victory is at a smaller scale.

Voter Registration Databases: Online voter registration systems provide a potential point of vulnerability to enable cyber actors to gain illicit access to voter registration databases. Cyber actors have exploited these portals in the past to gain illicit access to voter information. Compromises of voter registration databases have resulted in the potential release of PII, but not the modification of records—with the exception of one unconfirmed incident of voter registration manipulation reported by US media. The exposure of voters’ information would have limited impact on the integrity of the election process; however, it could undermine confidence in the system and provide the ability to conduct further cyber operations.

Public Dissemination of Voting Results: State government information technology solutions generally include a public-facing Internet-connected portion that is used to report election results to the general public and media, which some states have begun migrating to the cloud due to Election Day demand. Vulnerabilities in the public-facing Internet portion could be used to display inaccurate vote results to the public and media. Election Day results are not the official results of the state or local jurisdiction.

Iran Sanctions and Real Estate Investments in the U.S.

Posted on October 4, 2016October 4, 2016 by Denise Simon

Primer: While the United States under the Obama administration paid out $1.7 billion to Iran, still held and blocked is an estimated $1.97 billion in bonds that were or are held by Citigroup. There is additionally real estate property held not only as an embassy in Washington DC, but there is a 36 story office building in New York City owned by an Iranian Foundation known as Alavi. Other properties are located in Texas, California, Virginia, Maryland and other locations in New York City. For the most part these have been frozen by the United States and remain so.

There are 2 key Executive Orders #’s 13438 and 13572 that refer to Islamic State and Iranian Shiite militia operating in Iraq and the IRGC Qods Force and Commander Qasem Soleimani that remain in effect.

Trump’s organization did business with Iranian bank later linked to terrorism

GOP nominee has slammed Clinton for cutting ‘deals with our foreign adversaries’

CPI: Donald Trump’s real estate organization rented New York office space from 1998 to 2003 to an Iranian bank that U.S. authorities have linked to terrorist groups and Iran’s nuclear program.

Trump inherited Bank Melli, one of Iran’s largest state-controlled banks, as a tenant when he purchased the General Motors Building on Fifth Avenue in Manhattan, according to public records reviewed by the International Consortium of Investigative Journalists and the Center for Public Integrity. The Trump Organization kept the bank on as a tenant for four more years after the U.S. Treasury Department designated Bank Melli in 1999 as being controlled by the Iranian government.

U.S. officials later alleged that Bank Melli had been used to obtain sensitive materials for Iran’s nuclear program. U.S. authorities also alleged that the bank had been used between 2002 and 2006 to funnel money to a unit of the Iranian Revolutionary Guard that has sponsored terrorist attacks — a period that overlapped with the time the bank rented office space from Trump.

The Trump Organization’s dealings with the Iranian bank shed more light on Trump’s wide-ranging business interests, which sometimes stand at odds with his blunt declarations on the campaign trail. Trump has denounced Iran as a “big enemy,” blasted Hillary Clinton for not taking a harder line against the Iranian regime and charged that donations from foreign governments to the Clinton Foundation amounted to evidence of corruption. His five-year stint as Bank Melli’s landlord provides an example of the Trump Organization itself doing business with a government hostile to the United States.

“It’s a pretty hypocritical position to take,” said Richard Nephew, who served from 2013 to 2015 as principal deputy coordinator of sanctions policy at the U.S. State Department and spent nearly a decade working on Iran sanctions in the administrations of George W. Bush and Barack Obama. “It suggests that his principles are pretty flexible when it comes to him getting paid.”

A court document obtained by ICIJ indicates that Bank Melli’s rent on more than 8,000 square feet on the GM Building’s 44th floor may have topped half a million dollars a year.

The legal ramifications of the Trump Organization taking rent payments from Bank Melli are unclear.

At the time, the U.S. had a sweeping embargo in place which prohibited Americans from doing business with Iran, including receiving rent payments. However, some Iranian organizations were granted licenses exempting specific transactions from sanctions. If the payments were licensed, it may have been legally difficult for the Trump Organization to evict the bank.

The Treasury Department does not publicly disclose individual licenses granting companies exemptions from sanctions rules. The Treasury Department, the Trump campaign and Bank Melli all declined to answer whether the agency had issued a license to the Trump Organization or the bank permitting rent payments during Trump’s ownership of the building.

The Trump campaign declined to answer any questions about Bank Melli for this story, but said Trump would take steps to avoid any conflicts of interest with his business dealings if he is elected president.

“Mr. Trump’s sole focus is and will be on making our country great again,” campaign spokeswoman Hope Hicks said in an email. “He has already committed to putting his assets in a blind trust and will have no involvement whatsoever in the Trump Organization.”

Bank Melli did not respond to repeated telephone and email inquiries by ICIJ to its offices in Tehran, London and Paris.

Bank Melli’s office in the GM Building was listed by the Treasury Department among financial institutions “owned or controlled” by the Iranian government and subject to U.S. economic sanctions, according to the Code of Federal Regulations from the years 1999 through 2003. Trump owned the GM Building from July 1998 until September 2003, New York City property records show.

Under U.S. sanctions rules, Bank Melli was forbidden from conducting banking transactions within the U.S., but the bank may have maintained its New York offices in the hope that the U.S. government would someday ease sanctions against Iranian businesses.

The bank moved out of the GM Building sometime after 2003. A spokesperson for Boston Properties, Inc., which is currently the building’s majority owner, said Bank Melli was not a tenant when Boston Properties and other partners bought the building in 2008.

Bank’s ties to terror

U.S. sanctions against Iran date back to the Iranian Revolution in 1979, when Islamic fundamentalists seized power and held more than 50 Americans hostage for more than a year. After briefly lifting restrictions when the hostages were released, President Ronald Reagan designated Iran as a state sponsor of terrorism and imposed new sanctions in 1984 and 1987.

At the time, Donald Trump called for the U.S. take a tougher line against the Iranian regime.

In 1987, he suggested in a speech in New Hampshire that the U.S. should attack Iran and seize some of its oil fields to hit back for what he described as Iran’s bullying of America.

“I’d be harsh on Iran. They’ve been beating us psychologically, making us look a bunch of fools,” Trump told The Guardian in 1988. “It’d be good for the world to take them on.”

In the years that followed, Iran stepped up its support for international terrorist attacks, according to authorities in the U.S. and other Western nations.

In 1994, a suicide bomber killed 85 people at a Jewish center in Buenos Aires, an attack that Argentine prosecutors later charged was coordinated by the Iranian government.

In 1996, a truck bomb killed 19 American servicemen at the Khobar Towers apartment complex in Saudi Arabia. A U.S. court later held that the bombing had been “planned, funded, and sponsored by senior leadership in the government of the Islamic Republic of Iran.”

As Iran supported terror attacks abroad, the U.S. moved to punish the regime economically. President Bill Clinton approved a sweeping embargo in 1995 that banned Americans from conducting trade with Iranian businesses.

Bank Melli, one of Iran’s largest state-owned banks, had long had an office in the GM Building in midtown Manhattan. In 1998, Trump’s real estate organization bought the building and inherited Bank Melli as a tenant.

It is not clear if Trump knew personally that Bank Melli was renting an office from his company, but he was the Trump Organization’s chairman and president, and has described himself as a hands-on manager who pays attention to details.

Nephew, who worked on sanctions and nuclear nonproliferation issues for the U.S. government from 2003 to 2015, said there was less awareness in the 1990s about Iran’s nuclear program and the role of banks in financing terrorism. But he said that accepting payments from Bank Melli should have raised a red flag, even in 1998.

“Should someone in America have known better than to do business with Iran? Yeah,” Nephew said.

George Ross, the longtime executive vice-president of the Trump Organization, said he was not aware that Bank Melli had been a Trump tenant.

“We had any number of tenants in the GM Building,” Ross said in a brief telephone interview. “They might have been in there, but I have no knowledge of them.”

Emanuele Ottolenghi, an expert on Iran at the Foundation for the Defense of Democracies, said that it was “remarkable” that the Trump Organization had kept Bank Melli as a tenant for four years after the Treasury Department had listed the bank as an Iran-controlled entity.

“I just don’t think that a company of that size and means should be able to hide behind a ‘we didn’t know’ kind of argument,” Ottolenghi said.

In 2007, U.S. authorities charged that Bank Melli had facilitated purchases for Iran’s nuclear program, and that it had been used to send at least $100 million to the Quds Force, the feared special operations unit of Iran’s Revolutionary Guards.

The Quds Force was designated as a supporter of terrorism by President George W. Bush weeks after the attacks of Sept. 11, 2001, for providing support to the Taliban, Hamas and Hezbollah, groups that the U.S. has labeled as terrorist organizations.

Bank Melli played an important role in Iran’s nuclear program and support for international terrorism in the years before it was singled out by Treasury in 2007, experts told ICIJ.

“It was allowing the entities that were shopping for the regime to make payments,” said Ottolenghi, who described Bank Melli as “critical” to Iran’s past nuclear and terrorist activities.

A representative for Glodow Nead Communications, a public relations firm representing the Trump Organization, told an ICIJ reporter that the Trump Organization would only comment if the story was positive. She declined as a matter of policy to provide contact information for any of its employees.

The Trump Organization continued renting office space to Bank Melli until the insurance company Conseco, which had provided financing for the 1998 purchase, took control of the GM Building in 2003 and sold it to the Macklowe Organization, a New York City real estate developer.

Trump talks Iran

As a presidential candidate, Trump has been a fierce critic of Iran, denouncing its government as “the world’s top state sponsor of terrorism.” He has vowed to take a more warlike posture against the regime, threatening on Sept. 9 to shoot Iranian ships out the water if their sailors made rude gestures toward U.S. Navy ships.

Last week, during the first of three face-to-face debates with Clinton, Trump panned the United States’ 2015 nuclear deal with Iran, calling it “one of the worst deals ever made by any country in history.”

In June, a statement by the Trump campaign blasted Clinton for her work in support of the Iran nuclear deal after the airline Iran Air struck an agreement to purchase aircraft from Boeing, a company that has contributed to the Clinton Foundation.

“This is another example of Clinton’s pay-to-play governing style,” the Trump campaign said. “She will cut deals with our foreign adversaries as long as they are willing to line her pockets.”

At the same time, news reports published in the course of the presidential campaign have shown that the Trump Organization has been entangled with a number of foreign governments that are hostile to the United States.

Trump tried to raise money for the Trump Organization from the regime of Muammar Qaddafi, the Libyan dictator who provided support for the 1988 Pan Am flight bombing over Lockerbie, Scotland, that killed 189 Americans, Buzzfeed News reported in June.

A company owned by Trump violated the embargo against Cuba with a business trip to the island in 1998, shortly before he gave a speech in Miami expressing his support for the embargo, Newsweek reported in September. In addition, Bloomberg News has reported that Trump Organization executives may have also violated the Cuban embargo by scouting out a possible investment in a golf course near Havana in late 2012 or early 2013. The deal ultimately fell through, according to the report.

The Trump Organization has also made millions selling apartments to the government of Saudi Arabia, the New York Daily News reported in September. The Saudi government is formally a U.S. ally but is suspected of supporting militant Islamic groups, and Trump has called on the Clinton Foundation to return Saudi donations because of the government’s poor human rights record.

Other Trump Organization entanglements in India, Russia and Dubai create conflicts of interest that could threaten American national security if Trump becomes president, Newsweek reported in September.

Information on all of these ventures is limited because Trump has not released his tax returns. He is poised to become the first major party candidate not to do so by Election Day since Richard Nixon in 1972.

Trump pledged on Sept. 15 that he would “absolutely sever” his connections with the Trump Organization if he is elected president. “I will sever connections, and I’ll have my children and my executives run the company and I won’t discuss it with them,” he said on the television program “Fox and Friends.”

Sasha Chavkin is a staff writer and Michael Hudson is a senior editor at the International Consortium of Investigative Journalists. Dave Levinthal is senior political reporter at the Center for Public Integrity.