US Treasury to Publish Russian Oligarch Corruption Index

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In December of 2015, Obama took aggressive action expelling Russian diplomats over hacking and political intrusion.

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“In addition, the Russian Government has impeded our diplomatic operations by, among other actions — forcing the closure of 28 American corners which hosted cultural programs and English-language teaching; blocking our efforts to begin the construction of a new, safer facility for our Consulate General in St Petersburg; and rejecting requests to improve perimeter security at the current, outdated facility in St Petersburg.” Some additional actions and those expelled include:

Two Russian intelligence agencies, the GRU and the FSB, four GRU officers and three companies “that provided material support to the GRU’s cyber operations”.

The White House named Igor Valentinovich Korobov, the current chief of the GRU; Sergey Aleksandrovich Gizunov, deputy chief of the GRU; Igor Olegovich Kostyukov, a first deputy chief of the GRU; and Vladimir Stepanovich Alexseyev, also a first deputy chief of the GRU. The Obama Executive Order is here.

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White House Fact Sheet on Russian malicious behavior

Slide presentation on Fancy Bear, hacking

Russia’s Oligarchs Brace for U.S. List of Putin Friends

(Bloomberg) — The U.S. Treasury Department is finishing its first official list of “oligarchs” close to President Vladimir Putin’s government, setting off a flurry of moves by wealthy Russians to shield their fortunes and reputations.

Some people who think they’re likely to land on the list have stress-tested the potential impact on their investments, two people with knowledge of the matter said. Others are liquidating holdings, according to their U.S. advisers.

Russian businessmen have approached former Treasury and State Department officials with experience in sanctions for help staying off the list, said Dan Fried, who previously worked at the State Department and said he turned down such offers.

Some Russians sent proxies to Washington in an attempt to avoid lobbying disclosures, according to one person that was contacted.

The report is expected to amount to a blacklist of Russia’s elite. It was mandated by a law President Donald Trump reluctantly signed in August intended to penalize the Kremlin for its alleged meddling in the 2016 election.

A rare piece of legislation passed with a bipartisan veto-proof margin, the law gave Treasury, the State Department and intelligence agencies 180 days to identify people by “their closeness to the Russian regime and their net worth.”

That deadline is Jan. 29.

Shamed Oligarchs

The list has also become a headache within Treasury, where some officials are concerned it will be conflated with sanctions, a person familiar with the matter said.

Treasury officials are considering keeping some portions of the report classified — which the law allows — and issuing it in the form of a letter from a senior official, Sigal Mandelker, instead of releasing it through the Office of Foreign Assets Control, which issues sanctions.

That would help distinguish it from separate lists of Russians subject to U.S. economic penalties, said the person, who spoke on condition of anonymity.

“You’re going to have people getting shamed. It’s a step below a sanction because it doesn’t actually block any assets, but has the same optics as sanctions — you’re on a list of people who are engaged in doing bad things,” said Erich Ferrari, who founded Ferrari & Associates in Washington and has helped people get removed from the sanctions designation list.

Corruption Index

The report must include “indices of corruption” with the oligarch’s names and list any foreign assets they may own. Lawmakers expect the list to provide a basis for future punitive actions against Russia.

“Because of the nervousness that the Russian business community is facing, a number of oligarchs are already beginning to wind back businesses, treating them as if they are already designated, to stay ahead of it,” said Daniel Tannebaum, head of Pricewaterhousecoopers LLP’s global financial sanctions unit.

He advises a handful of wealthy Russian individuals and some businesses who he declined to identify.

Treasury’s terrorism and financial intelligence unit is working with the State Department and Office of National Intelligence to complete the report, said a spokesman who declined to elaborate on the criteria for the list or whether it would be made public.

“It should be released in the near future,” Treasury Secretary Steve Mnuchin said at a White House briefing. ‘It’s something we’re very focused on.”

‘Allows Mischief’

The list’s impact will depend on how it’s released, said Adam Smith, a former senior adviser in Treasury’s sanctions unit and now a partner at Gibson, Dunn & Crutcher LLP in Washington.

The law is “written in a way that it allows mischief if the administration wanted to go a different way,” Smith said. “If the president wanted to provide little or a lot and be very selective, he has the ability to do that.”

That discretion partly flows from the criteria used to assemble the list, which Congress left up to Treasury.

Senator Ben Cardin of Maryland, the ranking Democrat on the committee on foreign relations, said he would like to see “as much transparency as possible” from Treasury when it finishes the list.

Russia has sought to defend its elites. Putin warned of worsening U.S. sanctions last month and introduced a capital amnesty program to encourage wealthy nationals to repatriate some of their overseas assets.

He also approved a plan to issue special bonds designed to give the wealthy a way to hold their dollar assets out of reach of the U.S. Treasury.

‘Disgusting’ Relations

While compilation of the list doesn’t mean there’ll be a new round of tit-for-tat sanctions, Russia will react to any punitive measures against its business people, Kremlin spokesman Dmitry Peskov told reporters on a conference call Friday.

“The principle of reciprocity remains,” and it would be for Putin to decide on the best response, he said.

Prime Minister Dmitry Medvedev, a Putin lieutenant for two decades, called the state of the relationship “disgusting” in November.

Congress has also requested that Treasury submit an impact analysis of potential sanctions on Russian sovereign bonds. A Treasury spokesman said its international affairs office is working on the analysis.

U.S. sanctions on the bonds would deal a major blow to Russia’s finances, raising the prospect of a selloff in the bond market, posing a risk to the ruble and the potential for higher borrowing costs.

The Russian Finance Ministry relies on debt to cover budget shortfalls and is seeking to borrow $18 billion domestically in 2018.

Iran’s Cyber Forces under IRGC Target Dissenters/Enemies

NIN is not Nine Inch Nails but rather the Supreme Leader’s tightly controlled internet platform known as the National Internet Network. It operates somewhat like an fee based system, those that can afford and pay more for access and usage get the best speed and less government oversight. The poorer class and the dissenters are controlled by the regime and not only vulnerable to the throttling of service but are subject to phishing operations, hacks and DDoS outages, all at the direction of the regime.

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It almost sounds like a marriage between the U.S. version/marriage of Google, Facebook and NSA, right? Well it is.

The NIN can filter key words and phrases and send users only to the sites it approved, according to the CHRI report. The government has also limited access to thousands of sites and platforms, including Facebook and YouTube. It is attempting to replace search engines like Google with its own state-approved versions.

Iran has also been able to influence how people use the internet through pricing. While there are private internet service providers (ISPs), they are still under government control, allowing state-run infrastructure companies to set up a tiered plan where access to international internet sites costs more than domestic. This drives traffic away from the global internet and to the NIN.

It’s not just internet censorship that Iranians are facing. The report also highlights state-sponsored cyberattacks and phishing schemes. State security agencies like the Islamic Revolutionary Guard Corps, a branch of the armed forces meant to protect the Islamic system, have hacked into individual and private online communications and arrested people on the basis of their content, which is technically illegal under Iranian law.

DDoS attacks, which aim to make specific websites unavailable or limit access to information by flooding them with illegitimate traffic, have become more prominent during politically sensitive times as well, according to the report. During the election in 2016, reformist and centrist candidates like Gaam-e Dovvom faced multiple attacks. The report said many of these are also internal attacks through the government.

Meanwhile, Iranians are not blind to the extensive surveillance they are facing online. As we’ve reported, many internet users use VPNs and other apps to try and circumvent the censorship. And millions of Iranians have turned to the Toronto-born Psiphon app to use the internet during the protests in December and this month. More here.

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Tehran has become increasingly adept at conducting cyber espionage and disruptive attacks against opponents at home and abroad, ranging from Iranian civil society organizations to governmental and commercial institutions in Israel, Saudi Arabia, and the United States.

A new report by carnegiendowment.org evaluates Iran’s Cyber threat environment. Just as Iran uses proxies to project its regional power, Tehran often masks its cyber operations using proxies to maintain plausible deniability. Yet such operations can frequently be linked to the country’s security apparatus, namely the Ministry of Intelligence and Islamic Revolutionary Guard Corps.

While Iran does not have a public strategic policy with respect to cyberspace, its history demonstrates a rationale for when and why it will engage in attacks. Iran uses its capabilities in response to domestic and international events. As conflict between Tehran and Washington subsided after the 2015 nuclear deal, so too did the cycle of disruptive attacks. However, Iran’s decisionmaking process is obscured and its cyber capabilities are not controlled by the presidency, as evident in cases of intragovernmental hacking.

The report claims that the United States is reliant on an inadequately guarded cyberspace and should anticipate that future conflicts, online or offline, could trigger cyber attacks on U.S. infrastructure. The first priority should be to extend efforts to protect infrastructure and the public, including increased collaboration with regional partners and nongovernmental organizations targeted by Iran. More details here.

The U.S. Army War College recently included this concern: In late-2011, the executive chairman of Google stated, “The Iranians are unusually talented in cyber war for some reason we don’t fully understand.”3 Stopping a cyber adversary from disrupting activity or stealing intellectual property has been the primary concern of government and private sector organizations, but in the military and intelligence communities, there are other concerns about Iran.

Prior to 2009, much of Iran’s cyber efforts were focused internally on countering government dissidence. The influential Iranian Revolutionary Guard Corp (IRGC) proposed the development of an Iranian Cyber Army in 2005 to combat internal threats. It sought out professional hackers through voluntary means or by using blackmail and threats to boost its ranks. In early March 2012, Supreme Leader of Iran Ayatollah Ali Khameni publicly announced to state media the creation by decree of a new Supreme Council of Cyberspace charged “to oversee the defense of the Islamic Republic’s computer networks and develop new ways of infiltrating or attacking the computer networks of its enemies.”7 It included heads of intelligence, militia, security, media chiefs, and the IRGC. It has its own budget and offices along with the power to enact laws. Additionally, the IRGC stated that a secure internal network for high-level command and control called “Basir” (Persian for perceptive) was created to counter outside threats to online activities.8 However, it is clear from its actions against opposition influences and dissident groups that the regime continues internal censorship and monitoring as well. Furthermore, Reporters Without Borders, in its 2012 annual report of countries that restrict internet access, filter content, and imprison bloggers, “ranked Iran the number one enemy of the Internet…ahead of 11 other countries—including Saudi Arabia, Bahrain, Syria, China, and Belarus.”9

In late-2011, Iran invested at least $1 billion dollars in cyber technology, infrastructure, and expertise.10 In March 2012, the IRGC claimed it had recruited around 120,000 personnel over the past 3 years to combat “a soft cyber war against Iran.”11 In early-2013, an IRGC general publically claimed Iran had the “fourth biggest cyber power among the world’s cyber armies.”12 Regardless of the numbers, the fact is that Iran’s cyber capability continues to mature. The IRGC has its own Cyber Defense Command which recruits and trains cyber warriors to spy on dissidents on the internet and spread Iranian government propaganda.13 The IRGC also now owns and controls Iran’s largest communication company and manages the skilled cyber technicians and specialists of Iran’s Cyber Army trained to hack into opposition websites and conduct other types of offensive cyber operations. On the law enforcement side, the FETA police (in Persian it literally means Police of the Space of Creating and Exchanging Information) handle typical internet crimes as well as more opaque enforcement activities such as political and security crimes. There are other Iranian organizations and companies recruited and/or affiliated with Iran’s cyber capabilities, either knowingly or by loose association. The full summary is here.

DoJ’s Bruce Ohr Demoted Again, Project Cassandra?

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That’s it? On second thought, keep him employed to cough up the goods on Project Cassandra. More on that below. As an aside, in late December, Jeff Sessions ordered a complete review of Project Cassandra.

FNC: A Justice Department official demoted late last year for concealing his meetings with the men behind the anti-Trump “dossier” has been stripped of yet another title, Fox News has learned.

Bruce Ohr is no longer head of the Organized Crime Drug Enforcement Task Force.

Separately, sources familiar with the discussions tell Fox News that the Justice Department is expected to comply with demands from the House Intelligence Committee to provide Ohr for an interview. He is scheduled to visit the committee on Jan. 17, sources said.

Fox News first reported in December that Ohr had been demoted from the position of associate deputy attorney general, after it was revealed he had conducted undisclosed meetings with dossier author Christopher Steele and Glenn Simpson of Fusion GPS, the opposition research firm that produced the salacious document.

Fox News also reported that his wife Nellie Ohr worked for Fusion GPS, specifically on research related to the dossier.

At the time of his demotion, DOJ officials told Fox News that Bruce Ohr had been “wearing two hats,” and would fall back to his other title and portfolio – as head of OCDETF.

Now, Ohr has been stripped of that role as well; former deputy director Thomas Padden is now acting director.  It is unclear where Ohr has landed, only that he is still an employee with the Department of Justice.

One DOJ insider joked that Ohr might end up in “one of those offices without a phone.”

Fox News has also confirmed that Bruce Ohr, as the head of OCDETF, was directly involved with Project Cassandra, the interagency investigation spearheaded by the DEA that tracked a massive international drug and money laundering scheme allegedly run by Hezbollah.

The project recently was the subject of a critical and lengthy Politico report looking at how the Obama administration may have hampered the investigation. Those closest to Project Cassandra, including Derek Maltz, the now-retired supervisory DEA agent who was a major player in the operation, claim the project and its potential prosecutions were sidelined by senior Obama administration officials who didn’t want to upset Iran in the lead-up to the historic nuclear deal with Tehran in 2015.

Attorney General Jeff Sessions has promised to look into what happened with the investigation.

He said in a statement last month: “While I am hopeful that there were no barriers constructed by the last admission to allowing DEA agents to fully bring all appropriate cases under Project Cassandra, this is a significant issue for the protection of Americans. We will review these matters and give full support to investigations of violent drug trafficking organizations.”

Sources close to the attorney general told Fox News that he was recently made aware of Ohr’s role in Project Cassandra and that Sessions is personally involved in the review and frequently asks for updates.

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The 76 page criminal complaint for Project Cassandra is here.

Hezbollah Business Affairs Component 85 tons of cocaine was sold to Los Zetas one of the most violent Mexican cartels. Bruce Ohr was head of the teams assigned to Project Cassandra.

The United States Drug Enforcement Administration (DEA) (2016) announced significant enforcement activity including arrests targeting Lebanese Hizballah’s External Security Organization Business Affairs Component (BAC), which is involved in international criminal activities such as drug trafficking and drug proceed money laundering. These proceeds are used to purchase weapons for Hizballah for its activities in Syria. This ongoing investigation spans the globe and involves numerous international law enforcement agencies in seven countries, and once again highlights the dangerous global nexus between drug trafficking and terrorism.

This effort is part of DEA’s Project Cassandra, which targets a global Hizballah network responsible for the movement of large quantities of cocaine in the United States and Europe. This global network, referred to by law enforcement as the Lebanese Hizballah External Security Organization Business Affairs Component (BAC), was founded by deceased Hizballah Senior Leader Imad Mughniyah and currently operates under the control of Abdallah Safieddine and recent U.S.-designated Specially Designated Global Terrorist (SDGT) Adham Tabaja. Members of the Hizballah BAC have established business relationships with South American drug cartels, such as La Oficina de Envigado, responsible for supplying large quantities of cocaine to the European and United States drug markets. Further, the Hizballah BAC continues to launder significant drug proceeds as part of a trade based money laundering scheme known as the Black Market Peso Exchange.

“These drug trafficking and money laundering schemes utilized by the Business Affairs Component provide a revenue and weapons stream for an international terrorist organization responsible for devastating terror attacks around the world,” said DEA Acting Deputy Administrator Jack Riley.  “DEA and our international partners are relentless in our commitment to disrupt any attempt by terrorists and terrorist organizations to leverage the drug trade against our nations. DEA and our partners will continue to dismantle networks who exploit the nexus between drugs and terror using all available law enforcement mechanisms.”

Beginning in February 2015, based on DEA investigative leads, European authorities initiated an operation targeting the network’s criminal activities in that region. Since then, law enforcement authorities, closely supported by DEA, have uncovered an intricate network of money couriers who collect and transport millions of euros in drug proceeds from Europe to the Middle East. The currency is then paid in Colombia to drug traffickers using the Hawala disbursement system. A large portion of the drug proceeds was found to transit through Lebanon, and a significant percentage of these proceeds are benefitting terrorist organizations, namely Hizballah.

This investigation is a result of leads developed during the investigation into the Lebanese Canadian Bank.

The combination of aggressive international law enforcement investigations and Treasury’s ongoing sanctions (see below) pressure shows the scope of the global commitment to diminish the ability of Hizballah and its financial supporters to move funds worldwide.

Enforcement Action

With DEA and Customs and Border Protection (CBP) working closely with foreign counterparts in France, Germany, Italy and Belgium, authorities arrested top leaders of the European cell of this Lebanese Hizballah External Security Organization BAC last week. The most significant arrest was of the U.S.-designated SDGT Mohamad Noureddine, a Lebanese money launderer who has worked directly with Hizballah’s financial apparatus to transfer Hizballah funds via his Lebanon-based company Trade Point International S.A.R.L. and maintained direct ties to Hizballah commercial and terrorist elements in both Lebanon and Iraq.

The CPB National Targeting Center partnered with DEA and international counterparts such as Europol in this investigation. CBP’s continued cooperation with the DEA , and European law enforcement counterparts is a vital component in dismantling complex global drug trafficking and money laundering networks as well as enhancing the security of the United States border.

U.S. Treasury Sanctions

Separately, the U.S. Department of the Treasury announced sanctions last week targeted Hizballah’s financial support network by designating Hizballah-affiliated money launderers Noureddine and Hamdi Zaher El Dine, as well as Trade Point International S.A.R.L, a company owned or controlled by Noureddine, pursuant to Executive Order 13224. This order targets terrorists and those providing support to terrorists or acts of terrorism.  Noureddine and El Dine were designated for providing financial services to or in support of Hizballah, a Specially Designated Global Terrorist.  Trade Point International S.A.R.L. was designated for being owned or controlled by Noureddine. As a result of Treasury’s action, all assets of the designated individuals or entities that are located in the United States or in the possession or control of U.S. persons are frozen, and U.S. persons are generally prohibited from engaging in transactions with them.

As part of its designation, Adam J. Szubin, Acting Under Secretary for Terrorism and Financial Intelligence, stated that, “Hizballah needs individuals like Mohamad Noureddine and Hamdi Zaher El Dine to launder criminal proceeds for use in terrorism and political destabilization.  We will continue to target this vulnerability, and expose and disrupt such enablers of terrorism wherever we find them.”

Participating offices and agencies:

DEA Philadelphia, DEA Miami, DEA Newark, DEA New York, DEA Special Operations Division, DEA Bilateral Investigative Unit, DEA country offices in Europe, as well as Bogota and Cartagena
U.S. Customs and Border Protection
U.S. Treasury Financial Crimes Enforcement Network (FinCEN)
U.S. Treasury Office of Foreign Assets Control (OFAC)
EUROPOL
EUROJUST

Brazil/Petrobras: $2.95 B Settlement, Operation Car Wash

In January of 2017, a plane crashed.

SAO PAULO (Reuters) – Brazilian Supreme Court Justice Teori Zavascki, who was overseeing a graft investigation into scores of powerful politicians, was killed in a plane crash on Thursday, raising questions about who will take over the country’s biggest ever corruption case.

Rescuers found three bodies in the wreckage of the small, twin-prop plane that crashed off the coast of Rio de Janeiro state amid heavy rains, firefighters said. Federal prosecutors and police said they would immediately open an investigation in addition to that of aviation authorities.

Zavascki, 68, had in recent weeks been reviewing explosive testimony from executives at engineering group Odebrecht, expected to implicate an array of politicians in a vast kickback scandal centering on state-run oil company Petrobras and other enterprises. More here.

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Under the proposed settlement, Petrobras has agreed to pay US$ 2.95 billion to resolve claims in two installments of US$983 million and a last installment of US$984 million. The first installment will be paid within 10 days of preliminary approval of the settlement by the court. The second installment will be paid within 10 days of final approval of the settlement. The third installment will be paid by the later of (i) six months after final approval, or (ii) January 15, 2019. The total settlement amount will be recognized in the fourth quarter of 2017.

The agreement does not constitute any admission of wrongdoing or misconduct by Petrobras. In the agreement, Petrobras expressly denies liability. This reflects its status as a victim of the acts uncovered by Operation Car Wash, as recognized by Brazilian authorities including the Brazilian Supreme Court. As a victim of the scheme, Petrobras has already recovered R$1.475 billion in restitution in Brazil and will continue to pursue all available legal remedies from culpable companies and individuals.

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Since the scheme was detected three years ago, prosecutors have yet to reach bottom in their investigation—and the total sum of payoffs may exceed $5 billion. The criminality may also cost Petrobras, South America’s largest corporation, $13 billion in contract losses and legal settlements, and it’s already resulted in the layoff of thousands of Petrobras workers. Meanwhile, Odebrecht, the Brazilian construction giant that led the bribery bacchanal, is a disgraced and crumbling conglomerate. Its boss, Marcelo Odebrecht, was sentenced last year to 19 years in prison. More here.

*** In 2014: Although President Dilma Rousseff has not been implicated in any wrongdoing related to “Operation Car Wash,” she did serve as the Chairwoman of Petrobras from 2003 to 2010, and having her name connected with a company mired in scandal likely won’t bode well for her reelection campaign. According to a recent poll, she is trailing opponent Marina Silva in Brazil’s October elections.

Rousseff has already been criticized for her role in the 2012 purchase of an extremely overpriced Texas oil refinery, a deal that began when Rousseff was still chairwoman. Brazilian investigators are looking into whether or not the purchase of the refinery could be linked to “Operation Car Wash,” although such a link would not necessarily mean Rousseff had any knowledge of the money laundering scheme. More here.

Obama/Democrats DID vote for the Wall and an Immigration Proposal

June, 1995: The White House today welcomed a Federal advisory panel’s recommendation to cut legal immigration by one-third. But the proposals met fierce opposition from Hispanic, Asian-American, Roman Catholic and Jewish groups, as well as from the National Association of Manufacturers.

Barbara Jordan, chairwoman of the panel, the Commission on Immigration Reform, delivered the plan to President Clinton, and he congratulated the panel. “Consistent with my own views, the commission’s recommendations are pro-family, pro-work, pro-naturalization,” he said.

Mr. Clinton said the panel had “laid out a road map for Congress to consider.” His press secretary, Michael D. McCurry, said that “the President indicated to Barbara Jordan today that he will support such reductions,” which would represent the biggest change in immigration policy in more than 40 years.

In addition, Mr. Clinton said the proposal “appears to reflect a balanced immigration policy that makes the most of our diversity while protecting the American work force so that we can better compete in the emerging global economy.” More here.

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*** For an 8 minute video clip of then Senator Barack Obama on the matter of immigration and the border wall, go here.   In a separate speech on April 3, 2006, Barack Obama included these concepts:

The American people are a welcoming and generous people. But those who enter our country illegally, and those who employ them, disrespect the rule of law. And because we live in an age where terrorists are challenging our borders, we simply cannot allow people to pour into the United States undetected, undocumented, and unchecked. Americans are right to demand better border security and better enforcement of the immigration laws.

To begin with, the agencies charged with border security would receive new technology, new facilities, and more people to stop, process, and deport illegal immigrants. But while security might start at our borders, it doesn’t end there. Millions of undocumented immigrants live and work here without our knowing their identity or their background. We need to strike a workable bargain with them. They have to acknowledge that breaking our immigration laws was wrong. They must pay a penalty, and abide by all of our laws going forward. They must earn the right to stay over a 6-year period, and then they must wait another 5 years as legal permanent residents before they become citizens.

But in exchange for accepting those penalties, we must allow undocumented immigrants to come out of the shadows and step on a path toward full participation in our society. In fact, I will not support any bill that does not provide this earned path to citizenship for the undocumented population–not just for humanitarian reasons; not just because these people, having broken the law, did so for the best of motives, to try and provide a better life for their children and their grandchildren; but also because this is the only practical way we can get a handle on the population that is within our borders right now.

And before any guestworker is hired, the job must be made available to Americans at a decent wage with benefits. Employers then need to show that there are no Americans to take these jobs. I am not willing to take it on faith that there are jobs that Americans will not take. There has to be a showing. If this guestworker program is to succeed, it must be properly calibrated to make certain that these are jobs that cannot be filled by Americans, or that the guestworkers provide particular skills we can’t find in this country. The full text is here.

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In part from Politifact:

The Secure Fence Act of 2006, which was passed by a Republican Congress and signed by President George W. Bush, authorized about 700 miles of fencing along certain stretches of land between the border of the United States and Mexico.

The act also authorized the use of more vehicle barriers, checkpoints and lighting to curb illegal immigration, and the use of advanced technology such as satellites and unmanned aerial vehicles.

At the time the act was being considered, Barack Obama, Hillary Clinton and Chuck Schumer were all members of the Senate. (Schumer of New York is now the Senate minority leader.)

Obama, Clinton, Schumer and 23 other Democratic senators voted in favor of the act when it passed in the Senate by a vote of 80 to 19.