Did Trump Violate the Corrupt Foreign Practices Act?

The New Yorker has been publishing really groundbreaking reports on Trump’s business dealings with Russian oligarchs. Rachael Maddow featured the recent Trump, Putin, and the New Cold War in a recent episode, and for what it’s worth after that, I recommend it, too.
I’m writing about a more recent New Yorker article: Donald Trump’s Worst Deal. It’s about a real estate deal in Baku, the capital of Azerbaijan, a small country from the former Soviet Union, and now one of the most corrupt countries in the world, as measured by the Transparency International Corruption Perception Index.
The Trump Organization joined a project there to build what would be called the Trump International Hotel & Tower Baku. Trump had little investment and no business risk, but received millions in payments. Nice work, if you can get it.
When Trump first announced his candidacy in 2015, there were articles in Mother Jones, the Washington Post and the AP about how deeply questionable this project was. Here’s more from the New Yorker:
In one of the cables, a U.S. diplomat described Ziya Mammadov as “notoriously corrupt even for Azerbaijan.” The Trump Organization’s chief legal officer, Alan Garten, told reporters that the Baku hotel project raised no ethical issues for Donald Trump, because his company had never engaged directly with Mammadov.
According to Garten, Trump played a passive role in the development of the property: he was “merely a licensor” who allowed his famous name to be used by a company headed by Ziya Mammadov’s son, Anar, a young entrepreneur.
The Trump Organization broke their ties to it a month after Trump won the election.
What makes this interesting is the Corrupt Foreign Practices Act, which requires American businesses to ensure that neither they nor their foreign partners are involved in bribery, or trading with prohibited nations like Iran. The Act has teeth — penalties can be hundreds of millions of dollars — and claws — it’s a criminal offense: can go to jail.
This isn’t a ‘see no evil’ law. They don’t care about your intent, even if you swear you didn’t notice the corruption. You still go to jail. Companies are required to do their due diligence to ensure everything is legal.
Trump’s organization dealt with Anar Mammadov and signed contracts with Elton Mammadov, Anar’s brother, member of the Azeri Parliment, and, now, owner of Baku XXI Century, and Trump Tower Baku.
There was no evidence of Trump’s Organization doing much due diligence. That almost makes sense, but only if you don’t care, and you’re desperate for money. But then, Trump, never especially successful, was struggling.
But talk about a skeleton in his closet! Violating the Corrupt Foreign Practices Act to help bribe Azerbaijani government officials, and possibly launder money from the Iranian National Guard, so they can pay international terrorists to plot against the US.
Kinda explains why he’s going so far over the top, trying to distract us from the Russian connections. This wasn’t especially egregious, for Trump.
I wonder what else he’s been up to after the US banks stopped financing his real estate fiascos?

