On Wednesday Congressman James Comer and some colleagues held their.long-promised press conference detailing new information about corruption of the President of the United States. I happened to be driving at the time (not common for Manhattanites like me) and so listened to a portion of the event. The oral presentation was expressed in general terms that mostly reiterated things that we already knew. Added to our previous knowledge was information from recently produced and analyzed bank records that enabled pinpointing exact dates, sources and amounts of various payments from foreign entities to intermediary shell corporations and thence on to various Bidens.

The press conference was the occasion for release of a Memorandum with the May 10 date titled “Comer Reveals New Evidence in Biden Family’s Influence Peddling Schemes,” referred to in the Oversight Committee’s press release as the “second bank records memorandum.” The Committee had previously on March 16 release another Memorandum titled “New Evidence Resulting from the Oversight Committee’s Investigation into the Biden Family’s Influence Peddling and Business Schemes,” which is referred to in the press release as the “first bank records memorandum.” The two memoranda provide details of payments totaling multiple millions of dollars from entities in China (first memorandum) and Romania (second memorandum) to various Biden-related entities.

And thus little by little we learn more details about our current President accepting large amounts of money from multiple foreign countries, one of which is our most significant geopolitical adversary. I don’t think I’m the only one whose jaw drops when I find out that our “leaders” at the very highest levels — in other words, the President — think that it’s perfectly OK to take millions from foreign governments that include global adversaries, hide it with intermediaries and shell companies, and refuse to answer questions of any kind. Wasn’t there a time when the United States was a place where this kind of thing just was not done? Well, I guess the Clintons ended that era (most significantly and brazenly with the Clinton Foundation, which raised hundreds of millions from foreign powers when everyone knew Hillary would shortly be running for President, but to be fair was out of office at the time). The most significant thing about the Clintons’ corruption was that despite its enormous crookedness, the press never stopped protecting and even promoting them, even to this day. Biden learned that lesson, and then took things to a whole new level, including that he and/or his family took millions even when he was in office as Vice President.

Some relevant details of the conduct.

As we learn more details of the conduct, many of those become relevant to understanding the gravity of the situation.

The first bank records memorandum traces a $3 million payment made on March 1, 2017 (approximately 40 days after Joe Biden left office as Vice President) by State Energy HK Limited (a Chinese state-controlled entity) to Robinson Walker LLC (an intermediary controlled by Biden crony Rob Walker), and subsequent distribution of more than $2 million out of the $3 million to various Biden family members and affiliates, between March and May 2017.

The second bank records memorandum focuses on more than a million dollars in payments from a Romanian businessman named Gabriel Popoviciu, and his company Bladon Enterprises, to various Biden-related entities, again via the Robinson Walker intermediary. All but one of the payments from Bladon to Robinson Walker took place prior to January 20, 2017, that is, while Joe Biden was Vice President.

The bank account titles of the Biden-related entities receiving payments from these two distributions include “Robert Biden” (Robert is Hunter’s first name), “Biden” (with no first name given), “Hallie Biden” (that’s Beau’s widow, with whom Hunter then had a relationship), and corporate entities including Owasco P.C. and EEIG. The memoranda assert that other Bidens, including the President’s brother James, had an interest in entities receiving some of the payments, as did close business associates such as James Gilliar and Rob Walker.

The memoranda also assert that much of the bank information has come as a result of subpoenas issued by the Committee. However, various sources, including the New York Post here, report that along the way banks filed some 150 so-called Suspicious Activity Reports with respect to these and other Biden transactions.

Indicia of corruption.

Nobody could possibly miss the fact that the Bidens are behaving here like people with something big to hide. At least when a country like Qatar contributed a million or two to the Clinton Foundation, they just sent in the money. Hey, this was a “charity” (even if Bill and Hillary skimmed 10% for “salaries” and personal expenses). Here it’s intermediaries and shell companies and, when given to individuals it’s given in increments of say $10,000 to $50,000. Nobody would bother with this if it was on the up and up.

And could it possibly be that the Bidens provided some sort of legitimate service for the money? No. If they did, they would immediately come forward and say what the service is. And even if you might believe that Hunter Biden provided some legitimate service (preposterous!), how about Jim Biden or Hallie Biden?

And the fact that the banks filed some 150 SARs is significant. I have suggested to several bank in-house regulatory lawyers (i.e., my former associates) that they should file many more SARs than they do, as a way of covering their asses in the event of predatory government enforcement actions. And they have patiently responded that filing SARs is a difficult and time-consuming process. The fact that 150 of them were filed on the Bidens is truly extraordinary. Clearly the banks were not fooled by the shell companies and dividing the payments into smaller amounts.

Is any of this a crime?

My answer is, probably, but that is not established by these memoranda.

The main issue is that the crime of federal bribery requires some kind of “quid pro quo” of an “official act” by an in-office government official in return for the corrupt payment. That principle was established by the U.S. Supreme Court in the case of former Virgina governor Bob McDonnell in 2016. McDonnell had taken personal gifts totaling about $200,000 from a contributor, but all he had done in return was set up a few meetings. He was initially convicted, but the Supreme Court reversed, ruling that merely setting up meetings was insufficient to constitute the “official act.”

These memoranda do not go at all into what the quid pro quo official act might be. That does not mean that one, or many, do not exist. Has Joe Biden used his powers as President to benefit China in ways that he would not have done if he were not on their payroll? Just today, we have this from National Review via Reuters, headline “Biden Capitulates to China.”

According to a new report from Reuters, the State Department’s “China House” team was ordered to stand down on some long-planned measures targeting the Chinese Communist Party’s malfeasance.

Many more similar examples can be easily compiled. And then there is the whole subject of Hunter Biden’s service on the board of Ukrainian energy company Burisma, for which he received about $3 million, most while Joe Biden was in office and in charge of U.S. policy toward Ukraine. That subject does not figure at all in these memoranda. Joe Biden was caught on tape bragging that he got the prosecutor who was investigating Burisma corruption fired by threatening to withhold U.S. foreign aid. I have previously written several posts about why this is a laydown bribery case.

Justice Department corruption.

The performance of the Justice Department and its affiliate the FBI becomes more and more despicable each day. Even as Comer, et al., were holding their long-scheduled press conference in Washington, the prosecutors in the Eastern District of New York chose the exact same moment to arrest and arraign freshman Congressman George Santos of Long Island. Santos is a bizarre creature, and I don’t intend to stand up for his conduct. But the charges against him appear really trivial compared to what Biden was up to. And Santos is a freshman member of Congress, while Biden is President of the United States. But the timing was clearly orchestrated to give the media the chance to focus coverage on Santos and bury the Biden story. How do you feel about your FBI running cover for the favored political party in that way?

And then there is the question of the 150 SARs. Clearly the government has long been onto the Bidens’ conduct, and done nothing about it. The SARs had to be pried out of them by FOIA requests and subpoenas. Without that, the Bidens would have gotten a complete pass, not only from prosecution, but also from the public ever knowing what was going on.

Media corruption.

And the New York Times played right along with the Justice/FBI game. In yesterday’s print edition, the lead front page headline, covering two of the six columns, was “Santos Is Indicted as Inquiry Claims 3 Finance Schemes” (different headline online). The accompanying story fills the whole two columns above the fold.

And the story about the Congressional inquiry into the Bidens? Nothing whatsoever about that on the front page. Is it anywhere here? Oh yes, here on page A18 there is a headline, “4-Month G.O.P Inquiry Finds No Evidence of Wrongdoing by President.” What? You literally can’t make this up. For those who think that the Times may be ready to give up on Biden and throw him under the bus, I don’t think they’re there yet. They are in full Praetorian Guard mode.