TRAP Act of 2021

Anticorruption issues, anti-money laundering issues: Spoke about 2021 Summit for Democracy and anticorruption issues Anticorruption issues: Spoke about 2021 Summit for Democracy and anticorruption issues Countering Russian and Other Overseas Kleptocracy Act (CROOK Act) (H.R. 402, S. 158): To impose a penalty on violators of Foreign Corrupt Practices Act and invest those proceeds into anticorruption programs overseas Justice for Victims of Kleptocracy Act (S. 2010, H.R. 3781): To require the Department of Justice to publish and regularly update its website with an accounting of property that is forfeited to the United States as a result of foreign government corruption Foreign Extortion Prevention Act (H.R. 3887): To criminalize the demand side of foreign bribery Revealing and Explaining Visa Exclusions for Accountability and Legitimacy (REVEAL Act) (H.R. 4557, S. 2392): To provide the President with permissive authority to reveal the names of individuals banned from the USA under section 212(a)3(c) of the Immigration and Nationality Act (visa bans) Transnational Repression Accountability and Prevention (TRAP Act) (H.R. 4806, S. 2010): Establishes priorities of U.S. engagement at INTERPOL, identifies areas for improvement in the U.S. governments response to INTERPOL abuse, and protects the U.S. judicial system from abusive INTERPOL notices Combating Global Corruption Act (H.R. 4322, S. 14): Creates a country-by-country tiered reporting requirement based on compliance with anti-corruption norms and commitments. Those countries in the lowest tier will have their leadership considered for Global Magnitsky sanctions Foreign Corruption Accountability Act (H.R. 3887): Authorizes visa bans on foreign persons who use state power to engage in acts of corruption against any private persons Global Magnitsky Human Rights Accountability Reauthorization Act (S.93; House bill number TBD): "Permanently authorizes the President to impose visa- and property-blocking sanctions based on violations of human rights, and revises the President's authority to impose these sanctions" Counter-Kleptocracy Act (H.R. 5209): 7 transparency, information-sharing, and anti-bribery measures House National Defense Authorization Act (H.R. 4350), including amendments #91, #108, #109, #259 #422, #633, #638, #655, #722, FMS Notification (Malinowski), Navalny 35 (Malinowski): To include in the Act the Foreign Corruption Accountability Act (authorizes visa bans on foreign persons who use state power to engage in acts of corruption against any private person); Justice for Victims of Kleptocracy Act (to require the Department of Justice to publish and regularly update its website with an accounting of property that is forfeited to the United States as a result of foreign government corruption), as well as Amendment #91 (to require the DoD to codify current post-government employment restrictions in its acquisition law); Amendment #108 (to extend the duration of post-employment restrictions on lobbying and representational activities from one year to two); Amendment #109 (to apply whistleblower protections to all federal coronavirus relief programs); Amendment #259 (the Transnational Repression Accountability and Prevention Act and the Combating Global Corruption Act); Amendment #422 (the Countering Russian and Other Overseas Kleptocracy Act); Amendment #633 (to make the database of ethics opinions maintained by the DoD available to the public); Amendment #638 (to extend the recusal period from one to four years for industry officials entering public service at the DoD); Amendment #655 (Reauthorization of Global Magnitsky Act); Amendment #722 (to require contractors to report their hiring of former senior Pentagon officials and officers); FMS Notification (strengthen oversight to FMS deals); Navalny 35 bill (Malinowski, bill number TBD, to require the Administration to evaluate for Global Magnitsky sanctions the 35 Russian human rights abusers and kleptocracy identified by Russian political opposition leader Alexei Navalny) Senate National Defense Authorization Act of Fiscal Year 2022 (S. 2792): To include in the Act six bills/measures (Foreign Corruption Accountability Act, Justice for Victims of Kleptocracy Act, Transnational Repression Accountability and Prevention Act, Combating Global Corruption Act, Global Magnitsky Reauthorization Act, and "Navalny 35" bill (Malinowski; bill number TBD; to require the Administration to evaluate for Global Magnitsky sanctions the 35 Russian human rights abusers and kleptocracy identified by Russian political opposition leader Alexei Navalny)); in addition, measures to modernize and strengthen whistleblower protections for government contractors and grantees (S. Amdt 3899 to S. Amdt 3867 amending H.R. 4350)

Client expense: $25,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Justice, Dept of (DOJ), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Agency for International Development (USAID), White House Office

Issues related to combating global corruption, incorporation transparency, and defending our national security H.R. 402, S. 158, Countering Russian and Other Overseas Kleptocracy Act (CROOK Act) H.R. 5209, Counter-Kleptocracy Act S. 93, The Global Magnitsky Human Rights Accountability Reauthorization Act S. 1591, H.R. 4806, Transnational Repression Accountability and Prevention (TRAP) Act of 2021 S. 2986, A bill to require a review of sanctions with respect to Russian kleptocrats and human rights abusers. S. 14, H.R. 4322, Combating Global Corruption Act of 2021

Client expense: $10,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Security Council (NSC), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of

Anticorruption issues, anti-money laundering issues (White House): Spoke about 2021 Summit for Democracy Anticorruption issues, anti-money laundering issues (State Dept., USAID): Spoke about anti-corruption issues and 2021 Summit for Democracy Countering Russian and Other Overseas Kleptocracy Act (CROOK Act) (H.R. 402, S. 158): To impose a penalty on violators of Foreign Corrupt Practices Act and invest those proceeds into anti-corruption programs overseas Justice for Victims of Kleptocracy Act (S. 2010, H.R. 3781): To require the Department of Justice to publish and regularly update its website with an accounting of property that is forfeited to the United States as a result of foreign government corruption Foreign Extortion Prevention Act (H.R. 3887): To criminalize the demand side of foreign bribery Revealing and Explaining Visa Exclusions for Accountability and Legitimacy (REVEAL Act) (H.R. 4557, S. 2392): To provide the President with permissive authority to reveal the names of individuals banned from the USA under section 212(a)3(c) of the Immigration and Nationality Act (visa bans) Transnational Repression Accountability and Prevention (TRAP Act) (H.R. 4806, S. 2010)_ Establishes priorities of U.S. engagement at INTERPOL, identifies areas for improvement in the U.S. governments response to INTERPOL abuse, and protects the U.S. judicial system from abusive INTERPOL notices Section 3310 of S. 1260; Urging leadership to support Section 3310 of S. 1260, which would create notification and publication requirements for international agreements and certain non-binding instruments Combating Global Corruption Act (H.R. 4322, S. 14): Creates a country-by-country tiered reporting requirement based on compliance with anti-corruption norms and commitments. Those countries in the lowest tier will have their leadership considered for Global Magnitsky sanctions Foreign Corruption Accountability Act (H.R. 3887): Authorizes visa bans on foreign persons who use state power to engage in acts of corruption against any private persons Global Magnitsky Human Rights Accountability Reauthorization Act (S.93; House bill number TBD): "Permanently authorizes the President to impose visa- and property-blocking sanctions based on violations of human rights, and revises the President's authority to impose these sanctions" Counter-Kleptocracy Act (H.R. 5209): Transparency, information-sharing, and anti-bribery measures House National Defense Authorization Act (H.R. 4350), including amendments #91, #108, #109, #259 #422, #633, #638, #655, #722, FMS Notification (Malinowski), Navalny 35 (Malinowski): To include in the Act the Foreign Corruption Accountability Act (authorizes visa bans on foreign persons who use state power to engage in acts of corruption against any private person); Justice for Victims of Kleptocracy Act (to require the Department of Justice to publish and regularly update its website with an accounting of property that is forfeited to the United States as a result of foreign government corruption), as well as Amendment #91 (to require the DoD to codify current post-government employment restrictions in its acquisition law); Amendment #108 (to extend the duration of post-employment restrictions on lobbying and representational activities from one year to two); Amendment #109 (to apply whistleblower protections to all federal coronavirus relief programs); Amendment #259 (the Transnational Repression Accountability and Prevention Act and the Combating Global Corruption Act); Amendment #422 (the Countering Russian and Other Overseas Kleptocracy Act); Amendment #633 (to make the database of ethics opinions maintained by the DoD available to the public); Amendment #638 (to extend the recusal period from one to four years for industry officials entering public service at the DoD); Amendment #655 (Reauthorization of Global Magnitsky Act); Amendment #722 (to require contractors to report their hiring of former senior Pentagon officials and officers); FMS Notification (strengthen oversight to FMS deals); Navalny 35 bill (Malinowski, bill number TBD, to require the Administration to evaluate for Global Magnitsky sanctions the 35 Russian human rights abusers and kleptocracy identified by Russian political opposition leader Alexei Navalny) Senate National Defense Authorization Act of Fiscal Year 2022 (S. 2792): To include in the Act six bills/measures (Foreign Corruption Accountability Act, Justice for Victims of Kleptocracy Act, Transnational Repression Accountability and Prevention Act, Combating Global Corruption Act, Global Magnitsky Reauthorization Act, and "Navalny 35" bill (Malinowski; bill number TBD; to require the Administration to evaluate for Global Magnitsky sanctions the 35 Russian human rights abusers and kleptocracy identified by Russian political opposition leader Alexei Navalny)