[House Report 105-829]
[From the U.S. Government Printing Office]



                                                 Union Calendar No. 471
105th Congress, 2d Session  -  -  -  -  -  -  -  - House Report 105-829


 
       INVESTIGATION OF POLITICAL FUNDRAISING IMPROPRIETIES AND 
              POSSIBLE VIOLATIONS OF LAW INTERIM REPORT

                               ---------- 

                              SIXTH REPORT

                                 by the

                        COMMITTEE ON GOVERNMENT
                          REFORM AND OVERSIGHT

                             together with

                     ADDITIONAL AND MINORITY VIEWS
                             Volume 1 of 4





November 5, 1998.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed



   INVESTIGATION OF POLITICAL FUND-RAISING IMPROPRIETIES AND POSSIBLE 
                    VIOLATIONS OF LAW--VOLUME 1 OF 4



                                                 Union Calendar No. 471
105th Congress, 2d Session  -  -  -  -  -  -  -  - House Report 105-829


                      INVESTIGATION OF POLITICAL

                     FUNDRAISING IMPROPRIETIES AND

                      POSSIBLE VIOLATIONS OF LAW

                             INTERIM REPORT

                               __________

                              SIXTH REPORT

                                 by the

                        COMMITTEE ON GOVERNMENT

                          REFORM AND OVERSIGHT

                             together with

                     ADDITIONAL AND MINORITY VIEWS

                             Volume 1 of 4





November 5, 1998.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed
                                     

              COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT

                     DAN BURTON, Indiana, Chairman
BENJAMIN A. GILMAN, New York        HENRY A. WAXMAN, California
J. DENNIS HASTERT, Illinois         TOM LANTOS, California
CONSTANCE A. MORELLA, Maryland      ROBERT E. WISE, Jr., West Virginia
CHRISTOPHER SHAYS, Connecticut      MAJOR R. OWENS, New York
CHRISTOPHER COX, California         EDOLPHUS TOWNS, New York
ILEANA ROS-LEHTINEN, Florida        PAUL E. KANJORSKI, Pennsylvania
JOHN M. McHUGH, New York            GARY A. CONDIT, California
STEPHEN HORN, California            CAROLYN B. MALONEY, New York
JOHN L. MICA, Florida               THOMAS M. BARRETT, Wisconsin
THOMAS M. DAVIS, Virginia           ELEANOR HOLMES NORTON, Washington, 
DAVID M. McINTOSH, Indiana              DC
MARK E. SOUDER, Indiana             CHAKA FATTAH, Pennsylvania
JOE SCARBOROUGH, Florida            ELIJAH E. CUMMINGS, Maryland
JOHN B. SHADEGG, Arizona            DENNIS J. KUCINICH, Ohio
STEVEN C. LaTOURETTE, Ohio          ROD R. BLAGOJEVICH, Illinois
MARSHALL ``MARK'' SANFORD, South    DANNY K. DAVIS, Illinois
    Carolina                        JOHN F. TIERNEY, Massachusetts
JOHN E. SUNUNU, New Hampshire       JIM TURNER, Texas
PETE SESSIONS, Texas                THOMAS H. ALLEN, Maine
MICHAEL PAPPAS, New Jersey          HAROLD E. FORD, Jr., Tennessee
VINCE SNOWBARGER, Kansas                        ------
BOB BARR, Georgia                   BERNARD SANDERS, Vermont 
DAN MILLER, Florida                     (Independent) 
RON LEWIS, Kentucky 

                      Kevin Binger, Staff Director
                   Barbara J. Comstock, Chief Counsel
            David A. Kass, Deputy Counsel and Parliamentarian
                 Lisa Smith Arafune, Deputy Chief Clerk
                 Phil Schiliro, Minority Staff Director

                              -----------

          MINORITY STAFF                       MAJORITY STAFF
Kevin Binger, Staff Director        Kristin L. Amerling, Minority 
Barbara Jean Comstock, Chief            Counsel
    Counsel                         Kenneth M. Ballen, Minority Chief 
James C. Wilson, Chief                  Investigative Counsel
    Investigative Counsel           Philip S. Barnett, Minority Chief 
David A. Kass, Deputy Counsel and       Counsel
    Parliamentarian                 Courtney A. Cook, Minority Staff 
Michael Bopp, Senior Investigative      Assistant
    Counsel                         Sarah Despres, Minority Counsel
J. Timothy Griffin, Senior          Jonathan M. Frenkel, Minority 
    Investigative Counsel               Counsel
Kristi L. Remington, Senior         Harold W. Gossett, Minority 
    Investigative Counsel               Professional Staff Member
Elliot S. Berke, Investigative      Christopher P. Lu, Minority 
    Counsel                             Counsel
Robert J. Dold, Investigative       Michael J. Raphael, Minority 
    Counsel                             Counsel
Jason Hopfer, Investigative Counsel Ellen P. Rayner, Minority Chief 
John Irving, Investigative Counsel      Clerk
Rae Oliver, Investigative Counsel   Jessica R. Robinson, Minority 
Jim Schumann, Investigative Counsel     Staff Assistant
Michelle E. White, Investigative    David Sadkin, Minority Counsel
    Counsel                         Philip M. Schiliro, Minority Staff 
Dudley Hodgson, Chief Investigator      Director
Milt Copulos, Investigator          Andrew H. Su, Minority Research 
Kevin Davis, Investigator               Assistant
G. Andrew Macklin, Investigator     Amy R. Wendt, Minority Staff 
John T. Mastranadi, Investigator        Assistant
Matt Tallmer, Investigator          Barbara A. Wentworth, Minority 
Thomas P. Bossert, Assistant to         Research Assistant
    Chief Counsel                   Michael T. Yang, Minority Counsel
Jason Foster, Assistant Systems     Michael J. Yeager, Minority 
    Administrator                       Counsel
Laurel Grover, Staff Assistant      
Kenneth Feng, GAO Detailee          
Roger Stoltz, GAO Detailee          
Richard D. Bennett, Special Counsel 
    to the Committee 


                         LETTER OF TRANSMITTAL

                              ----------

                                  House of Representatives,
                                  Washington, DC, November 5, 1998.
Hon. Newt Gingrich,
Speaker of the House of Representatives,
Washington, DC.
    Dear Mr. Speaker: By direction of the Committee on 
Government Reform and Oversight, I submit herewith the 
committee's sixth report to the 105th Congress.
                                                Dan Burton,
                                                          Chairman.


                            C O N T E N T S

                              ----------                              
                                                                   Page
Preface..........................................................     1
Chapter I: Introduction..........................................     5
Chapter II: Unprecedented Obstacles to the Committee's 
  Investigation..................................................    47
Chapter III: The Democrats' Failure to Return Illegal Campaign 
  Contributions..................................................   149
Chapter IV: Unprecedented Infusion of Foreign Money Into the 
  American Political System......................................  1185
    Part A: The Riady Family and John Huang: Access and Influence 
      with the Clinton White House...............................  1185
    Part B: Yah Lin ``Charlie'' Trie and His Relationship with 
      the Clinton Administration.................................  1347
    Part C: Johnny Chung: His Unusual Access to the White House 
      and His Political Donations................................  1671
    Part D: The Sioeng Family's Contributions and Foreign Ties...  2131
Chapter V: The Failure of Government Agencies to Vigorously 
  Pursue Campaign Violations.....................................  2933
    Part A: Jorge Castro's Illegal Campaign Contributions, and 
      Why They Were Never Prosecuted.............................  2933
    Part B: FEC Enforcement Practices and the Case Against 
      Foreign National Thomas Kramer: Did Prominent DNC 
      Fundraisers Receive Special Treatment?.....................  2983
Chapter VI: The Hudson Casino Rejection..........................  3111
Chapter VII: Procedural Background of the Campaign Finance 
  Investigation..................................................  3863

                                 VIEWS

Additional views of Hon. Dan Burton..............................  3881
Additional views of Hon. Pete Sessions...........................  3920
Minority views of Hon. Henry A. Waxman, Hon. Tom Lantos, Hon. 
  Robert E. Wise, Jr., Hon. Major R. Owens, Hon. Edolphus Towns, 
  Hon. Paul E. Kanjorski, Hon. Gary A. Condit, Hon. Bernard 
  Sanders, Hon. Carolyn B. Maloney, Hon. Eleanor Holmes Norton, 
  Hon. Chaka Fattah, Hon. Elijah E. Cummings, Hon. Dennis J. 
  Kucinich, Hon. Rod R. Blagojevich, Hon. Danny K. Davis, Hon. 
  Thomas H. Allen, and Hon. Harold E. Ford, Jr...................  3923
Additional views of Hon. Thomas M. Barrett.......................  4878



                                                 Union Calendar No. 471
105th Congress                                            Rept. 105-829
                        HOUSE OF REPRESENTATIVES

 2d Session                                                 Vol. 1 of 4
_______________________________________________________________________


   INVESTIGATION OF POLITICAL FUNDRAISING IMPROPRIETIES AND POSSIBLE 
                           VIOLATIONS OF LAW

                                _______
                                

November 5, 1998.--Committed to the Committee of the Whole House on the 
              State of the Union and ordered to be printed

_______________________________________________________________________


  Mr. Burton, from the Committee on Government Reform and Oversight, 
                        submitted the following

                              SIXTH REPORT

                             together with

                     ADDITIONAL AND MINORITY VIEWS

    On October 8, 1998, the Committee on Government Reform and 
Oversight approved and adopted a report entitled, 
``Investigation of Political Fundraising Improprieties and 
Possible Violations of Law.'' The chairman was directed to 
transmit a copy to the Speaker of the House.

                                PREFACE

  Interim Report of the Committee on Government Reform and Oversight 
           Campaign Finance Investigation and Related Matters

    In the closing months of the 1996 campaign, a multitude of 
campaign finance violations involving foreign money being 
funneled into the political system came to light. In the 
opening days of the 105th Congress, the House Committee on 
Government Reform and Oversight as well as the Senate 
Governmental Affairs Committee were tasked with investigating 
potential campaign law violations.
    By early 1997, the Democratic National Committee (``DNC'') 
had returned close to $3 million in illegal contributions, much 
of the funds facilitated by individuals with extensive ties to 
the People's Republic of China (``PRC'')--namely, John Huang, 
Charlie Trie, and Johnny Chung. In February 1997, the 
Washington Post first reported a link between foreign campaign 
contributions and the People's Republic of China:

        A Justice Department investigation into improper 
        political fundraising activities has uncovered evidence 
        that representatives of the People's Republic of China 
        sought to direct contributions from foreign sources to 
        the Democratic National Committee before the 1996 
        presidential campaign.\1\
---------------------------------------------------------------------------
    \1\ Bob Woodward and Brian Duffy, ``Chinese Embassy Role in 
Contributions Probed,'' the Washington Post, Feb. 13, 1997, p. A1.

Again in April 1997, the Washington Post reported that ``top'' 
Chinese officials approved plans ``to attempt to buy influence 
with American politicians'' and the plans continued through 
1996 to the present.
    Unlike the Senate investigation, the House investigation 
scope was not limited to the 1996 campaign.\2\ The Committee 
was able to examine a pattern of conduct which began in the 
1992 campaign cycle with such key figures as DNC Finance Vice-
Chairman John Huang as well as the Indonesian millionaire James 
Riady. Both were long time friends of President Clinton.
---------------------------------------------------------------------------
    \2\ The House Committee's scope included investigating ``political 
fund-raising improprieties and possible violations of law'' going back 
to the 1992 election cycle.
---------------------------------------------------------------------------
    Because of the unprecedented lack of cooperation of 
witnesses, including 120 relevant individuals who either 
asserted Fifth Amendment privileges or fled the country, both 
the House and Senate investigations were severely hampered. In 
addition, the stalling tactics of the White House and the DNC, 
as well as the total lack of cooperation from foreign 
governments in obtaining bank records and relevant witnesses, 
limited the information available to the Committee. 
Nevertheless, both the House and Senate ``followed the money'' 
and uncovered extensive evidence of foreign money being 
funneled into campaigns and learned more about key individuals 
such as James Riady, John Huang, Charlie Trie, Antonio Pan, 
Johnny Chung, and Ted Sioeng. These individuals all had high 
level access to the Administration, including the President. 
They also had established ties to the PRC. Due to the lack of 
cooperation, many questions remain about their conduct and 
contacts with senior White House and DNC officials.
    Throughout 1997, the House worked with the Senate 
investigation to the greatest extent possible. The House 
investigation further developed information relating to the 
political and business contacts, as well as the source of the 
funds both here and abroad, of the above named individuals. In 
addition, the Committee is investigating foreign money from 
other fronts, including South America and funds from a German 
national. The Committee identified illegal funds contributed to 
the Clinton/Gore '96 campaign, as well as the DNC, undermining 
the President's November 1996 contention that it was the 
``other campaign'' (the DNC), not his, which had problems with 
illegal money.
    These investigations are still ongoing as the Committee 
continues to pursue witnesses and follow the money trail. This 
interim report reflects a work in progress, and numerous areas 
of the Committee's investigation are not yet included because 
of the ongoing nature of the investigation. The House 
investigation has continued to review the contributions 
solicited by John Huang and Charlie Trie and has discovered 
still hundreds of thousands of dollars in illegal and suspect 
funds in Democratic coffers that have not been returned. 
Hundreds of thousands of dollars more in contributions from the 
family of Ted Sioeng still haven't been returned by the DNC. In 
investigating the background of the individuals involved with 
these illegal contributions, the House Committee identified 
additional, extensive ties that the key fundraisers had with 
Asian sources and businesses.
    In May 1998, the New York Times reported that Johnny Chung 
told Federal investigators that he funneled tens of thousands 
of dollars from a Chinese military officer, Liu Chao-ying, to 
the Democrats during the 1996 campaign. Chung said the money 
came from the People's Liberation Army through Liu Chao-ying, a 
Chinese aerospace executive whose father was a senior Chinese 
military officer.\3\ The Committee developed extensive 
information regarding Chung's Chinese business contacts and 
activities.
---------------------------------------------------------------------------
    \3\ Roberto Suro, ``Chung Alleges DNC Sought Illegal Funds, Justice 
Dept. Probe Enters New Phase,'' the Washington Post, June 20, 1998; 
Jeff Gerth, David Johnston and Don Van Natta, ``Democrat Fund-Raiser 
Said to Detail China Tie,'' the Washington Post, May 15, 1998, A1.
---------------------------------------------------------------------------
    The Committee continues to be hampered by the refusal of 
the Justice Department to provide immunity for low-level 
witnesses with relevant information which would allow the 
investigation to move forward or to aggressively push foreign 
governments to turn over information on bank records the 
Committee has traced to foreign sources. In a number of 
instances the Committee has identified witnesses previously 
unknown to the Justice Department.
    Finally, the failure of the Attorney General to follow the 
law and appoint an independent counsel for the entire campaign 
finance investigation has been the subject of two sets of 
Committee hearings. FBI Director Louis Freeh and the Attorney 
General's hand-picked Chief Prosecutor, Charles La Bella, wrote 
lengthy memos to the Attorney General advising her that she 
must appoint an Independent Counsel under the mandatory section 
of the Independent Counsel Statute. As part of the Committee's 
oversight of the Justice Department, the Committee subpoenaed 
these memos, and held the Attorney General in contempt for not 
producing them or providing any legal basis for this refusal. 
Until an independent counsel is appointed in this matter, the 
American people cannot be assured that the same standards of 
justice will be applied to the President and Vice-President as 
apply to every other citizen. Nevertheless, the Committee 
continues to investigate and review the numerous outstanding 
matters that remain in carrying out its mandate.
      

=======================================================================


                               CHAPTER I

                              INTRODUCTION

=======================================================================

      
                              INTRODUCTION

   INTERIM REPORT OF THE COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT

               BACKGROUND ON THE CAMPAIGN FINANCE SCANDAL

                            I. Introduction

    Two years ago, the American people were confronted with 
serious questions involving the basic integrity of our 
democratic electoral process. In the closing months of the 1996 
campaign, there were daily revelations about foreign money 
coming into the U.S. political system.
    John Huang, a former Lippo Group executive, a longtime 
friend of the President and a Presidential appointee at the 
Commerce Department, was placed at the Democratic National 
Committee (``DNC'') in 1995 to raise money with the full 
knowledge, encouragement and blessing of the President and his 
senior aides. Huang was at the center of the growing scandal. 
His ties with the Riadys' Lippo Group, and the President's 
longtime friendship with both Huang and the Riadys were the 
subject of many unanswered questions during the closing weeks 
of the 1996 campaign. In October 1996, it also came to light 
that the Riadys provided a $100,000 ``consulting'' fee to 
Presidential friend and former Associate Attorney General 
Webster Hubbell in 1994. At the time, Hubbell was under 
investigation in the Whitewater matter.\1\ Charlie Trie and Ted 
Sioeng, two other sources of illegal foreign campaign 
contributions, also had ties with Huang. Johnny Chung, another 
source of illegal DNC contributions, interacted with Huang and 
Trie as well as senior White House officials.
---------------------------------------------------------------------------
    \1\ Susan Schmidt, ``Hubbell Got $700,000 for Little or No Work, 
House Probe Shows,'' Washington Post, Apr. 24, 1998 p. A6.
---------------------------------------------------------------------------
    The issues regarding John Huang, Charlie Trie, the Riadys 
and other possible sources of foreign money are of great 
concern. It is important for the American public to understand 
who is financing elections and what interests they might have. 
These were precisely the type of concerns which were raised in 
the closing days of the 1996 election. Yet, at the time the Los 
Angeles Times observed that `` . . . Clinton and his aides 
admitted almost nothing [about the campaign finance problems] 
until his re-election was signed, sealed and delivered. . . . 
We were clearly trying to push this onto the DNC to respond and 
keep it away from the president and the campaign trail,'' Mike 
McCurry candidly admitted in late 1996.\2\
---------------------------------------------------------------------------
    \2\ Glenn F. Bunting and Alan C. Miller, ``Money saga points to 
deception; Clinton, Democrats withheld information on foreign campaign 
gifts,'' Los Angeles Times, Dec. 30, 1996.
---------------------------------------------------------------------------
    Federal election laws are designed so that those who are 
involved in the process of funding our election system are 
citizens or residents with a stake in the United States' system 
of democratic government. Federal laws are also designed to 
provide full disclosure to the American people about who is 
funding candidates for public office. U.S. election laws do not 
allow for contributions from foreign sources.\3\ When the laws 
governing our elections are broken, the very system designed to 
govern our free elections is threatened. If money is given 
illegally, that can, in and of itself, change the outcome in 
any given election. That is why tracking the huge infusion of 
foreign money from, among other sources, those with communist 
Chinese government ties, and determining how and why this was 
done, is so important.
---------------------------------------------------------------------------
    \3\ See 2 U.S.C. 441e(a).
---------------------------------------------------------------------------
    Masking donations through conduit donors is one way in 
which the true source of funds can be hidden, thereby 
increasing the influence of either a foreign or illegal source 
of money. Using conduit contributions also allows a single 
individual to make more hard dollar contributions than they 
would otherwise be allowed to make. An individual can give up 
to $20,000 in ``hard money'' to a party committee. When an 
individual provides conduit funds to a new individual who has 
not previously donated, that first $20,000 contributed by that 
conduit donor will also be counted as ``hard money'' donations. 
It should be noted that throughout the 1996 campaign, there was 
a big push to obtain more hard money. Memos authored by White 
House Deputy Chief of Staff Harold Ickes, who coordinated the 
campaign, raised the issue of a shortage of ``hard money'' 
throughout the 1996 campaign season.\4\
---------------------------------------------------------------------------
    \4\ Harold Ickes Documents, DNC 3109247-49; EOP 035856-59; EOP 
037358-362 (Exhibit 1).
---------------------------------------------------------------------------
    The Committee has tracked hundreds of thousands of dollars 
in conduit contributions and learned that many illegal conduit 
funds have yet to be returned by the DNC and other Democratic 
entities. Now that it has been clearly established that much of 
the millions of dollars in illegal contributions came from 
foreign bank accounts and/or conduits, the troubling question 
persists: Were foreign sources of any kind buying access to the 
White House and trying to influence the 1996 elections?
    To date, the President, White House officials and DNC 
officials, all claim no prior knowledge of the massive amount 
of illegal foreign money raised by John Huang, Charlie Trie, 
Johnny Chung, their associates and others. However, senior 
White House and DNC officials were all part of a reckless 
fundraising scheme which involved providing extensive 
opportunities for large DNC donors to gain access to the 
President and senior Administration officials. White House 
perks such as Lincoln Bedroom overnights, White House coffees, 
Air Force One trips and Kennedy Center tickets, also were 
provided to donors and their friends.\5\ A number of the 
individuals who received the ``perks'' and White House VIP 
treatment, were later deemed inappropriate. These included 
individuals such as a drug dealer, an arms merchant and many 
foreign nationals with unknown agendas.
---------------------------------------------------------------------------
    \5\ White House Documents, EOP 036287-88 (Exhibit 2).
---------------------------------------------------------------------------
    While the Committee at this time is not prepared to make 
any final conclusions about the precise role or actions of 
senior White House and DNC officials, including the President 
and Vice-President, in the campaign finance scandal, the 
Committee will continue to explore their actions. FBI Director 
Louis Freeh and the Task Force Chief Prosecutor Charles La 
Bella already have told the Attorney General that the actions 
of those at the highest levels of the White House and DNC 
necessitate the appointment of an independent counsel. Some 
have suggested that there might be a larger conspiracy to 
violate election laws which necessitates an independent 
counsel. Nevertheless, the Attorney General has declined to 
appoint an Independent Counsel for campaign finance, failing to 
follow the law in this matter. It should be noted that it is 
the common understanding of the recommendations of both Mr. 
Freeh and Mr. LaBella that any Independent Counsel appointed to 
investigate campaign finance matters would investigate any 
conduct relating to Republicans as well as Democrats.
    Finally, in ``following the money,'' the Committee 
ultimately focused more on Democratic fundraising for one 
simple reason--that is where the foreign money was directed 
over the past several election cycles. However, this Committee 
and the Senate Governmental Affairs Committee did not neglect 
the instances where foreign money was found in Republican 
coffers and examined both the matters involving Ambrous Young 
\6\ and Ted Sioeng \7\ as they related to Republicans.
---------------------------------------------------------------------------
    \6\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 4, 
4657 (1998).
    \7\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 4, 
5573 (1998).
---------------------------------------------------------------------------

II. The Foreign Fund-Raising Story Breaks in Fall 1996: Keeping a Lid 
                    on the Story Past the Election

                   A. The Initial Fundraising Stories

    The foreign fundraising scandal first came to light in 
September 1996 with press reports of an illegal $250,000 
donation from Cheong Am America, a start-up California company, 
which had no U.S. generated income at the time of the 
donation.\8\ John Huang had promised the head of the company, 
John H.K. Lee, that he would have the opportunity to meet with 
the President after making his April 8, 1996 contribution to 
the DNC.\9\ In exchange for Lee's contribution, Huang arranged 
a quick photo op in a California Hotel where Mr. Lee met and 
posed for pictures with the President.\10\
---------------------------------------------------------------------------
    \8\ Alan C. Miller, ``Democrats Return Illegal Contribution: South 
Korean Subsidiary's $250,000 Donation Violated Ban on Money from 
Foreign Nationals,'' Los Angeles Times, September 21, 1996 at A16.
    \9\ David Willman, Alan C. Miller and Glenn F. Bunting, ``What 
Clinton Knew: How a Push for New Fund-Raising Led to Foreign Access, 
Bad Money and Questionable Ties,'' Los Angeles Times, Dec. 21, 1997 at 
A1.
    \10\ Id.
---------------------------------------------------------------------------
    Following the Cheong Am disclosure by the Los Angeles Times 
in September 1996,\11\ and the many unanswered questions raised 
about John Huang's fundraising, the press aggressively began 
reporting about large, potentially illegal donations to the 
Democratic National Committee. Donations focused on by the 
press included the Cheong Am $250,000 donation;\12\ $450,000 in 
donations from the Wiriadinatas, an Indonesian couple linked to 
the Riadys;\13\ $140,000 from monks and nuns who attended a 
fundraiser in April 1996 at a Buddhist temple in 
California;\14\ and, a $325,000 donation from Yogesh 
Gandhi.\15\ John Huang was the DNC contact for most of these 
illegal contributions.
---------------------------------------------------------------------------
    \11\ Alan C. Miller, ``Democrats Return Illegal Contribution,'' Los 
Angeles Times, Sept. 21, 1996.
    \12\ Id.
    \13\ Los Angeles Times, Dec. 21, 1997.
    \14\ Ruth Marcus and Ira Chinoy, ``A Fund-Raising `Mistake'; DNC 
Held Event in Buddhist Temple,'' the Washington Post, Oct. 17, 1996 p. 
A1.
    \15\ Los Angeles Times, Dec. 21, 1997.
---------------------------------------------------------------------------
    In the weeks before the 1996 Presidential election, top 
White House, DNC and Commerce Department officials refused to 
release much of the relevant information regarding John Huang, 
the Riadys, Charlie Trie and other fundraisers and suspicious 
characters connected with questionable DNC campaign donations. 
As Brookings Institution scholar Stephen Hess observed:

        I've been around this town for 30 years and I've never 
        seen a group raise stonewalling to such an art form. . 
        . . This is nothing new for the Clintons . . . but they 
        may ultimately pay a very heavy price for it.\16\
---------------------------------------------------------------------------
    \16\ Los Angeles Times, Dec. 30, 1996.
---------------------------------------------------------------------------

      B. White House and DNC Dodge Questions and Go On the Attack

    The President was clearly among those avoiding answering 
questions about these matters in October 1996. On October 15, 
1996, when asked about criticism of various DNC contributions, 
the President would only say: ``It's election time,'' before he 
ducked into his hotel.\17\ The following Washington Post story 
on October 22, 1996 was typical of the White House response:
---------------------------------------------------------------------------
    \17\ Edward Walsh, ``Dole Aide Suggests `Potentially Criminal 
Actions' in DNC Gift'' the Washington Post, Oct. 15, 1996 at A10.

        Clinton has not provided any substantive answers, 
        dismissing the matter by saying that his campaign has 
        asked the Federal Election Commission to examine 
---------------------------------------------------------------------------
        Huang's fundraising activities. . . .

        White House press secretary Michael McCurry said today 
        that this [Huang's not being available for questions] 
        is because Huang is too busy preparing for the FEC 
        inquiry to meet with the news media. And he said the 
        White House hopes that the FEC will reach its 
        conclusions and make a report before the presidential 
        election. But McCurry was smiling when he said it, 
        knowing that the FEC routinely takes months or years--
        not weeks--to reach its conclusions on such matters.

        ``Extremely cynical performance, Mr. McCurry,'' one 
        reporter bellowed. ``I don't know about that,'' McCurry 
        chortled. ``I've seen worse. I've done worse.'' \18\
---------------------------------------------------------------------------
    \18\ John Harris, ``President Sidesteps Funds Flap,'' the 
Washington Post, Oct. 22, 1996 at A1.

    Senator Christopher Dodd, the Co-Chairman of the DNC, 
denied that John Huang had ``done anything wrong here'' during 
an appearance on Face the Nation on October 20, 1996, and said 
the DNC would make Huang available for questioning.\19\ At the 
time of Dodd's statement, the DNC had decided to relieve Mr. 
Huang of his fundraising duties and ask the FEC to investigate 
the donations Huang solicited.\20\
---------------------------------------------------------------------------
    \19\ Jill Abramson and Glenn R. Simpson, ``Lippo Issue Remains at 
Center of Presidential Race,'' Wall Street Journal, Oct. 21, 1996 at 
A24 (quoting Face the Nation (CBS television broadcast, Oct. 20, 
1996)).
    \20\ Id.
---------------------------------------------------------------------------

                        C. John Huang in Hiding

    During this pre-election time John Huang was in hiding, but 
in contact with DNC officials. The DNC then reported back to 
the White House of growing concerns about Huang's fundraising. 
However, it was only when Huang was facing a nationwide manhunt 
by U.S. Marshals that his attorney, John Keeney, assured U.S. 
District Judge Royce Lamberth that Huang would attend a civil 
deposition relating to his Commerce Department activities.\21\ 
Exasperated with Huang's avoidance of a subpoena, the judge 
indicated that the marshals had been attempting to locate 
Huang. In a particularly testy courtroom exchange, Judge 
Lamberth asked:
---------------------------------------------------------------------------
    \21\ Andy Thibault, ``Huang's lawyer says he'll return,'' the 
Washington Times, Oct. 26, 1996 at A1.

          Judge Lamberth. Is he [Huang] within 100 miles?
          Mr. Keeney. I don't have an atlas.
          Judge Lamberth. You don't need an atlas . . . You 
        know exactly where he is. If he wants to flee from 
        service, I'm going to find out where he is.\22\
---------------------------------------------------------------------------
    \22\ Id.

    Mr. Keeney had claimed Huang would not be available until 
after the Presidential election.\23\ At that point, Judge 
Lamberth ordered the DNC to require that Huang report to work 
on the following Monday. Upon receiving the order, DNC Chairman 
Don Fowler complied.\24\ To forestall any delaying tactics, 
Judge Lamberth indicated that he was prepared to hold a hearing 
on whether Huang's lawyer could legally refuse to disclose his 
client's location. Keeney sent the DNC a letter saying Huang 
would be available for the deposition.\25\
---------------------------------------------------------------------------
    \23\ Id.
    \24\ Id.
    \25\ Toni Locy and Serge Kovaleski, ``Huang to Return Monday to 
Accept Civil Subpoena,'' the Washington Post, Oct. 26, 1996 at A13.
---------------------------------------------------------------------------
    Documents turned over to the Committee from the DNC show 
that Huang submitted a ``DNC Expense Report'' for part of his 
time in hiding in October 1996.\26\ In a submission he made in 
the fall of 1996 under ``purpose of travel'' Huang wrote: 
``Stayed away from D.C.; Return home for materials.'' The 
timeframe was October 11-15, 1996.\27\
---------------------------------------------------------------------------
    \26\ DNC Document D0000053 (Exhibit 3).
    \27\ Id.
---------------------------------------------------------------------------

          D. The DNC Stalls Past the Election on FEC Reporting

    With all of the troubling information about possibly 
illegal contributions surfacing in the closing days of the 1996 
election, the DNC made the extraordinary decision not to submit 
its financial report to the Federal Election Commission on 
time, as required by law.\28\ This was the first time since the 
Federal election law was enacted that a party had purposefully 
decided not to file a pre-election campaign finance report. 
This produced an outcry even from party loyalists such as 
former Judiciary Committee Chairman and Democrat Representative 
Don Edwards, who noted the report should have been filed by the 
DNC: ``They've had people out of control over there who went 
overboard [on fund-raising].'' \29\
---------------------------------------------------------------------------
    \28\ Donald Lambro, ``After election comes the deluge? Democrats 
fear funds flap fallout,'' the Washington Times, Oct. 31, 1996 at A1.
    \29\ Id.
---------------------------------------------------------------------------
    Following a public uproar, the DNC reversed itself and 
released ``raw data'' of the campaign finance report.\30\ 
Charles Lewis, Executive Director of the Center for Public 
Integrity observed at the time:
---------------------------------------------------------------------------
    \30\ The Washington Times, Oct. 30, 1996 at A13.

        If Bill Clinton is re-elected, it could well become the 
        second term from Hell. . . . We're seeing something we 
        have not seen since Watergate, in terms of the contempt 
        for the American people about the amount of campaign 
        money being raised from dubious sources and of 
        questionable legality.\31\
---------------------------------------------------------------------------
    \31\ The Washington Times, Oct. 31, 1996 at A1.
---------------------------------------------------------------------------

    III. The Post-Election Response to the Campaign Finance Scandal

                 A. Problems Identified with John Huang

    From the very beginning, John Huang's fundraisers included 
an unusually high number of foreign nationals. This did not go 
unnoticed by DNC officials in 1996. DNC Chairman Don Fowler and 
DNC Finance Chairman Marvin Rosen attended the events 
orchestrated by Huang and at the time of Huang's first 
fundraiser in February 1996, noted that a number of foreign 
nationals were at the event. By the time of a July 30, 1996, 
small Presidential fundraising dinner where few of the 
attendees were eligible to contribute, Marvin Rosen put out the 
word that Huang could not do anymore events with the 
President.\32\ However, Huang's fundraising was allowed to 
continue behind the scenes.
---------------------------------------------------------------------------
    \32\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 1, 
1703 (1998) (``Senate Report'').
---------------------------------------------------------------------------
    As became evident shortly after the 1996 election, there 
were serious problems with John Huang's fundraising practices, 
as well as the DNC vetting practices--or rather, the lack 
thereof. There were hundreds of thousands of dollars in illegal 
foreign contributions connected with Huang. In fact, problems 
with John Huang's fundraising practices were first brought to 
the attention of the DNC after his first fundraising event in 
Washington, DC, on February 19, 1996.
    Shortly after Huang's first fundraising event, a February 
19, 1996 Asian-American event which Huang claimed to have 
raised $1 million for the party, the DNC learned that at least 
two of the contributions were clearly illegal.\33\ Two $12,500 
checks solicited by Huang from a couple who run an 
international trading group based in China were returned in 
March 1996.\34\ DNC General Counsel Joseph Sandler claims to 
have no recollection of these checks being returned by the DNC 
in March 1996, even though he has testified that he extensively 
reviewed John Huang's contributions from the February 19, 1996 
event.\35\ It was not until July 1997 when the information 
about these two returned checks was first turned over to 
Congress. For almost a year, the DNC left the impression that 
the first notice that they had of any problems with John Huang 
was the $250,000 Cheong Am donation identified as illegal in 
mid-September 1996. That impression was deliberately 
misleading.
---------------------------------------------------------------------------
    \33\ Senate Report, vol. 1, at 1694-1698.
    \34\ Id.
    \35\ Deposition of Joseph Sandler, by the Senate Committee on 
Governmental Affairs, May 30, 1997, at 102-103.
---------------------------------------------------------------------------
    These early warning signs about John Huang's solicitation 
of illegal foreign money were clearly ignored by the DNC. 
However, both DNC Finance Director Richard Sullivan and DNC 
Finance Chairman Marvin Rosen claimed to have had sufficient 
concerns about Huang to recommend special training by DNC 
General Counsel Joseph Sandler. Sandler has denied ever being 
requested to conduct such training or in fact engaging in such 
training for Huang.\36\
---------------------------------------------------------------------------
    \36\ Senate Report, vol. 1, at 1692-1694.
---------------------------------------------------------------------------
    Perhaps most disturbing about all matters related to John 
Huang is the fact that Attorney General Janet Reno's task force 
appears to be making little if any progress in making a case 
against John Huang.\37\ As is evidenced in the Committee's 
report, there is ample reason to believe he is every bit as 
involved in illegal campaign contributions as the lower level 
individuals who have been indicted by the Justice Department's 
Campaign Finance Task Force to date.
---------------------------------------------------------------------------
    \37\ See Letter from Chairman Burton to Attorney General Janet Reno 
of Oct. 2, 1998. (Exhibit 4).
---------------------------------------------------------------------------

           B. Problems identified with the DNC vetting system

    By mid-October 1996, DNC officials had not only realized 
they had serious problems with their compliance procedures, 
according to DNC General Counsel Joseph Sandler, they had begun 
a process to change the vetting system.\38\ It is clear from 
Sandler's testimony that a public acknowledgment of serious 
shortcomings in the DNC finance system was deliberately delayed 
past election day.\39\
---------------------------------------------------------------------------
    \38\ Deposition of Joseph Sandler, Senate Committee on Governmental 
Affairs, May 15, 1997 at 21 (hereinafter ``Sandler Senate 
Deposition'').
    \39\ Id. at 22-30.
---------------------------------------------------------------------------
    Although DNC Chairman Don Fowler refused to make any public 
statements before the election, he came forward on November 13, 
1996, to acknowledge that there were ``serious'' flaws in the 
party's process for reviewing contributions and donors. Fowler 
claimed he had instituted new safeguards.\40\
---------------------------------------------------------------------------
    \40\ Ruth Marcus, ``DNC Official Concedes `Mistakes of Process'; 
National Chairman Makes First Statements on Donor Controversy,'' the 
Washington Post, Nov. 13, 1996 at A4.
---------------------------------------------------------------------------
    Yet, even after the election, the DNC hid the true nature 
of the problem. For example, the day after the election, the 
DNC returned a $325,000 check to Yogesh Gandhi. However, the 
DNC had arranged to return the contribution before the 
election, in late October 1996.\41\ In a similar incident, at 
the November 13, 1996 press conference, DNC Chairman Fowler 
insisted that the $450,000 from the Indonesian couple, the 
Wiriadinatas, had been ``thoroughly reviewed'' and was 
legal.\42\ Yet only 10 days later, after intense public 
scrutiny, the DNC announced that it was returning this $450,000 
in donations from the Wiriadinatas because they had failed to 
file U.S. income tax returns for 1995 and they had moved back 
to Indonesia--information which was known to the DNC by mid-
October.\43\ This pattern of delaying the return of illegal or 
inappropriate contributions continues today.
---------------------------------------------------------------------------
    \41\ Sandler Senate Deposition, May 15, 1997 at 114-116.
    \42\ The Washington Post, Nov. 13, 1996 at A4.
    \43\ Alan C. Miller, ``Democrats Give Back more disputed money,'' 
the Los Angeles Times, Nov. 23, 1996 at A1.
---------------------------------------------------------------------------
    By November 1996, the Justice Department had set up its 
task force to investigate the campaign fundraising matter, 
which in turn prompted the DNC to hire outside auditors, 
lawyers and investigators to further examine the questionable 
contributions. In February 1997, the DNC identified $1,492,051 
in contributions to be returned, yet officials at the DNC 
continued to deny any prior knowledge of this extensive pattern 
of illegal contributions generated by John Huang, Charlie Trie, 
Johnny Chung and others.

        C. Problems Identified with Charlie Trie's Contributions

    Problems related to DNC fundraiser, Presidential appointee, 
and long-time Clinton friend, Charlie Trie, also came to public 
light in the fall of 1996. Charlie Trie worked closely with 
John Huang in fundraising in the 1996 cycle. Notably, Harold 
Ickes flagged Charlie Trie as a potential problem in mid-
October 1996 when he spoke with DNC Executive Director B.J. 
Thornberry,\44\ but his fundraising problems largely escaped 
unnoticed until after the election. However, in an October 1996 
conversation with Ms. Thornberry, Ickes suggested that if she 
thought she had problems with Huang, ``you better look at 
Trie.'' \45\ Ickes' delay in calling attention to Trie is 
particularly problematic as Ickes was in charge of coordinating 
the campaign and fundraising for the DNC.
---------------------------------------------------------------------------
    \44\ Deposition of B.J. Thornberry, House Committee on Government 
Reform and Oversight, July 22, 1997 at 71.
    \45\ Id.
---------------------------------------------------------------------------
    Ickes had known of fundraising problems relating to Charlie 
Trie since early April 1996, when the Executive Director of the 
President's Legal Expense Trust, Michael Cardozo, informed Mr. 
Ickes and the First Lady, that Charlie Trie had provided over 
$380,000 in suspect contributions to the Presidential Legal 
Expense Trust.\46\ Mr. Cardozo informed Ickes and the First 
Lady that he was going to investigate the suspect contributions 
from Trie.\47\ Cardozo's testimony indicated that initially in 
the meeting, the First Lady appeared not to know Charlie 
Trie.\48\ Ickes also testified that he did not know who Trie 
was until Cardozo brought the situation to his attention.\49\ 
However, Trie, an Arkansas native, had been active in DNC 
fundraising circles since June 1994 when he contributed 
$100,000 to the DNC specifically dedicated to the First Lady's 
Health Care effort \50\ which was headed up by Harold Ickes at 
the White House.
---------------------------------------------------------------------------
    \46\ Deposition of Michael Cardozo, Senate Committee on 
Governmental Affairs, May 7, 1997 at 68.
    \47\ Id. at 71.
    \48\ Id.
    \49\ Deposition of Harold Ickes, Senate Committee on Governmental 
Affairs, June 26, 1997 at 160, 166.
    \50\ Memo to John O'Hanlon from David Mercer regarding VIP 
requests, June 18, 1994. F 0045848 (Exhibit 5).
---------------------------------------------------------------------------
    A document turned over from Ickes' files which features an 
exclusive group of large dollar donors features Charlie Trie 
along with notables such as Evelyn Lauder, Ely Callaway, and 
Marvin Davis, demonstrates that Ickes certainly could have 
known of Trie's role in fundraising.\51\ Despite warnings from 
Cardozo regarding Trie's fundraising, a Presidential 
appointment to the Commission on U.S.-Pacific Trade and 
Investment Policy went forward on April 17, 1996,\52\ with 
apparently no concern. The Committee has heard from a witness, 
an aide to Senator Bingaman, who told the committee that he 
protested repeatedly regarding Trie's placement on the 
Commission, only to be told by a White House official that Trie 
was a ``must appointment'' from high levels of the 
Administration.\53\ Many of those who served with Trie on the 
Commission found his qualifications and abilities severely 
lacking.
---------------------------------------------------------------------------
    \51\ Harold Ickes Documents CGRO 1623-24 (Exhibit 6).
    \52\ White House Documents EOP 030404-030406 (Exhibit 7).
    \53\ Staff Interview of Steve Clemons, Dec. 5, 1997.
---------------------------------------------------------------------------
    In a May 9, 1996 meeting at the White House, Michael 
Cardozo again met with top White House officials including 
Ickes and Bruce Lindsey and other White House Counsel, to 
inform them that he planned on returning the PLET contributions 
gathered by Trie, because it appeared they had been funneled 
through a Buddhist cult.\54\ At this May 9, 1996 meeting, Mr. 
Cardozo recalled that Bruce Lindsey mentioned something about 
Trie being a DNC fundraiser.\55\ Ickes does not recall any 
discussion that took place during the meeting.\56\
---------------------------------------------------------------------------
    \54\ Cardozo Senate Deposition, May 7, 1997 at 150-152.
    \55\ Id. at 175.
    \56\ Ickes Senate Deposition, June 26, 1997 at 179.
---------------------------------------------------------------------------
    Despite the knowledge of the First Lady and senior White 
House officials regarding Trie's suspect fundraising, just days 
later on May 13, 1996, the President, sitting at a table with 
two foreign nationals praised Charlie Trie:

        [S]oon it will be twenty years that I had my first meal 
        with Charlie Trie. Almost twenty years, huh? Twenty 
        years in just a few months. At the time, neither of us 
        could afford a ticket to this dinner, it's fair to 
        say.\57\
---------------------------------------------------------------------------
    \57\ White House Communications Agency videotape No. 6, May 13, 
1996.

At the time when the President made this statement reflecting 
upon Trie's apparent good fortune, his staff had already been 
informed of Trie's questionable fundraising practices for PLET. 
During this same month Charlie Trie borrowed $5,000 from former 
White House employee Mark Middleton \58\ and faced court 
charges for failing to pay his rent.\59\
---------------------------------------------------------------------------
    \58\ Deposition of Holli Weymouth, by the House Committee on 
Government Reform and Oversight, July 14, 1998 at 104.
    \59\ Complaint for possession of real estate, P704553 (Exhibit 8).
---------------------------------------------------------------------------
    In June 1996, all of Trie's gathered contributions were 
returned by PLET and the White House Counsel's office was again 
informed of this matter by Mr. Cardozo.\60\ Yet again on July 
22, 1996, and again on August 18, 1996, Charlie Trie was a key 
fundraiser for these Presidential events. In August 1996, when 
the Presidential Legal Expense Trust filed its quarterly 
report, it notably omitted all of the returned contributions 
provided by Trie.\61\ In August 1996, senior White House 
officials such as Harold Ickes, Bruce Lindsey, Maggie Williams 
and Cheryl Mills were informed of a letter received by a PLET 
donor connected with the funds Trie had forwarded which 
indicated that the funds were indeed gathered under highly 
questionable circumstances.\62\ Yet, it was not until December 
1996--after the election and after reporters keyed in on the 
fundraising role of Charlie Trie, that the White House 
acknowledged problems with Trie's PLET donations and Trie's DNC 
donations were publicly scrutinized.\63\ Even with knowledge of 
Trie's large and problematic donations, he continued to attend 
fundraisers and was invited to a December Christmas party at 
the White House for major DNC donors.\64\ At the Christmas 
party, according to Bruce Lindsey, Trie approached the 
President in the receiving line and apologized for any problems 
he caused the President and then left the White House.\65\ 
Shortly thereafter, when Trie's problems with the Trust Fund 
were made public, Trie left the country and remained in Asia 
throughout 1997.
---------------------------------------------------------------------------
    \60\ Cardozo Senate Deposition, May 7, 1997 at 201.
    \61\ Id. at 169.
    \62\ Id. at 223-224.
    \63\ Deposition of Michael Cardozo, by the Senate Committee on 
Governmental Affairs, May 8, 1997 at 10-11.
    \64\ Deposition of Bruce Lindsey, by the House Committee on 
Government Reform and Oversight, Apr. 29, 1998 at 20.
    \65\ Id.
---------------------------------------------------------------------------
    By February 1997, it was clear that Trie was connected with 
hundreds of thousands of dollars in illegal contributions. When 
the DNC completed its initial review of questionable 
contributions, it returned all of Trie's personal and corporate 
contributions. Nevertheless, many of his conduit political 
donations took months to trace. Even after both the Senate and 
House identified conduit funds provided by Charlie Trie, the 
DNC continued to retain the funds long after information about 
their illegal source was publicly identified.

                  D. The Specter of Foreign Influence

    Over the past 2 years, the millions of dollars in illegal 
foreign money that went to the DNC and other Democratic 
entities have been traced to a small number of key figures, 
namely John Huang, Charlie Trie, and Johnny Chung. These 
individuals were provided unique access to the White House and 
senior Administration officials. They also used their access to 
bring their foreign business associates to the White House and 
DNC functions. Even though many of their foreign associates 
were not eligible to contribute, foreign nationals such as 
Charlie Trie's business associate ``Mr. Wu'' did in fact funnel 
foreign money into the DNC. Trie brought ``Mr. Wu,'' who has 
been linked to local government officials in the People's 
Republic of China, to the White House on numerous occasions.
    Huang, Trie and Chung were provided with opportunities to 
bring their Chinese business associates to the White House 
while these same associates provided them with funds for 
illegal foreign contributions. As the Committee has continued 
its investigation, more information about these questionable 
business interests has come to light. Johnny Chung's confession 
that tens of thousands of dollars which he contributed were 
given to him from a Chinese government source was ultimately 
not surprising. Indeed, some at the DNC had suspected he was 
doing this.\66\
---------------------------------------------------------------------------
    \66\ Deposition of Richard Sullivan, by the House Committee on 
Government Reform and Oversight, Sept. 3, 1997 at 187.
---------------------------------------------------------------------------
    In March 1998, Chung pled guilty to illegally funneling 
$20,000 to Clinton/Gore '96.\67\ Chung also had contributed 
$366,000 to the DNC \68\ in the same period in which he visited 
the White House approximately 50 times,\69\ often with his 
Chinese business associates. According to news reports, Chung 
admitted that a large part of the nearly $100,000 he gave to 
Democrats in 1996, including $80,000 to the DNC, came from the 
Chinese People's Liberation Army through Chinese army 
Lieutenant Colonel and China Aerospace Corporation executive 
Liu Chao-ying.\70\ Chung, once labeled a ``hustler'' by a 
National Security Council aide,\71\ escorted Ms. Liu to a 
Presidential fundraiser in Los Angeles in 1996.\72\ A House 
Select Committee continues to investigate the intelligence and 
national security matters related to these issues, while this 
Committee continues to investigate the money trail and the 
business associations.
---------------------------------------------------------------------------
    \67\ Don Terry, ``Fund-Raiser Chung Pleads Guilty,'' the Washington 
Post, Mar. 17, 1998.
    \68\ FEC Internet records--tray.com/fecinfo/
    \69\ White House WAVE Records.
    \70\ Jeff Gerth, ``Democrat Fund-Raiser said to Detail China Tie,'' 
New York Times, May 15, 1998.
    \71\ E-mail from Robert Suettinger of the National Security Council 
describing Johnny Chung as a ``hustler'' EOP 005439.
    \72\ Chung guest list for Eli Broad fundraiser held on June 18, 
1996, JCH 15017 (Exhibit 9).
---------------------------------------------------------------------------
    The connections with foreign campaign money and foreign 
business associates also is apparent with Charlie Trie and his 
associate Antonio Pan; John Huang and the Riady family; Ted 
Sioeng and his foreign associates, as well as others. As the 
Committee continues to follow the money trail and push for 
foreign cooperation and an end to the stonewalling by dozens of 
key witnesses, it is very likely more foreign ties will be 
discovered. For example, the Committee has traced $200,000 in 
travelers checks back to Jakarta, Indonesia.\73\ These funds 
were used in part for conduit contributions to the DNC. To 
date, the committee and the Justice Department have been 
unsuccessful in obtaining the cooperation of the Indonesian 
government in turning over Indonesian bank records which would 
identify the source of these funds. However, it is the 
operative theory of both the Committee and the Justice 
Department that the source of these funds is very likely 
connected in some manner to the Riady family and/or Lippo 
Group.
---------------------------------------------------------------------------
    \73\ See generally, letter from Christopher M. Curran, Esq., 
Attorney for Bank Central Asia, to Committee Senior Investigative 
Counsel Tim Griffin, Esq., July 20, 1998.
---------------------------------------------------------------------------
    Finally, the Committee believes that the House's 
investigation continues to provide additional support to the 
issues as set out by the Senate Governmental Affairs majority 
report on ``The China Plan.'' \74\
---------------------------------------------------------------------------
    \74\ Senate Report, vol. 2, at 2499.
---------------------------------------------------------------------------

                               Conclusion

    The Committee's interim report outlines foreign money 
raised or contributed by John Huang, Charlie Trie, Johnny 
Chung, and others connected with these individuals such as Ted 
Sioeng and the dozens of conduits connected with them. What is 
clear is that high level officials from the White House, the 
Administration and the DNC made themselves available to these 
individuals despite warning signs that their fundraising 
practices were highly suspect. John Huang, and his patrons, the 
Riadys, are friends of President Clinton, as is Charlie Trie. 
They came to the fundraising table by virtue of their 
relationships with the President--not through any relationship 
with Don Fowler, Harold Ickes or other DNC or Administration 
officials.
    The illegal foreign money solicited by these individuals is 
doubly suspect because of their extensive ties to the People's 
Republic of China. The original--but as yet unidentified--
sources of these funds were traced to bank accounts in Hong 
Kong, Macau and Indonesia. As the Senate Governmental Affairs 
Committee Final Report on campaign finance noted, ``officials 
at the highest levels of the Chinese government approved of 
efforts to increase the PRC's involvement in the U.S. political 
process. There are indications that the plan or parts of the 
plan and possibly related PRC activities were implemented 
covertly in this country.'' \75\ Since the Senate issued its 
report in March 1998, the Committee has developed a more 
extensive record on the key fundraising figures and their 
foreign ties. Finally, in addition to the Asian sources of 
foreign money, the Committee has also identified South American 
foreign money that first came into the DNC coffers in 1992, as 
well as funds from a German national which were largely ignored 
by the FEC.
---------------------------------------------------------------------------
    \75\ Senate Report, vol. 2, at 2510.
---------------------------------------------------------------------------
    This is an interim report on the Committee's work in the 
campaign finance investigation. Due to the extensive 
stonewalling endured by the Committee and the lack of testimony 
from 120 relevant witnesses, many fundamental questions remain 
unanswered. What was the motivation behind the massive flow of 
foreign money into the U.S. political system? Where did the 
funds ultimately originate? Who were the foreign power brokers 
and what were they hoping to get in exchange for their money? 
Were any national security or policy matters compromised by 
these activities?
    Justice Department officials have indicated that cases such 
as these take years to get to the facts. The extensive 
financial transactions coupled with reluctant and non-available 
witnesses makes for a difficult trail to follow. Nevertheless, 
the Committee is determined to continue to get the facts to the 
American people.

              COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT              
               [Summary of Hearings by Witness and Topic]               
------------------------------------------------------------------------
           Date and Witness(es)                        Subject          
------------------------------------------------------------------------
October 8, 1997: (None), Member's           Campaign Finance            
 Statements.                                 Improperties and the       
                                             Possible Violation of Law. 
October 9, 1997: Manlin Foung, Joseph       Conduit Payments to the     
 Landon, David Wang.                         Democratic National        
                                             Committee.                 
November 6, 1997: Charles F.C. Ruff,        White House Compliance with 
 Cheryl D. Mills, Lanny Breuer, Dimitri      Committee Subpoenas.       
 Nionakis.                                                              
November 7, 1997: Charles F.C. Ruff,        White House Compliance with 
 Cheryl D. Mills, Lanny Breuer, Dimitri      Committee Subpoenas.       
 Nionakis.                                                              
November 13, 1997: Margaret Williams,       Johnny Chung: His Unusual   
 Nancy Hernreich, Kelly Crawford, Carol      Access to the White House, 
 Khare, Ceandra Scott.                       His Political Donations and
                                             Related Matters.           
November 14, 1997: Brooke Darby, Robert     Johnny Chung: His Unusual   
 Suettinger.                                 Access to the White House, 
                                             His Political Donations and
                                             Related Matters.           
December 9, 1997: Honorable Janet Reno,     Current Implementation of   
 Honorable Louis J. Freeh, Donald Smaltz.    the Independent Counsel    
                                             Act.                       
December 10, 1997: Honorable Louis J.       Current Implementation of   
 Freeh, Donald Smaltz.                       the Independent Counsel    
                                             Act.                       
January 21, 1998: Gaiashkibos, Arlyn        The Department of the       
 Ackley, Sr., George Newago, Fred Havenick.  Interior's Denial of the   
                                             Wisconsin Chippewa's Casino
                                             Applications.              
January 22, 1998: George Skibine, Michael   The Department of the       
 Anderson, Robin Jaeger, Denise Homer, Tom   Interior's Denial of the   
 Hartman.                                    Wisconsin Chippewa's Casino
                                             Applications.              
January 28, 1998: Patrick O'Connor, Scott   The Department of the       
 Dacey, Tom Collier, John Duffy.             Interior's Denial of the   
                                             Wisconsin Chippewa's Casino
                                             Applications.              
January 29, 1998: Honorable Bruce Babbit..  The Department of the       
                                             Interior's Denial of the   
                                             Wisconsin Chippewa's Casino
                                             Applications.              
March 31, 1998: Scott E. Thomas, Lawrence   FEC Enforcement Actions:    
 M. Noble, Lois Lerner, Jose Rodriguez.      Foreign Campaign           
                                             Contributions and other    
                                             FECA Violations.           
April 30, 1998: Jorge Castro Barredo,       Venezuelan Money and the    
 Richard T. Preiss, Joseph J. Dawson.        Presidential Election.     
August 4, 1998: Honorable Louis J. Freeh,   The Need for an Independent 
 Charles G. La Bella, James V. Desarno.      Counsel in the Campaign    
                                             Finance Investigation.     
August 6, 1998: (None), Member's            Whether to hold The Attorney
 Statements.                                 General in Contempt Of     
                                             Congress.                  
------------------------------------------------------------------------

    [Supporting documentation follows:]





=======================================================================


                               CHAPTER II

        UNPRECEDENTED OBSTACLES TO THE COMMITTEE'S INVESTIGATION

=======================================================================

      
        UNPRECEDENTED OBSTACLES TO THE COMMITTEE'S INVESTIGATION

                              Introduction

    Since early 1997, when the Committee first began conducting 
its campaign finance investigation, the Committee encountered 
unprecedented obstacles, never before faced by a congressional 
investigation. These obstacles resulted in limited or no access 
to the most relevant witnesses and caused the Committee to have 
to subpoena far more materials than it might otherwise have 
done if faced with cooperating witnesses and cooperating 
entities.
    These obstacles include the following:
          I. To date, 120 witnesses connected with the campaign 
        finance investigation have either fled the country or 
        asserted Fifth Amendment privileges. Many of these 
        witnesses were associates of the central campaign 
        fundraising figures, all of whom refused to cooperate 
        with the Committee. Included are: John Huang, Charlie 
        Trie, Johnny Chung, James Riady, Webster Hubbell, Mark 
        Middleton and Melinda Yee. Huang, Trie, Hubbell, 
        Middleton and Yee were all political appointees of 
        President Clinton.
          II. The Committee has been faced with the White 
        House's consistent, 6 year pattern of dragging out 
        investigations by refusing to turn over relevant 
        documents until threatened with contempt. Furthermore, 
        the White House has on many occasions asserted 
        frivolous privileges which had already been struck down 
        in court. These actions were designed to delay and 
        minimize the effective dissemination of relevant 
        information.
          III. The Committee has been faced with the Democratic 
        National Committee's (``DNC'') protracted and 
        disorganized document production which still has not 
        concluded, as well as the DNC's failure to provide any 
        certain date when all records will be produced to 
        either congressional or Justice Department 
        investigators.
          IV. The Committee has been faced with a total lack of 
        cooperation from foreign governments. It has been 
        almost impossible to obtain relevant information and 
        access to witnesses. Furthermore, the Administration 
        has failed to press for any such cooperation which 
        would uncover the original source of the millions in 
        foreign money which flowed into the U.S. political 
        system over the past several years. In addition, the 
        People's Republic of China refused to allow visas to be 
        issued for Committee investigators and the 
        Administration did not press for cooperation in any 
        meaningful way.

I. The Unprecedented Number of Witnesses Who Refused To Cooperate With 
                     the Committee's Investigation

    In January 1997, the House Government Reform and Oversight 
Committee, in accordance with its oversight responsibilities, 
began an investigation into the allegedly illegal campaign 
finance activities of the 1996 elections.\1\ Since the 
Committee began its work, it has faced a level of stonewalling 
and obstruction never before encountered by a congressional 
Committee. During the course of the inquiry, the Committee ran 
into serious roadblocks in its attempts to secure testimony and 
obtain documents from the White House, the Democratic National 
Committee, and various witnesses.\2\ In June 1998, 18 months 
into the Committee's investigation, the number of witnesses 
refusing to testify topped 100.\3\ As of the beginning of 
October, the list had swelled to 120.
---------------------------------------------------------------------------
    \1\ Providing Special Investigative Authorities for the Committee 
on Government Reform and Oversight, H. Rept. No. 137, 105th Cong., 1st 
sess. (1997).
    \2\ Congressional Record, May 12, 1998, pp. H3054. Question of 
Personal Privilege. Remarks made by Government Reform and Oversight 
Committee Chairman Dan Burton.
    \3\ Government Reform and Oversight Committee press release, 10 New 
Witnesses Take the Fifth, Total now at 104, June 23, 1998.
---------------------------------------------------------------------------
    The number of potential witnesses who have exercised their 
Fifth Amendment right not to give testimony that would be self-
incriminating now stands at 79. An additional 18 witnesses have 
left the country, and 23 witnesses live overseas and have 
refused to be interviewed, bringing the total number of non-
cooperating witnesses to 120.\4\
---------------------------------------------------------------------------
    \4\ See Exhibit 1. Committee Chart detailing the 120 witnesses who 
have pled the fifth or fled the country to avoid cooperating with 
congressional investigations into campaign finance.
---------------------------------------------------------------------------
    On September 24, 1997, the Committee immunized three 
witnesses on the list who made illegal conduit contributions at 
the behest of Charlie Trie and Antonio Pan.\5\ On June 23, 
1998, the Committee immunized four additional witnesses 
relating to DNC fundraisers Johnny Chung, Gene and Nora Lum, 
and Ted Sioeng.\6\ The Senate also immunized several witnesses 
involved in the Hsi Lai Buddhist Temple fundraiser and other 
conduit contributions.\7\ However, the bulk of the 120 
witnesses have yet to be heard from.
---------------------------------------------------------------------------
    \5\ House Government Reform and Oversight Committee, Business 
Meeting: Immunity Vote. Sept. 24, 1997.
    \6\ House Government Reform and Oversight Committee, Business 
Meeting: Immunity Vote. June 23, 1998.
    \7\ Final Report of the Senate Committee on Governmental Affairs, 
S. Rept. No. 167, 105th Cong., 2d sess., vol. 2, at 1794-95, 2520.
---------------------------------------------------------------------------
    The list of people who are no longer in the country and who 
refuse to be interviewed include longtime Clinton friends and 
campaign contributors James and Mochtar Riady, who control the 
Lippo Group of Indonesia, Ng Lap Seng, the Macau financier who 
underwrote hundreds of thousands of dollars in illegal 
contributions orchestrated by Charlie Trie, and Antonio Pan, 
who was indicted with Trie by the Justice Department on January 
28, 1998.
    The number of witnesses associated with Trie who have taken 
the Fifth or refused to cooperate with the investigation totals 
13.
    Over 25 friends and family members of Ted Sioeng have 
either exercised their Fifth Amendment rights or left the 
country to avoid testifying. Sioeng and his network of business 
associates gave $400,000 to the Democratic party and another 
$150,000 to Republicans.\8\
---------------------------------------------------------------------------
    \8\ For details, see chapter IV D.
---------------------------------------------------------------------------
    There are 17 witnesses associated with John Huang who have 
either taken the Fifth or left the country.
    In June 1998, the Committee received notice that 12 
employees of Florida businessman Mark Jimenez would exercise 
their Fifth Amendment right not to testify about suspected 
conduit contributions to the Clinton/Gore campaign.\9\ Jimenez 
was indicted in September for orchestrating nearly $40,000 in 
illegal contributions to the Clinton/Gore campaign and other 
Democratic campaigns.\10\
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    \9\ See Letter to Richard D. Bennett, Chief Counsel, from John F. 
Conroy, June 17, 1998; Letter to Richard D. Bennett, Chief Counsel, 
from William L. Gardner June 30, 1998 (informing the Government Reform 
and Oversight Committee that the following individuals will assert 
their fifth amendment rights: Messrs, Jacob Devalle, William Gearhart, 
Richard Esparragoza, Manuel Garcia, Reynaldo B. Crespo, Raymond Dos 
Remedios, David Fried, Louis C. Leonardo, Juan L. Ruiz, Marcelino V. 
Brontonel, Enrique Sanchez, and Mrs. Ruth S. Ramirez).
    \10\ Department of Justice press release, Sept. 30, 1998.
---------------------------------------------------------------------------
    The list of witnesses who have asserted their Fifth 
Amendment right not to testify includes a number of 
Presidential appointees:
          Former White House Deputy Chief of Staff Mark 
        Middleton,
          Former Associate Attorney General Webster Hubbell,
          Former Deputy Assistant Commerce Secretary John 
        Huang, and
          Longtime Presidential friend and appointee Charlie 
        Trie, who was appointed to the Bingaman Commission on 
        international trade.
    During a December 1997 hearing of the Government Reform and 
Oversight Committee, Chairman Burton asked FBI Director Louis 
Freeh if the Director had ever seen so many witnesses in a 
Federal investigation invoke the Fifth Amendment or flee the 
country. Director Freeh responded by comparing the current 
investigation to his years fighting organized crime in New 
York:

        I spent 16 years doing organized crime cases in New 
        York City, and many people were frequently unavailable. 
        . . . It went on for quite a while.\11\
---------------------------------------------------------------------------
    \11\ Hearing on Current Implementation of the Independent Counsel 
Act Before the House Committee on Government Reform and Oversight, 
105th Cong., 1st sess., 294-295 (1997).

    The unwillingness of so many witnesses to provide sworn 
testimony became a serious obstacle to the Committee's efforts 
to conduct a thorough investigation and inform the public about 
the allegations under investigation. The extraordinary number 
of potential witnesses who either fled the country or invoked 
their Fifth Amendment rights is a strong indication of the 
unusual level of illegal activity that occurred during both the 
1992 and 1996 election cycles.
    Conversely, when witnesses did cooperate with the 
investigation, the Committee made swift progress. For example, 
upon granting immunity to three witnesses who made conduit 
contributions at the request of Charlie Trie and Antonio Pan 
(Manlin Foung, Joseph Landon and David Wang), the Committee 
received detailed information about these conduit payments and 
moved swiftly to public hearings.\12\ Months later, in June 
1998, the Committee granted immunity to four additional 
witnesses (Kent La, Irene Wu, Nancy Lee, and Larry Wong). Both 
Nancy Lee and Irene Wu then provided the Committee with 
important information relating to Johnny Chung's efforts to 
funnel illegal conduit contributions to Democratic 
campaigns.\13\
---------------------------------------------------------------------------
    \12\ Hearing on the Conduit Payments to the Democratic National 
Committee Before the House Committee on Government Reform and 
Oversight, 105th Cong., 1st sess. (1997) (testimony of Manlin Foung, 
Joseph Landon and David Wang).
    \13\ See Depositions of Nancy Lee, Government Reform and Oversight 
Committee, July 28, 1998; Deposition of Irene Wu, Government Reform and 
Oversight Committee, July 28, 1998.
---------------------------------------------------------------------------
    Attached as Exhibit 1 is the entire list of 120 individuals 
who have invoked the Fifth Amendment, fled the country, or 
refused to be interviewed in their home countries.

                          II. The White House

    In its oversight capacity the Committee on Government 
Reform and Oversight previously had the occasion to work with 
the Clinton White House on document productions pursuant to 
requests and subpoenas in other investigations, including the 
White House Travel Office investigation and the ``Filegate'' 
investigation. As documented in its reports on these 
investigations, the Committee was subjected to repeated delays 
and obstruction throughout its prior dealings with the White 
House.\14\ The Committee prepared for similar tactics during 
the 105th Congress, yet hoped for greater cooperation from 
President Clinton's newly appointed counsel, Charles F.C. Ruff. 
Unfortunately that was not to be the case, and the White 
House's actions during the document production phase served 
only to hinder the progress of the Committee's investigation 
for months. As the Senate Governmental Affairs Committee noted 
in its report, the White House used the 1 year deadline for the 
Senate investigation to drag out the process and stymie the 
efforts of the Senate to get to the bottom of the campaign 
finance scandal.\15\ Knowing of the penchant for this White 
House to drag out the investigative process, the House 
investigation did not agree to such time constraints.
---------------------------------------------------------------------------
    \14\ House Committee on Government Reform and Oversight, 
Investigation of the White House Travel Office Firings and Related 
Matters, H. Rept. No. 461, 104th Cong., 2d sess., 3 (1996); House 
Committee on Government Reform and Oversight, Investigation into the 
White House and Department of Justice on Security of FBI Background 
Investigation Files, H. Rept. No. 469, 104th Cong., 2d sess., 4 (1996).
    \15\ Final Report of the Committee on Governmental Affairs, U.S. 
Senate, ``Investigation of Illegal or Improper Activities in Connection 
with 1996 Federal Election Campaigns,'' 105th Cong., 2d sess., S. Rept. 
No. 105-167, vol. 1, p. 18-20.
---------------------------------------------------------------------------

             A. White House Responses to Committee Requests

    On February 6, 1997, the Chairman met and discussed the 
Committee's document production needs and expectations with Mr. 
Ruff, the White House Counsel. In that meeting, Mr. Ruff 
pledged the White House's cooperation and assured the Chairman 
that the President was committed to providing all of the 
documents necessary to the Committee's investigation and would 
not claim any privileges over any relevant documents in the 
campaign finance investigation.
    Prior to the Ruff meeting, the Committee had already made 
several document requests to Jack Quinn, who preceded Ruff as 
White House Counsel. During the 104th Congress, the Committee, 
under then-Chairman William F. Clinger, sent several campaign 
finance related document requests to the White House.\16\ 
Requests for documents related to John Huang were first made as 
early as October 1996. At the beginning of the 105th Congress, 
Chairman Burton issued a comprehensive request to the White 
House on January 15, 1997. This request was addressed to both 
Counsels Quinn and Ruff for documents relating to campaign 
finance matters.\17\
---------------------------------------------------------------------------
    \16\ Letter to President Bill Clinton from Chairman William F. 
Clinger, Jr., House Government Reform and Oversight Committee, Chairman 
Henry J. Hyde, House Judiciary Committee, and Chairman Bill Thomas, 
Committee on House Oversight, Oct. 18, 1996 (requesting that documents 
relating to John Huang's activities at the DNC be released publicly); 
Letter to President Bill Clinton from Chairman William F. Clinger, Oct. 
23, 1996 (requesting information on Jorge Cabrera); Letter to President 
Bill Clinton from Chairman William F. Clinger, Chairman Bill Thomas, 
and Chairman Henry J. Hyde, Oct. 25, 1996 (requesting information on 
John Huang and requesting FEC investigation); Letter to President Bill 
Clinton from Chairman William F. Clinger, Oct. 31, 1996 (requesting 
that the President make all records regarding John Huang available to 
Congress and the public); Letter to Terry Good, Office of Records 
Management, the White House from Chairman William F. Clinger, Jr., Oct. 
31, 1996 (requesting WAVES records for John Huang); Letter to John M. 
Quinn, Counsel to the President, from Chairman William F. Clinger, Nov. 
1, 1996 (requesting WAVES records for John Huang); Letter to John M. 
Quinn, Counsel to the President, from Chairman William F. Clinger, Jr., 
Nov. 14, 1996 (requesting WAVES records for John Huang); Letter to John 
M. Quinn, Counsel to the President, from Chairman William F. Clinger, 
Jr., Chairwoman Jan Meyers, House Small Business Committee, Chairman 
Bill Thomas, House Oversight Committee, Chairman Larry Combest, 
Permanent Select Committee on Intelligence, Chairman Donald Mazullo, 
House Subcommittee on Exports, Small Business Committee, Nov. 21, 1996 
(relating to SBA withholding of documents at the request of the White 
House).
    \17\ Letter to John M. Quinn, Counsel to the President, and Charles 
F.C. Ruff from Chairman Dan Burton, Jan. 15, 1997 (Exhibit 2).
---------------------------------------------------------------------------
    At the time of the January 15, 1997 Committee request for 
documents, the White House had already sent three directives to 
White House staff, instructing them to search for responsive 
documents.\18\ Each directive to search for documents requested 
that documents be produced no later than November 12, 1996, 
December 23, 1996 and January 17, 1997, respectively. Thus, the 
Committee had every reason to believe that a responsible White 
House interested in expeditiously responding to the campaign 
finance investigation would promptly turn over relevant 
records. However, Mr. Quinn wrote to Chairman Burton that the 
White House was unable to produce documents in the 2 week time 
period the Committee requested and that production would be 
delayed until a meeting time could be arranged with White House 
officials. One week after Quinn's letter, the White House 
released a number of responsive documents to the press, without 
producing them to the Committee.\19\ The documents were 
delivered to the Committee 5 days after the press received 
them, setting the tone for the manner in which the White House 
would respond to Committee requests and subpoenas.
---------------------------------------------------------------------------
    \18\ Memorandum to All Staff of the White House, the Office of 
Administration, the Office of Management and Budget, and all other 
units of the Executive Office of the President from Jack Quinn, Counsel 
to the President, Re: Documents Relating to the Lippo Group, Indonesia 
and Other Matters, Oct. 31, 1996 (Exhibit 3). Memorandum to Executive 
Office of the President Staff from Jack Quinn, Counsel to the 
President, Re: Document Request, Dec. 16, 1996 (Exhibit 4). Memorandum 
to Executive Office of the President Staff from Jack Quinn, Counsel to 
the President, Re: Follow-up to Dec. 16, 1996 Document Request, Jan. 9, 
1997 (Exhibit 5).
    \19\ Letter to Charles Ruff, Counsel to the President from Chairman 
Dan Burton, Jan. 31, 1997.
---------------------------------------------------------------------------
    Between January and March 1997, the White House refused to 
comply fully with any of the Committee's document requests. As 
a result, on March 4, 1997, the Committee issued a subpoena to 
the White House for a variety of records relevant to the 
campaign finance investigation.\20\ The subpoena called for the 
production of documents on March 24, 1997. As the White House 
had been collecting documents since the end of October 1996--
for almost 5 months--the Committee believed the time for 
production was adequate.\21\
---------------------------------------------------------------------------
    \20\ Subpoena to Executive Office of the President from Committee 
on Government Reform and Oversight, U.S. House of Representatives, Mar. 
4, 1998 (Exhibit 6).
    \21\  Exhibits 3, 4, and 5.
---------------------------------------------------------------------------
    The White House, in March 1997, refused to produce 
unredacted documents to the Committee until a protocol for the 
handling of documents was adopted by the Committee.\22\ The 
Chairman and Committee staff assured the White House Counsel's 
Office that the Committee was acting under a protocol approved 
by the Chairman until the full Committee was able to approve a 
document protocol. However, the White House would not provide 
the Committee with unredacted, or what it considered sensitive 
documents, 4 months into the investigation.\23\
---------------------------------------------------------------------------
    \22\ Letter to the Chief Counsel Government Reform and Oversight 
Committee from Lanny A. Breuer, Special Counsel to the President, Mar. 
19, 1997.
    \23\ Letter to Lanny A. Breuer, Special Counsel to the President 
from Chief Counsel Government Reform and Oversight, Mar. 19, 1997 
(Exhibit 7).
---------------------------------------------------------------------------
    The full Committee did approve a formal document protocol 
on April 10, 1997, yet the White House still would not produce 
documents to the Committee. The White House claimed that the 
protocol adopted by the full Committee was not sufficient to 
protect its documents.\24\ At one point, the White House 
Counsel's office even proposed a document protocol which would 
have required armed guards to stand watch over White House 
documents. The White House insisted that the Committee conform 
to its ``confidentiality proposal'' or what the White House 
considered appropriate procedures, including mandating the 
amount of Committee staff to have access to the documents.\25\ 
As a coequal branch of government, the Committee could not 
allow the executive branch to dictate the enforcement of or 
compliance with a legislative subpoena, or effectively annul 
the protocol approved by vote of the Committee.\26\ As for any 
national security or classified documents, the Committee made 
arrangements to have such material stored with the House 
Permanent Select Committee on Intelligence. Only a limited 
number of staff with proper security clearances were allowed to 
review the material.
---------------------------------------------------------------------------
    \24\ Letter to Chairman Dan Burton from Charles F.C. Ruff, Counsel 
to the President, Apr. 21, 1997.
    \25\ Letter to Chairman Dan Burton from Charles F.C. Ruff, Counsel 
to the President, Apr. 25, 1997 (Exhibit 8).
    \26\ Letter to Charles F.C. Ruff, Counsel to the President from 
Chairman Dan Burton, Apr. 27, 1997.
---------------------------------------------------------------------------
    Even while the White House refused to produce documents, 
the Committee attempted to accommodate the White House and 
ensure that documents would be forthcoming, by prioritizing the 
March 4, 1997, subpoena through an April 18, 1997 letter.\27\ 
The Committee engaged in extensive, good faith discussions and 
negotiations to assist the White House in producing documents. 
By late April, the White House still refused to cooperate and 
to produce all responsive documents. The Committee then issued 
six targeted subpoenas to the White House, focused on records 
relating to the Riady family, John Huang, Charlie Trie, Pauline 
Kanchanalak, Mark Middleton and Webster Hubbell.\28\
---------------------------------------------------------------------------
    \27\ Letter to Lanny A. Breuer, Special Counsel to the President 
from Chief Counsel Government Reform and Oversight, Apr. 18, 1997 
(Exhibit 9).
    \28\ Subpoenas to Executive Office of the President from Committee 
on Government Reform and Oversight, Apr. 23, 1997 (for records relating 
to the Riady family/Lippo Group and John Huang); subpoenas to Executive 
Office of the President from Committee on Government Reform and 
Oversight, Apr. 24, 1997 (for records relating to Charlie Trie and 
Pauline Kanchanalak); subpoenas to Executive Office of the President 
from Committee on Government Reform and Oversight, Apr. 29, 1997 (for 
records relating to Mark Middleton and Webster Hubbell).
---------------------------------------------------------------------------
    Despite the Committee's best efforts to work with the White 
House in prioritizing and streamlining requests, by the 
beginning of May 1997, the White House had not supplied the 
Committee with all relevant documents, had not informed the 
Committee which documents were being withheld, and had not 
provided the Committee with any production or privilege logs. 
Moreover, many of the documents that were produced to the 
Committee were redacted so heavily that they were 
unintelligible.

B. White House Claims of Executive Privilege and the Committee's Threat 
                              of Contempt

1. Claims of Executive Privilege over Documents

    In a May 9, 1997, letter to White House Counsel Charles 
Ruff, Chairman Burton insisted that the White House comply with 
the Committee's lawful subpoena, or in the alternative claim 
executive privilege over the documents being withheld and 
provide the Committee with a privilege log.\29\ The only valid 
claim the White House could make for withholding any documents 
from the Committee in the face of a lawful subpoena would be 
executive privilege.\30\ Executive privilege is a doctrine 
which historically has been exerted ``only in the most 
compelling circumstances, and only after careful review 
demonstrates that assertion of the privilege is 
necessary.''\31\
---------------------------------------------------------------------------
    \29\ Letter to Charles F.C. Ruff, Counsel to the President from 
Chairman Dan Burton, May 9, 1997.
    \30\ The Constitution does not grant Congress the explicit 
authority to investigate, neither does it grant the President the 
specific privilege to withhold information. However, the Supreme Court 
has held that the legislature and the executive each hold these 
respective powers as they are implied in the Constitution for the 
essential functioning of both branches. See, McGrain v. Daugherty, 273 
U.S. 135 (1927); United States v. Nixon, 418 U.S. 683 (1974).
    \31\ Memorandum for the Heads of Executive Department and Agencies 
from President Ronald Reagan, Procedures Governing Responses to 
Congressional Requests for Information, Nov. 4, 1982 (hereinafter 
``Reagan Memorandum'').
---------------------------------------------------------------------------
    In United States v. Nixon,\32\ the Supreme Court for the 
first time recognized a constitutional basis for executive 
privilege when it held that ``the protection of the 
confidentiality of Presidential communications has . . . 
constitutional underpinnings.'' \33\ However, the Court 
unequivocally rejected President Nixon's claim to an absolute 
privilege. Blanket claims, it held, are unacceptable without 
further, discrete justification, and then only when there is a 
need to protect military, national security, or foreign affairs 
secrets. It is only in such cases where the President's claim 
of privilege should receive deferential treatment in the face 
of a legitimate claim on materials from another branch of 
government. The Supreme Court set out this test in United 
States v. Nixon as follows:
---------------------------------------------------------------------------
    \32\ 418 U.S. 683 (1973).
    \33\ 418 U.S. at 705-06.

        However, neither the doctrine of separation of powers, 
        nor the need for confidentiality of high-level 
        communications, without more, can sustain an absolute, 
        unqualified Presidential privilege of immunity from 
        judicial process under all circumstances. The 
        President's need for complete candor and objectivity 
        from advisers calls for great deference from the 
        courts. However, when the privilege depends solely on 
        the broad, undifferentiated claim of public interest in 
        the confidentiality of such conversations, a 
        confrontation with other values arises. Absent a claim 
        of need to protect military, diplomatic, or sensitive 
        national security secrets, we find it difficult to 
        accept the argument that even the very important 
        interest in confidentiality of Presidential 
        communications is significantly diminished by 
        production of such material for in camera inspection 
        with all the protection that a district court will be 
---------------------------------------------------------------------------
        obliged to provide.

        To read the Article II powers of the President as 
        providing an absolute privilege as against a subpoena 
        essential to enforcement of criminal statutes on no 
        more than a generalized claim of the public interest in 
        confidentiality of non-military and non-diplomatic 
        discussions would upset the constitutional balance of 
        `a workable government' and gravely impair the role of 
        the courts under Article III.\34\
---------------------------------------------------------------------------
    \34\ 418 U.S. at 706,707.

    In the matters before the Committee in this investigation, 
as well as previous investigations, there has never been a 
situation involving the invocation of executive privilege to 
protect military, diplomatic, or national security secrets. To 
the contrary, the White House very promptly has turned over all 
national security information, which the Committee stored in a 
classified setting and kept confidential. It has been the non-
classified and the non-national security records that the White 
House has balked at providing. Thus, it is ironic; when it 
comes to protecting national security, the Administration takes 
far less dramatic measures to keep the information confidential 
than it does when keeping potentially embarrassing or 
potentially incriminating information from the Committee.\35\ 
Executive privilege was intended to operate in exactly the 
opposite way.
---------------------------------------------------------------------------
    \35\ It should be noted that despite the White House's decrying of 
leaks, White House officials have been notably silent about the stream 
of leaks from its own Justice Department of classified information over 
the past year and a half in matters involving the ``China Plan'' and 
other national security matters connected with the campaign finance 
investigation. See, Bob Woodward and Brian Duffy, ``Chinese Embassy 
Role in Contributions Probed,'' the Washington Post, Feb. 13, 1997, p. 
A1; Bob Woodward, ``Top Chinese Linked to Plan to Buy Favor,'' the 
Washington Post, Apr. 25, 1997, p. A1; Jeff Gerth, David Johnston and 
Don Van Natta, ``Democrat Fund-Raiser Said to Detail China Tie,'' the 
New York Times, May 15, 1998; Robert Suro, ``Chung Alleges DNC Sought 
Illegal Funds: Justice Dept. Probe Enters New Phase,'' the Washington 
Post, June 20, 1998.
---------------------------------------------------------------------------
    The Reagan Memorandum on executive privilege, which 
President Clinton's counsels have stated they follow, explains 
that the doctrine should only be invoked to ``preserve the 
confidentiality of national security secrets, deliberative 
communications that form a part of the decision making process, 
or other information important to the discharge of the 
Executive Branch's constitutional responsibilities.'' \36\ More 
importantly, the policy under President Reagan was that no 
privileges were claimed over any matters under investigation. 
During the Iran-Contra investigations, President Reagan assured 
the Congress that he would not claim executive privilege over 
any matters under investigation, nor did he.\37\ In contrast, 
President Clinton, while telling the American people he would 
fully cooperate with this and other investigations, has 
repeatedly invoked frivolous privilege claims in order to 
hamper congressional as well as criminal investigations.
---------------------------------------------------------------------------
    \36\ Reagan Memorandum.
    \37\ During Iran-Contra, President Reagan fully cooperated with 
Congress and turned over 300,000 White House, State Department, Defense 
Department, Justice Department and Central Intelligence Agency 
documents. Congress deposed numerous executive branch officials, 
including Attorney General Edwin Meese, and executive branch officials 
testifying before Congress. President Reagan even turned over his 
personal diaries without asserting executive privilege. Senate Select 
Committee on Secret Military Assistance to Iran and the Nicaraguan 
Opposition, S. Rept. No. 100-216, 100th Cong., 1st sess. (1987).
---------------------------------------------------------------------------
    In a memorandum to executive departments and agencies, 
Special Counsel to the President Lloyd Cutler outlined 
President Clinton's policy on executive privilege, ``[i]n 
circumstances involving communications relating to 
investigations of personal wrongdoing by government officials, 
it is our practice not to assert executive privilege, either in 
judicial proceedings or in congressional investigations and 
hearings.'' \38\ Despite President Clinton's stated policy, in 
May 1997, his Counsel refused to provide responsive documents 
which were ``subject to executive privilege.'' \39\ The 
Counsel's Office letter was effectively a claim of executive 
privilege.
---------------------------------------------------------------------------
    \38\ Memorandum for All Executive Department and Agency General 
Counsels from Lloyd N. Cutler, Special Counsel to the President, 
Congressional Requests to Departments and Agencies for Documents 
Protected by Executive Privilege, Sept. 28, 1994.
    \39\ Letter to the Chief Counsel Government Reform and Oversight 
from Lanny A. Breuer, Special Counsel to the President, May 14, 1997.
---------------------------------------------------------------------------
    The Committee considered whether to hold the White House in 
contempt for not responding to the subpoena, but first 
requested that Mr. Ruff appear before the Committee on May 15, 
1997 to explain the White House's position.\40\ It took this 
threat of contempt of Congress for the White House to begin to 
comply with the Committee's subpoenas. It was disappointing 
that it was not until this point that Mr. Ruff said his 
attention was ``focused'' on the issue of turning over the 
documents. In other words, the Committee had to threaten to 
hold the President's Counsel in contempt before the President 
would comply both with the law and his own stated policy.
---------------------------------------------------------------------------
    \40\ Id.
---------------------------------------------------------------------------
    Chairman Burton met with Mr. Ruff on May 16, 1997 to 
discuss White House document production. At that time, Mr. Ruff 
agreed to produce a volume of outstanding documents as well as 
a ``privilege log'' regarding any documents which were to be 
withheld from Congress under a claim of privilege. A production 
of the withheld documents followed this agreement. Some of the 
withheld documents included records such as a number of memos 
between and among members of the White House Counsel's office. 
The memos related to statements made by Deputy Counsel Bruce 
Lindsey regarding the President's meetings with James Riady and 
John Huang.\41\ These memos demonstrated there had been a 
dispute between White House Special Counsel Jane Sherburne and 
White House Deputy Counsel Bruce Lindsey in characterizing the 
President's contacts with James Riady and John Huang.
---------------------------------------------------------------------------
    \41\ White House Documents, EOP 008737-41, EOP 004943-47, EOP 
007378-82, EOP 004948-50, EOP 00406163, EOP 004956, EOP 008732-36, EOP 
004047-48, EOP 037008-17.
---------------------------------------------------------------------------
    Ms. Sherburne wrote that in October 1996, she learned from 
DNC General Counsel Joe Sandler that Huang had refused to tell 
him ``about one of the subjects that had been discussed in his 
September 1995 meeting with the President, Bruce and Riady. I 
asked Bruce if he had any idea what Huang was withholding and 
Bruce told me that they had discussed Huang moving from his 
post in the Commerce Department to a fundraising position at 
the DNC.'' \42\ Sherburne's memo demonstrated she was concerned 
that Lindsey refused to be more forthcoming about the Riady/
Huang meetings.\43\ On Lindsey's copy of Sherburne's memo 
Lindsey wrote to then White House Counsel Jack Quinn: ``Jack, 
This is mostly crap'' and signed his name.\44\
---------------------------------------------------------------------------
    \42\ White House Documents, EOP 008732-36 at 008734.
    \43\ Id.
    \44\ White House Document Production, EOP 008737-41.
---------------------------------------------------------------------------
    These memos provided information indicating that Huang did 
not want to talk about the meetings with the President. This 
was information that was certainly relevant to the Committee's 
inquiry. The fact that the White House Special Counsel was 
concerned about public representations made by Bruce Lindsey 
also was relevant to the inquiry. These memos were in no way 
``privileged'' and the fact that the White House Counsel's 
office withheld them for close to 5 months from investigators 
was not in keeping with the commitment for full cooperation. 
This was typical of the type of battle the Committee had to 
regularly engage in with the White House in order to obtain 
relevant subpoenaed records.
    It took another month of extensive negotiations to obtain 
access to the documents on the privilege log provided to the 
Committee in June 1997. Ultimately it took the Committee over 5 
months after the first requests to obtain the basic White House 
records.\45\ These delays in producing documents that the White 
House had gathered months before are inexcusable. Although the 
White House's actions impeded the House investigation, it had 
an even more dramatic impact on the Senate investigation, which 
had a strict time deadline.
---------------------------------------------------------------------------
    \45\ Letter from Charles F.C. Ruff, Counsel to the President to 
Chairman Dan Burton, May 20, 1997.
---------------------------------------------------------------------------

2. Claim of Executive Privilege over Testimony

    Claiming privilege in depositions was another method of 
White House stonewalling which unduly delayed proceedings. In 
September 1997, the Committee deposed Deputy White House 
Counsel Bruce Lindsey.\46\ During the deposition Lindsey 
testified that he spoke with the President about a conversation 
between James Riady and the President. When asked a follow up 
question about his conversation with the President, Lindsey 
declined to answer on the ground that his answer would 
implicate executive privilege concerns. Indeed, Lindsey called 
White House Counsel Charles Ruff on his cell phone in the 
deposition and reported on their conversation in the deposition 
record: ``And Mr. Ruff informs me--he says that these sorts of 
conversations give rise to serious executive privilege 
concerns; that at this time I should not respond, and that he 
will be happy to discuss it with you after the deposition.\47\
---------------------------------------------------------------------------
    \46\ Deposition of Bruce R. Lindsey, Government Reform and 
Oversight Committee, Sept. 8, 1997 (hereinafter ``Lindsey 
Deposition'').
    \47\ Id. at 54.
---------------------------------------------------------------------------
    The Committee subsequently wrote to White House Counsel 
Charles Ruff regarding Lindsey's claim of privilege.\48\ The 
Committee pointed out that the question posed to Lindsey 
involved his discussion with the President about a personal 
conversation with James Riady. Executive privilege is designed 
to protect executive branch decisionmaking, not to be used as a 
shield for personal matters having nothing to do with affairs 
of state or presidential decisionmaking. This conversation did 
not go to any core duties of the President or to national 
security or other sensitive matters. The White House responded 
to the Committee, noting that although Lindsey refused to 
answer, his refusal was based only on the fact that the 
response may be subject to privilege.\49\ Essentially, the 
White House made a distinction without a difference, as Lindsey 
refused to answer the question. After numerous letters and 
discussions with the White House about Mr. Lindsey's 
presumptive claim of privilege, Committee attorneys informed 
the Counsel's office of the Committee's intent to call Mr. 
Lindsey back for a deposition to answer these and other 
outstanding questions. It was made clear at the time that the 
Committee was prepared to proceed with contempt proceedings 
again if necessary. On April 29, 1998, Lindsey continued his 
deposition.\50\
---------------------------------------------------------------------------
    \48\ Letter to Charles F.C. Ruff, White House Counsel from Chairman 
Dan Burton, Feb. 25, 1998.
    \49\ Letter to Chairman Dan Burton from Charles F.C. Ruff, White 
House Counsel, Feb. 26, 1998.
    \50\ Deposition of Bruce Lindsey, Committee on Government Reform 
and Oversight, Apr. 29, 1998.
---------------------------------------------------------------------------
    It should be noted that at the same time the Committee was 
having such difficulty in obtaining Mr. Lindsey's testimony on 
this matter because of his frivolous privilege claims, Mr. 
Lindsey was asserting the same type of privilege claims in 
Federal court before the Whitewater grand jury.\51\
---------------------------------------------------------------------------
    \51\ Communication from the Office of the Independent Counsel, 
Kenneth W. Starr transmitting Appendices to the Referral to the United 
States House of Representatives pursuant to Title 28, United States 
Code, Section 595c submitted by the Office of the Independent Counsel, 
September 9, 1998, H. Doc. 105-311, 105th Cong., 2d sess., 184-200 
(1998).
---------------------------------------------------------------------------

3. The History of the Clinton Administration's Abuse of Privileges

    On many occasions over the past several years, the 
President has inappropriately invoked executive privilege in 
what many scholars and commentators have noted is a calculated 
attempt to delay ongoing criminal and congressional 
investigations. That this is done using government resources is 
deeply troubling. The President's history of using the White 
House Counsel to delay includes investigations by the House of 
Representatives, Senate and various independent counsels.
    For example, in November 1995, the White House invoked 
executive privilege in response to the Senate Whitewater 
Committee's subpoena.\52\ The privilege claim was over 
responsive notes taken by former Associate White House Counsel 
William Kennedy.\53\ Ultimately, after the Senate adopted a 
resolution directing the Senate Legal Counsel to initiate a 
civil action for an order to produce the documents, the White 
House acquiesced and produced the notes.\54\ The Senate 
Committee reported that the notes contained evidence that the 
White House inappropriately gathered information from various 
agencies investigating Whitewater, and passed such information 
to private lawyers for the President and First Lady.\55\
---------------------------------------------------------------------------
    \52\ Final Report of the Special Committee to Investigate 
Whitewater Development Corporation and Related Matters, S. Doc. No. 
280, 104th Cong., 2d sess., 237-238 (1996).
    \53\ Id.
    \54\ Id.
    \55\ Id.
---------------------------------------------------------------------------
    The Committee had a similar experience with the White House 
during the Travel Office investigation. The White House claimed 
privilege over more than 3,000 pages of documents and refused 
to produce the documents to the Committee.\56\ After 
negotiations with the White House failed, the Committee voted 
on May 9, 1996 to hold then-Counsel to the President Jack Quinn 
in contempt of its subpoena.\57\ On May 30, 1996, the morning 
of a scheduled House floor contempt vote, the documents were 
turned over to the Committee.\58\ Within the documents the 
White House had claimed executive privilege over were notes 
White House attorneys had taken of debriefing sessions with 
witnesses' attorneys.\59\ Perhaps most shocking was a request 
for former Travel Office Director Billy Dale's FBI background 
investigation, months after he was fired from the White 
House.\60\ This document led to the eventual discovery that 
hundreds of Reagan and Bush appointees' background files were 
obtained by the Clinton White House. None of these documents 
were even arguably privileged.
---------------------------------------------------------------------------
    \56\ House Committee on Gov't Reform and Oversight, Investigation 
of the White House Travel Office Firings and Related Matters, H. Rept. 
No. 461, 104th Cong., 2d sess., 8 (1996).
    \57\ Id.
    \58\ Id.
    \59\ Id.
    \60\ Id.
---------------------------------------------------------------------------
    In addition, the President's frivolous legal claims have 
delayed civil and criminal investigations. Over the past year, 
the Clinton Administration has litigated, and lost, the 
following four significant immunity/privilege cases: Clinton v. 
Jones,\61\ which held there was no temporary Presidential 
immunity from civil suit for unofficial acts; In re Grand Jury 
Subpoena Duces Tecum,\62\ in which claims of attorney-client 
and work product privilege asserted by the White House were 
denied; In re Sealed Case,\63\ in which executive privilege 
claims of the White House were ultimately overcome by 
Independent Counsel Smaltz's sufficient demonstration of need 
for the records in question; and, In re Sealed Case,\64\ in 
which White House claims of attorney-client and work produce 
privilege were denied.
---------------------------------------------------------------------------
    \61\ 117 S. Ct. 1636 (1997).
    \62\ 112 F.3d 910 (8th Cir. 1997), cert. denied 117 S. Ct. 2487 
(1997).
    \63\ 116 F.3d 550, reissued in unredacted form, 121 F.3d 729 (D.C. 
Cir. 1997).
    \64\ 124 F.3d 230 (D.C. Cir. 1997).
---------------------------------------------------------------------------
    The President's frivolous privilege claims have served him 
personally in delaying investigations and dragging out the 
process. However, they have not served the Presidency, which 
has ultimately been weakened by case after case being decided 
against the executive branch. During the Committee's 
investigation of the White House Travel Office matter, senior 
Justice Department official Michael Shaheen testified before 
the Committee that in his 20 year Justice Department career in 
the Office of Professional Responsibility, ``the lack of 
cooperation and candor'' from the Clinton White House was the 
worst he had experienced. Nothing the Committee experienced in 
the 105th Congress has changed that perception. While President 
Clinton has sought short term personal gain, in the long term 
it is the Presidency that has been most harmed by his frivolous 
privilege claims. This legacy will long outlast any personal 
matters related to Bill Clinton.

 C. Records Highly Relevant to the Campaign Finance Investigation Were 
     Produced Months or Even a Year after White House Certification

    On June 27, 1996, Counsel to the President Charles Ruff 
certified that the White House produced all documents 
responsive to the Committee's subpoenas, except those listed on 
the White House privilege log.\65\ After Mr. Ruff's 
certification to the Committee, the White House made 36 
productions of documents of over 17,700 pages responsive to the 
Committee's original subpoenas. The White House produced 
responsive documents as late as July 28, 1998, over a year from 
the date of the Committee's original subpoenas.
---------------------------------------------------------------------------
    \65\ Letter to Chairman Dan Burton from Charles F.C. Ruff, Counsel 
to the President, June 27, 1997 (Exhibit 10).
---------------------------------------------------------------------------

1. Documents relevant to the preliminary investigation of Vice 
        President Gore

    The July 1998, document production included memoranda 
relating to fundraising telephone calls made by Vice President 
Gore from his White House office.\66\ The fundraising calls 
were under investigation by the Department of Justice in late 
1997. On these belatedly discovered documents were handwritten 
notations of Gore Deputy Chief of Staff David Strauss.
---------------------------------------------------------------------------
    \66\ White House Document Production, July 28, 1998, EOP 070968-
070973.
---------------------------------------------------------------------------
    The notes indicate that there may have been discussions 
with the President and Vice-President about making phone calls 
for ``hard money'' as well as ``soft money'' for the DNC. The 
discussions occurred during a meeting, attended by both 
President Clinton and Vice President Gore, about raising money 
for the DNC through phone calls by the President and Vice 
President.\67\ Although there were questions raised regarding 
the legality of the calls, in December 1997, Attorney General 
Reno decided that there were no further grounds for 
investigation of Vice President Gore's fundraising calls under 
the Independent Counsel Act.\68\ However, at the time neither 
the Justice Department nor the Committee had knowledge of the 
White House documents, ultimately produced in July 1998, which 
would have been directly relevant to the initial inquiry.\69\ 
In fact, since obtaining the notes, the Justice Department has 
initiated another preliminary inquiry into the Vice President's 
phone calls.\70\ This second preliminary inquiry is to 
determine whether Vice President Gore lied to investigators 
when he was initially interviewed about his telephone 
solicitations to donors from the White House and said he had no 
knowledge of the phone call solicitations being for hard money.
---------------------------------------------------------------------------
    \67\ Id.
    \68\ David Johnston, Reno Rejects a Prosecutor on Clinton and Gore 
Calls; Bitter, G.O.P. Vows to Fight, New York Times, Dec. 3, 1997, at 
A1.
    \69\ The notes show that during the meeting there was a discussion 
of raising money for the DNC's media fund. Next to the budget for media 
is the handwritten notation ``65% soft/35% hard'' showing the breakdown 
of what type of money would be used. There is also a notation with the 
definition of soft money as ``corporate or anything over $20K from an 
individual.'' At issue in the original investigation was whether Gore 
knew that both hard and soft money would be used in the media fund. 
Gore told investigators that he believed only soft money would be used. 
One of Attorney General Reno's explanations for not pursuing an 
Independent Counsel in December 1997 was Gore's explanation that he 
believed he was only raising soft money. The newly produced memoranda 
cast doubt upon his statements. (Exhibit 11).
    \70\ David Johnston, Reno Is Extending Inquiry into Gore and 
Fundraising, New York Times, Aug. 27, 1998, at A1.
---------------------------------------------------------------------------

2. White House Communications Agency Videotapes

    An additional example of White House delays is the 
production of the White House videotapes on October 5, 1997. 
The Committee's March 4, 1997 subpoena clearly includes 
videotapes in its definition of records.\71\ However, the White 
House claimed that the Counsel's Office had no knowledge of the 
video taping performed by the White House Communications Agency 
(``WHCA'').\72\ The assertion is not credible as WHCA filmed 
the President daily, while he was constantly accompanied by 
White House senior staff. In fact, Deputy Counsel to the 
President Cheryl Mills, along with her family, was taped by 
WHCA during a Saturday morning radio address.\73\
---------------------------------------------------------------------------
    \71\ Paragraph one of the Committee's subpoena to the White House 
states: For the purpose of this subpoena, the word ``record'' or 
``records'' shall include, but shall not be limited to, any and all 
originals and identical copies of any item whether written, typed, 
printed, recorded, transcribed, punched, taped, filmed, graphically 
portrayed, video or audio taped, however produced or reproduced, and 
included, but is not limited to, any writing, reproduction, 
transcription, photograph, or video or audio recording, produced or 
stored in any fashion. . . . (Exhibit 6).
    \72\ White House Compliance with Committee Subpoenas: Hearings 
Before the House Committee on Government Reform and Oversight, 105th 
Cong., 1st sess., 87-93, 487 (1997). See also, Letter to Chairman Dan 
Burton and Ranking Minority Member Henry Waxman from Charles F.C. Ruff, 
Counsel to the President, Oct. 6, 1997.
    \73\ WHCA Videotape of Saturday Morning Radio Address, Mar. 11, 
1995.
---------------------------------------------------------------------------
    The White House Counsel's Office was specifically asked 
about video taping at the White House in early August 1997, yet 
failed to actively address the issue until late September after 
numerous particularized requests from Senate investigators.\74\ 
The White House search for the videotapes occurred at the same 
time Attorney General Janet Reno was making her decision about 
the need for an independent counsel to investigate White House 
fundraising practices, including the White House coffees.
---------------------------------------------------------------------------
    \74\ Deposition of Michael X. Imbroscio, Committee on Government 
Reform and Oversight, Oct. 16, 1997, 96-97, 149-156.
---------------------------------------------------------------------------
    Charles Ruff, Counsel to the President, testified that he 
was aware that Attorney General Reno was scheduled to make a 
decision on an independent counsel on Friday October 3, 1997, 
and he was told about the existence of the coffee videotapes 
early in the day of October 2, 1997, shortly before he met with 
Attorney General Reno.\75\ Despite Mr. Ruff's knowledge of 
Attorney General Reno's pending decision and his knowledge of 
the White House coffee videotapes which would be pertinent to 
her decision, Mr. Ruff failed to tell Miss Reno of the 
existence of the tapes during their meeting.\76\ When the 
existence of the videotapes was made public, the Justice 
Department called a number of members of the White House 
Counsel's office before the grand jury to explain why these 
records were withheld.
---------------------------------------------------------------------------
    \75\ White House Compliance with Committee Subpoenas: Hearings 
Before the House Committee on Government Reform and Oversight, 105th 
Cong., 1st sess., 159 (1997) (testimony of Charles F.C. Ruff).
    \76\ Id.
---------------------------------------------------------------------------
    The tapes are highly relevant to the investigation because 
they allow one to witness the President interacting with many 
of the individuals central to the campaign finance 
investigation, including many individuals who have either 
invoked their Fifth Amendment right against self incrimination 
or have left the country.\77\ For those who have refused to 
cooperate, the videos are the only first-hand information the 
Committee has on these individuals.
---------------------------------------------------------------------------
    \77\ Those individuals attending the coffees and other taped DNC 
events include: John Huang, James Riady, Charlie Trie and Wang Jun (a 
Chinese businessman and arms dealer), Ng Lap Seng (a.ka. Mr. Wu), Mark 
Middleton, Johnny Chung and six Chinese businessmen, Pauline 
Kanchanalak, Ted Sioeng, Arief Wiriadinata, Mark Jimenez, and Roger 
Tamraz.
---------------------------------------------------------------------------
    For instance, although the Committee was unable to speak 
with Arief Wiriadinata, an Indonesian landscaper, who along 
with his wife contributed $450,000 to the DNC, he is seen 
greeting the President during a White House coffee. As 
Wiriadinata shakes the President's hand, he says, ``James Riady 
sent me.'' \78\ President Clinton answers, ``yes, I'm glad to 
see you.'' \79\ Even after his statements, no one at the White 
House or DNC questioned the unusually large contributions. At 
this time, James Riady was living abroad and he was not 
eligible to contribute to any Federal or State campaigns.
---------------------------------------------------------------------------
    \78\ WHCA video of White House/DNC fundraising coffee, Dec. 15, 
1995.
    \79\ Id.
---------------------------------------------------------------------------
    In another video, President Clinton meets with Mark 
Middleton and Mark Jimenez privately prior to a February 6, 
1996, DNC fundraising coffee at the White House.\80\ They have 
a brief conversation about Jimenez's contributions to the 
Clinton Birthplace Foundation before entering the coffee. Both 
Middleton and Jimenez have invoked their Fifth Amendment right 
against self-incrimination in the face of a Committee subpoena, 
and Jimenez was recently indicted by the Department of Justice 
on campaign finance related matters.\81\ Middleton and Jimenez 
arranged for Carlos Mersan, an advisor of Paraguayan President 
Wasmosy, to attend the same coffee.\82\ Mr. Jimenez's wife 
wrote a $50,000 check to the DNC 2 days before the coffee.\83\ 
At the time, the Paraguayan President himself was unable to 
obtain a meeting with President Clinton. In addition, the 
United States had just de-certified Paraguay because of their 
record in fighting the narcotics war; de-certification would 
disqualify the country from certain aid as well. Shortly after 
the coffee, President Clinton issued a discretionary national 
interest waiver to Paraguay.
---------------------------------------------------------------------------
    \80\ Also attending the Feb. 6, 1996 DNC fundraising coffee at the 
White House was Charlie Trie. Trie brought Wang Jun, head of the 
Chinese company CITIC, to the White House coffee with the President. A 
CITIC subsidiary, Poly Technologies, is the Chinese company responsible 
for illegally smuggling thousands of Chinese AK-47 machine guns into 
California. WHCA video of White House/DNC fundraising coffee, Feb. 6, 
1996.
    \81\ Letter to Chairman Dan Burton from Robert D. Luskin, Attorney 
for Mark Middleton, Feb. 27, 1997; Letter to Richard D. Bennett, Chief 
Counsel Committee on Government Reform and Oversight from Abbe D. 
Lowell, Attorney for Mark Jimenez, Oct. 3, 1997.
    \82\ White House Document Production [Committee Bates No.] 004409-
10 (Exhibit 12). Democratic National Committee Document Production 
DNC3793399 (Feb. 5, 1996 DNC request for security information noting 
that Mersan is a guest of Mark Jimenez); CommerceCorp International 
Document Production CC-H-000573 (memorandum to Yusuf Khapra at the 
White House from Sandy McClure for Mark Middleton requesting White 
House access for Mark Jimenez and Carlos Mersan).
    \83\ Although the check was signed by Carol Jimenez, it was 
credited to Mark Jimenez with the FEC. Democratic National Committee 
Document Production, DNC 3064956.
---------------------------------------------------------------------------
    Along with the tapes of the coffees, the Committee 
requested videos of other fundraising events taped by the White 
House Communications Agency which were responsive to the 
Committee's subpoena. One such video shows the President and 
Commerce Secretary Ron Brown greeting Charlie Trie, Ng Lap Seng 
(a.k.a. Mr. Wu), Richard Mays, and Ernie Green.\84\ The 
President greets Trie and states, ``Hey Charlie, how are you 
doing?'' \85\ The President eventually gets to Ng Lap Seng, 
who, Ernie Green explains, hosted a small reception for Ron 
Brown in Hong Kong. Commerce Secretary Brown appears for a 
picture with the group and referring to Mr. Wu, tells the 
President, ``big business, helps us everywhere.'' Brown 
continues, ``This is part of the Trie Team,'' as Charlie Trie, 
Ng Lap Seng, several Asian businessmen, Ernie Green and Richard 
Mays, among others, line up to have their picture taken with 
Commerce Secretary Brown and President Clinton.\86\ From the 
setting and circumstances, one can infer that Brown was 
referring to Trie's fundraising prowess. The tape also shows 
the intimate relationship Trie had with high-level 
administration officials. The tape on this event was 
particularly important because the official records for this 
event do not show these individuals as attending the event. The 
videotape tells a different story than the paper record.
---------------------------------------------------------------------------
    \84\ White House Communications Agency video, African-American 
Luncheon Event at the Carbarn in Georgetown, Nov. 5, 1995.
    \85\ Id.
    \86\ Id.
---------------------------------------------------------------------------
    Although these three videos represent only a small sampling 
of those the Committee has reviewed, they demonstrate the type 
of information which can be gleaned from them. Although many of 
the individuals central to the Committee's investigation refuse 
to cooperate, the videotapes provide insight into the 
interaction between individuals and the familiarity some 
witnesses have with high level government officials.

                       D. Historical Perspective

    Although all congressional Committees involved in 
investigating the Clinton White House have complained about 
delays, specious claims of privileges, and general stonewalling 
tactics, the Committee hoped that the White House would be more 
cooperative under the new White House Counsel's Office headed 
by Charles Ruff.\87\ Unfortunately, despite the promises, the 
level of cooperation was no different under the new leadership 
of Mr. Ruff.
---------------------------------------------------------------------------
    \87\ Senate Special Committee to Investigate Whitewater Development 
Corp. and Related Matters, S. Rept. No. 280, 104th Cong., 2d sess., 11-
17 (1996); House Committee on Government Reform and Oversight, 
Investigation of the White House Travel Office Firings and Related 
Matters, H. Rept. No. 461, 104th Cong., 2d sess., 3 (1996); House 
Committee on Government Reform and Oversight, Investigation into the 
White House and Department of Justice on Security of FBI Background 
Investigation Files, H. Rept. No. 469, 104th Cong., 2d sess., 4 (1996).
---------------------------------------------------------------------------
    The Committee reviewed reports from investigations of prior 
administrations to determine whether the White House's conduct 
was consistent with that of Republican administrations. The 
Iran-Contra report stated:

        Once our investigation commenced, the White House rose 
        above partisan considerations in cooperating with our 
        far-reaching requests and in ensuring the cooperation 
        of other agencies and departments of the Executive 
        Branch. . . . Consequently, in compliance with our 
        requests, over 250,000 documents were produced by the 
        White House alone. . . . \88\
---------------------------------------------------------------------------
    \88\ Senate Select Committee on Secret Military Assistance to Iran 
and the Nicaraguan Opposition, S. Rept. No. 216, 100th Cong., 1st 
sess., 637 (1987).

During the Iran-Contra investigation, the Reagan White House 
produced a total of 250,000 documents in approximately 6 months 
and claimed no privileges, although many of the documents 
involved matters of national security.\89\ Likewise, during the 
October Surprise investigation, all Bush administration 
executive agencies cooperated fully, and President Bush did not 
claim any privileges.\90\ In contrast, the Clinton White House 
took over 6 months to produce less than 60,000 pages of heavily 
redacted documents related to fundraising, some of which the 
President claimed were privileged. The White House produced 
responsive documents over a year and a half into the 
investigation, and noted in a letter that it continues to 
search for relevant documents.\91\
---------------------------------------------------------------------------
    \89\ Id.
    \90\ The Joint Task Force did not request many records directly 
from the White House. The majority of the information came from the 
National Security Agency, Department of Defense, Department of Justice, 
Federal Bureau of Investigation, and other departments and agencies. In 
addition, many records came from private individuals. Task Force to 
Investigate Certain Allegations Concerning the Holding of American 
Hostages by Iran in 1980, H. Rept. No. 1102, 102d Cong., 2d sess., 15-
18 (1993).
    \91\ Letter to Barbara Comstock, chief investigative counsel, from 
Lanny A. Breuer, Special Counsel to the President, July 28, 1998.
---------------------------------------------------------------------------
    During the Iran-Contra investigation, senior White House, 
Justice Department and National Security officials testified at 
length without claiming privileges. Even Attorney General Edwin 
Meese testified about actions taken at the Justice Department 
regarding Iran-Contra. This cooperation was ongoing even while 
the White House and Reagan Justice Department had to respond to 
a massive independent counsel investigation of Iran-Contra 
matters.

                 III. The Democratic National Committee

    The DNC's refusal to produce relevant information in a 
timely manner acted as an additional restraint on the 
Committee's efforts. The Democratic National Committee blamed 
painfully slow document production on more urgent obligations 
to other investigations and grand jury subpoenas.\92\ When 
productions finally arrived, the Committee staff was often met 
with the challenge of decoding illegible documents resulting 
from the poor quality of photocopying.
---------------------------------------------------------------------------
    \92\ Letter to Chairman Dan Burton, House Government Reform and 
Oversight Committee, from Judah Best, Counsel to the DNC, Nov. 17, 
1997.
---------------------------------------------------------------------------
    In addition, production logs for many documents were never 
provided to the Committee despite repeated requests. This has 
made it impossible to ascertain the origin of many key 
documents. Documents with consecutive Bates numbers were 
produced weeks apart and were separated by thousands of pages. 
The DNC offered no reasonable explanation and left the 
Committee to simply wonder how and why this occurred. The DNC 
continued to extend promises of cooperation but time and time 
again the Committee encountered delay after delay. Over a year 
and a half after receiving the Committee's March 4, 1997, 
subpoena (preceded by a January 15, 1997 document request), the 
DNC continues to produce documents with no clear final 
production date in sight. As late as September 28, 1998, the 
Committee received a production of four boxes from the DNC.

                  A. DNC's Inability to Meet Deadlines

    The Committee first requested documents from the DNC in 
January 1997.\93\ From the beginning the DNC chose to ignore 
the Committee's requests and indicated that compliance with the 
Committee's due dates would be impossible.\94\ After no signs 
of cooperation were forthcoming, the Committee was forced to 
issue a subpoena for DNC documents on March 4, 1997, with a due 
date of March 24, 1997.\95\
---------------------------------------------------------------------------
    \93\ Letter request to Senator Christopher J. Dodd and Mr. Donald 
Fowler, from Chairman Dan Burton, House Government Reform and Oversight 
Committee, Jan. 15, 1997 (requesting documents relating to the Asian 
Pacific American Working Group and the Asian Pacific American 
Leadership Council).
    \94\ Letter to Tim Griffin, senior investigative counsel, from 
Joseph Sandler, Counsel to the DNC, Jan. 22, 1997.
    \95\ Subpoena to Democratic National Committee from Government 
Reform and Oversight Committee, U.S. House of Representatives, Mar. 4, 
1997 (Exhibit 13).
---------------------------------------------------------------------------
    By April 22, 1997, the DNC had produced little more than 
nine boxes of documents. The DNC's rate of production was 
surprising, as it was on notice since before the November 1996 
elections that Congress would be investigating the fundraising 
issues involved in the 1996 federal elections. Nevertheless, 
partial productions followed, accompanied by constant excuses 
that resources and staff were needed elsewhere, implying that 
the Committee's inquiry was labeled a low priority. The 
Committee was not provided with an indication of when the DNC 
intended to comply with the subpoena. Over the course of the 
following 6 months, the DNC provided 127 boxes, which 
represented a small percentage of the overall production 
requested by the Committee.\96\ This left the Committee with no 
real sense that anyone was taking responsibility for complying 
with the Committee's request.
---------------------------------------------------------------------------
    \96\ Letter to Judah Best, Counsel to the DNC from Chairman Dan 
Burton, House Government Reform and Oversight Committee, July 16, 1997 
(expressing concern over the slow rate of production exhibited by the 
DNC).
---------------------------------------------------------------------------
    On September 8, 1997, the Committee sent interrogatories to 
the DNC regarding the return of certain contributions.\97\ Even 
though the Committee was entitled to accurate answers to these 
questions, DNC counsel suggested the information ``may largely 
if not entirely'' be found among documents already in the 
Committee's possession.\98\ This response was unacceptable and 
unrealistic because the Committee was not provided with 
production logs; therefore, it would be difficult and 
extraordinarily time consuming for staff to locate these 
relevant documents. It was November 1997 before the DNC 
addressed this issue and agreed to respond to the Committee's 
interrogatories by November 21, 1997.\99\ To date, the DNC 
continues to tell the Committee that it cannot estimate when 
its document production will be completed.
---------------------------------------------------------------------------
    \97\ Letter to Judah Best, Counsel to the DNC, from Chairman Dan 
Burton, Sept. 8, 1997.
    \98\ Letter to Chairman Dan Burton from Judah Best, Counsel for the 
DNC, Sept. 15, 1997.
    \99\ Letter to Chairman Dan Burton from Judah Best, Nov. 17, 1997.
---------------------------------------------------------------------------
    The DNC displayed a propensity to produce significant 
information just prior to depositions or just after a 
deposition had been completed. The most glaring example, also 
reported by the press, was the late ``discovery'' of 
significant material from the filing cabinet of DNC Finance 
Director, Richard Sullivan.\100\ The DNC originally claimed 
that boxes of documents found sitting in a filing cabinet in 
Richard Sullivan's office were generic Finance Division 
documents that no one had bothered to search.\101\ However, 
these documents proved to be some of the most significant 
produced, containing Sullivan's handwritten notes, files on 
Democratic contributors Roger Tamraz and Johnny Chung, and 
fundraising call sheets prepared for Hillary Rodham Clinton.
---------------------------------------------------------------------------
    \100\ Bob Woodward, ``Senate Probes DNC Files Delay,'' the 
Washington Post, Aug. 8, 1997, p. A1.
    \101\ On Friday, Aug. 1, 1997, a DNC attorney called the Senate 
Committee on Governmental Affairs and informed it that a number of the 
boxes were actually from Richard Sullivan's files. Mr. Sullivan was 
deposed in May and again in June, and had been the Senate Committee's 
first witness in public hearings on July 9-10.
---------------------------------------------------------------------------
    Shortly after the DNC produced these documents, the 
Committee deposed Sullivan. At the time, DNC Chairman Roy Romer 
stated that the failure to discover the documents earlier was 
the result of ``pure, innocent oversight.'' \102\ However, 
Richard Sullivan himself said he told Joseph Birkenstock, a 
lawyer for the DNC's Office of General Counsel, about the 
documents on the day of his departure from the DNC, ``I pointed 
out to him the boxes in which I assembled the documents from my 
office with the exception of the file cabinet and I pointed out 
the file cabinet to him.'' \103\ The Committee must conclude 
there was an obvious lack of due diligence in the DNC's search.
---------------------------------------------------------------------------
    \102\ Bob Woodward, ``Senate Probes DNC Files Delay,'' the 
Washington Post, Aug. 8, 1997, p. A1.
    \103\ Deposition of Richard Sullivan before the Senate Committee on 
Governmental Affairs, Sept. 5, 1997, p. 215.
---------------------------------------------------------------------------
    The Committee was in a similar situation when it deposed 
David Mercer, the Deputy Director of the Finance Division, on 
August 21, 1997.\104\ The day before his deposition, the DNC 
produced a box of documents relevant to the questioning of 
Mercer. The Committee had no alternative but to suffer the 
inconvenience of bringing Mercer back for additional 
questioning. To add insult to injury, at the conclusion of the 
deposition, the DNC provided the Committee with three more 
boxes of relevant documents. Three days later, four more boxes 
of relevant documents arrived. On September 5, 1997, the DNC 
gave the Committee another eight boxes of information, 
including documents that came from Mercer's own files. The 
arrival of documents on a serial basis made it impossible to 
conduct a thorough deposition of Mercer. This pattern of 
production continued throughout the investigation, and not only 
made the deposition process more difficult and time consuming, 
but also brought into question whether the witnesses' testimony 
was thorough and reliable.
---------------------------------------------------------------------------
    \104\ Deposition of David Mercer before the Committee on Government 
Reform and Oversight, Aug. 21, 1997.
---------------------------------------------------------------------------

                 B. Refusal to Provide Production Logs

    During the investigation, there were ongoing discussions 
over whether the DNC would provide production logs to the 
Committee. Such a log, indicating the origin of the documents 
produced, would provide some semblance of order to the DNC's 
randomly assembled documents. In addition, a production log is 
of particular importance when preparing for depositions. 
Without a log, it is impossible to know from whose files a 
document, such as a calendar or phone log, came. For example, a 
memo in one person's possession could be innocuous but in the 
hands of another it might raise questions.
    The DNC continuously refused to provide the Committee with 
a complete production log for all documents, claiming that it 
could not afford to divert personnel to accomplish the 
task.\105\ The Committee found the DNC's argument of lack of 
personnel to be disingenuous after detailed handwritten 
production logs were mistakenly left in a document production 
to the Committee.\106\ The logs included the document 
identification number, the box number in which the document was 
located, and a detailed description of the document.\107\ 
Although the DNC had the time to create logs for itself, if its 
arguments are to be believed, the DNC could not afford the 
staff time to photocopy the logs for the Committee.
---------------------------------------------------------------------------
    \105\ Letter to Chairman Dan Burton, Committee on Government Reform 
and Oversight, from Judah Best, Counsel to DNC, Nov. 17, 1997.
    \106\ The DNC mistakenly left approximately 300 pages of production 
logs in the boxes of documents. A representative sample is produced as 
an exhibit. DNC Document Production Log, Aug. 29, 1997 (Exhibit 14) 
[Democratic National Committee Production Logs].
    \107\ Id.
---------------------------------------------------------------------------
    Ultimately, the DNC produced an interim log of the contents 
of the first 66 boxes.\108\ However, in one exchange, the 
Committee was informed that the DNC had no plan for providing 
any form of production log for material contained in boxes 
produced subsequent to box 66.\109\ The DNC tried to impose an 
agreement on the Committee that was made by the Senate 
Committee on Governmental Affairs.\110\ Although the Senate 
agreed to forgo production logs, it was under the imposition of 
a deadline and needed documents on an expedited basis. The 
Government Reform and Oversight Committee, however, had no such 
hindrance and would have benefited greatly from the DNC's 
cooperation.
---------------------------------------------------------------------------
    \108\ Letter to Barbara Comstock, chief investigative counsel, from 
Judah Best, Counsel to DNC, July 11, 1997.
    \109\ Letter to Paul Palmer, Counsel to the DNC, from James C. 
Wilson, senior investigative counsel, July 18, 1997.
    \110\ Letter to Barbara Comstock, chief investigative counsel, from 
Judah Best, Counsel to the DNC, July 11, 1997 (the Senate Committee 
agreed to accept productions after box 66 without detailed 
representations regarding the specific sources of all of those 
documents).
---------------------------------------------------------------------------

                    c. adoption of document protocol

    The Committee formally adopted its Document Protocol on 
April 10, 1997.\111\ The DNC criticized the Protocol claiming 
it did not provide adequate protection for sensitive documents. 
Such criticism ignored the provision allowing for the public 
release of documents only after the Chairman consulted with an 
Advisory Committee. Prior to the adoption of the protocol, the 
DNC had produced just over nine boxes of documents and refused 
to produce certain documents deemed confidential. These 
documents were under subpoena, and the DNC was legally 
obligated to produce them. Even though the DNC had no basis for 
withholding, it allowed the Committee an opportunity to review 
these ``confidential'' documents only in the office of the 
DNC's counsel.\112\ At this time, there were about 30 boxes of 
``sensitive'' documents that the Committee had not received. It 
was impossible for staff only to have limited access to these 
documents and yet be able to compare them to other documents 
and conduct an effective investigation. The Committee made 
every attempt to cooperate but the demands made by the DNC were 
outrageous.
---------------------------------------------------------------------------
    \111\ Protocol for Documents, Apr. 10, 1997 (Exhibit 15).
    \112\ Letter to Committee from Judah Best, Counsel for DNC, Apr. 
18, 1997.
---------------------------------------------------------------------------
    Due to the necessity that the staff review such a large 
volume of documents, the Chairman again on May 28, 1997, 
requested that the DNC comply with the Committee's document 
request.\113\ Ultimately, the DNC agreed to produce the 
confidential documents.\114\ However, rather than copy the 
documents in its possession and send them to the committee all 
at one time, the DNC insisted on producing them in increments. 
The manner in which the DNC produced documents to this 
committee is yet another example of footdragging.
---------------------------------------------------------------------------
    \113\ Letter to Judah Best, Counsel for DNC, from Chairman Dan 
Burton, Committee on Government Reform and Oversight, May 28, 1997.
    \114\ Letter to Chairman Dan Burton, Committee on Government Reform 
and Oversight, from Judah Best, May 29, 1997.
---------------------------------------------------------------------------

                D. alleged duplication of senate efforts

    During the course of the investigation, the Committee 
requested to depose certain present and former employees of the 
DNC. The DNC raised concerns that this would be an unnecessary 
duplication of the Senate's efforts and suggested that the 
Committee staff review prior testimony and limit the inquiry to 
matters not previously covered.\115\ In many cases involving 
certain DNC witnesses, the Committee did agree to delay 
depositions. Although the Committee had no desire to duplicate 
efforts, in many instances the Senate depositions were not 
available. Even more important, usually the DNC had produced 
additional relevant documents relating to an individual after 
the Senate deposition, which raised further questions. In 
addition, the Committee needed to interview or depose witnesses 
who had testified before the Senate because the two 
investigations had different scopes. Unlike the Senate, the 
Committee was not limited to the 1996 Presidential 
Election.\116\ Therefore, the DNC's objection based on 
``duplication'' was not valid and impeded the effective 
examination of witnesses.
---------------------------------------------------------------------------
    \115\ Letter to Barbara Comstock, chief investigative counsel, from 
Judah Best, July 3, 1997.
    \116\ House Resolution 167.
---------------------------------------------------------------------------
    The various obstruction tactics employed by the DNC 
hampered the Committee's investigation. The slow response to 
the Committee's requests and the pattern of delay undercut any 
promises of cooperation made by the DNC. The failure to produce 
documents in a timely manner burdened the taxpayers and 
inconvenienced the DNC's own employees. Despite the DNC's 
resistance, the Committee uncovered a great deal of information 
regarding the suspect fundraising practices of the DNC.

    IV. Failure of the Clinton Administration To Press for Foreign 
    Cooperation and the Failure of Foreign Governments To Cooperate

    Shortly before the 1996 Federal elections, it was revealed 
that the DNC had accepted illegal foreign contributions. As 
time passed, the scope of the infiltration of foreign money was 
soon realized. Millions of dollars in foreign money were 
contributed to the DNC from foreign sources. When the Committee 
pursued its investigation, it found that cooperation stopped at 
the U.S. borders. In addition, it was difficult to get 
cooperation from U.S. citizens, many of whom invoked their 
Fifth Amendment right against self-incrimination, or in the 
alternative, fled the country. With many important witnesses in 
the United States obstructing the investigation, the 
cooperation of foreign governments was critical if the identity 
of the ultimate sources of contributions and the motivation for 
making illegal contributions were to be revealed.
    The nature of the Committee's investigation into 
contributions from foreign sources necessarily required foreign 
documents, particularly bank records, as well as the 
cooperation of witnesses in foreign countries. In order to gain 
cooperation from such foreign governments, the Committee 
followed established diplomatic procedures to request 
assistance in its investigation. Generally, all requests 
relating to foreign governments would be channeled through the 
executive branch, specifically the Department of State.
    The Committee was quickly disappointed in the level of 
cooperation from both the Clinton Administration and the 
relevant foreign governments. Although the Clinton 
Administration adopted a public stance of cooperation, it did 
almost nothing to assist the Committee, or its own Department 
of Justice's investigations. The open refusal of some foreign 
governments to cooperate seems to indicate that the belief that 
there would be no consequences from the Clinton Administration 
for non-cooperation.

                     a. the clinton administration

    In February 1997, the media reported on a Chinese plan to 
attempt to infiltrate the U.S. political system.\117\ In the 
face of such allegations, President Clinton called for a 
thorough investigation.\118\ However, it soon became apparent 
that the Administration would not adhere to the President's 
public pronouncement.
---------------------------------------------------------------------------
    \117\ Bob Woodward and Brian Duffy, ``Chinese Embassy Role in 
Contributions Probed,'' the Washington Post, Feb. 13, 1997, at A1.
    \118\ Susan Schmidt, ``Clinton: New Allegations Warrant Vigorous 
Probe; President Says He Was Unaware of Focus on Chinese,'' the 
Washington Post, Feb. 14, 1997, at A12.
---------------------------------------------------------------------------
    One month later in March 1997, during an official visit to 
China, Vice President Gore dismissed the importance of the 
campaign finance investigation by telling Chinese Premier Li 
Peng in a private meeting that, ``this in no way would deflect 
the administration from pursuing its policy of 
engagement.''\119\ In fact, the Vice President did not even 
warn Li that there would be serious consequences if the 
allegations were proven true.\120\ Foreign governments could 
not be faulted for interpreting Vice President Gore's words as 
a signal that the Administration was not expecting their 
cooperation.
---------------------------------------------------------------------------
    \119\ John F. Harris, ``Funds Probe Won't Mar U.S.-China Ties, Gore 
Says; Dispute Surfaces Over Talks With Beijing Premier,'' the 
Washington Post, Mar. 26, 1997, at A1.
    \120\ An official spokesman, who was present at the meeting between 
Li and the Vice President, said the Vice President never discussed what 
would happen if the allegations were proven true. Later, a more senior 
official who refused to be identified, said the first official 
statement was erroneous and that the Vice President did say that if the 
allegations were true, ``it's a very serious matter.'' Id.
---------------------------------------------------------------------------
    According to news reports, allegations of the Chinese 
government's role in illegal foreign contributions came from 
electronic eavesdropping by U.S. intelligence agencies.\121\ 
The Vice President, though, downplayed the significance of 
those interceptions when he told Li that, ``unproven 
allegations are not significant; what are significant are the 
facts.'' \122\ Although the Committee shares the Vice 
President's view, in order to obtain the facts, foreign 
governments must assist in acquiring documents sought by the 
Committee and make witnesses available for interviews.
---------------------------------------------------------------------------
    \121\ Bob Woodward and Brian Duffy, ``Chinese Embassy Role in 
Contributions Probed,'' the Washington Post, Feb. 13, 1997, at A1.
    \122\ Hilary Stout and Kathy Chen, ``Gore Assures China On Bid to 
Bolster Ties,'' the Wall Street Journal, Mar. 26, 1997, at A3.
---------------------------------------------------------------------------
    President Clinton took Vice President Gore's statements a 
step further when it was publicly revealed that the FBI had 
evidence that top levels of the Chinese government may have 
been involved in the illegal contributions.\123\ Although 
President Clinton stated that there would be serious 
consequences in U.S.-China relations if the allegations were 
true, he went on to suggest that perhaps China was simply 
trying to increase its lobbying presence in Washington.\124\
---------------------------------------------------------------------------
    \123\ John F. Harris, ``Don't Prejudge China, Clinton Urges; He 
Says Beijing May Have Sought to Make Voice Heard Here Legally,'' the 
Washington Post, Apr. 26, 1997, at A16.
    \124\ Id.
---------------------------------------------------------------------------
  b. china denies any involvement in a plan to funnel money into u.s. 
                               elections
    The Chinese government has steadfastly denied any role in 
the funneling of illegal contributions to the DNC. After it was 
reported that U.S. intelligence agencies acquired evidence of 
the Chinese government's involvement in the scheme, the Chinese 
State Information Department said, ``[w]e express indignation 
at the evil actions of those persons within the U.S. government 
who continue to spread rumors, disrupting and sabotaging Sino-
U.S. relations.''\125\ The Chinese government even went so far 
as to insist that U.S. officials should not allow such articles 
to appear in the press.\126\
---------------------------------------------------------------------------
    \125\ Marc Lacey; Jack Nelson, ``Clinton Tries to Quell China Funds 
Impact,'' Los Angeles Times, Apr. 26, 1997, at A1.
    \126\ Id.
---------------------------------------------------------------------------
    While traveling in China this past summer, President 
Clinton held a joint press conference with Chinese President 
Jiang Zemin on June 27, 1998. During the press conference Jiang 
Zemin stated that his government had conducted a thorough 
investigation of the allegations of a Chinese plan and found 
that there was no such plan.\127\ In response to questions 
about the Chinese government's denial, President Clinton 
stated:
---------------------------------------------------------------------------
    \127\ White House Press Conference, Beijing China, Office of the 
Press Secretary, June 27, 1998.

        [Jiang Zemin] said they looked into that [the campaign 
        finance allegations] and that he was obviously certain. 
        And I do believe him, that he had not ordered or 
        authorized or approved any such a thing, and that he 
        could find no evidence that anybody with governmental 
        authority had done that.\128\
---------------------------------------------------------------------------
    \128\ ``We Can Build a Good Positive Partnership,'' the Washington 
Post, July 4, 1998, at A20.

Although President Clinton may have full faith in the 
assertions of the Chinese government, other administration 
officials are skeptical. Louis Freeh, Director of the FBI, when 
asked if he believed Zemin's statement that they conducted an 
earnest investigation, replied, ``I'd like to see his report.'' 
\129\ Director Freeh also stated that the FBI has not accepted 
China's statement and has continued to investigate foreign 
links with the investigation.\130\
---------------------------------------------------------------------------
    \129\ The Need for an Independent Counsel in the Campaign Finance 
Investigation, H. Rept. No. 105-155, 105th Cong., 2d sess., 138 (1998).
    \130\ Id.
---------------------------------------------------------------------------
  c. the committee's attempts to investigate overseas involvement in 
                     illegal foreign contributions
    In order to conduct a proper investigation, the Committee 
required the assistance of foreign governments in three areas: 
production of documents, availability of witnesses, and 
overseas travel. The Committee attempted to secure the 
cooperation of foreign governments, through the Clinton 
Administration, on all three fronts.
1. China
            a. Charlie Trie
    The first request by the Committee came after Yah Lin 
``Charlie'' Trie's June 24, 1997, interview with Tom Brokaw on 
``NBC Nightly News.'' Earlier in 1997, Trie had fled the United 
States after allegations of his illegal fundraising had 
surfaced in the press. After the broadcast of the Trie 
interview, the Committee asked President Clinton to formally 
petition the Chinese government to make Trie available to the 
Committee.\131\ The Committee received nothing but a 
perfunctory response \132\ to its requests until Trie made a 
July 27, 1997 appearance on a competing nightly news show, 
again from China.\133\ According to the broadcast, Trie had 
been living in a hotel in Beijing for weeks, registered under 
his own name.\134\ Just the week before, Chinese officials 
stated that they did not know whether Trie was in China.\135\
---------------------------------------------------------------------------
    \131\ Letter from Chairman Burton to President Clinton, June 27, 
1997.
    \132\ The only response from the State Department thus far stated:

        Consistent with the Secretary's commitment to provide the 
      maximum possible assistance to Congress in this matter, I 
      am pleased to inform you that, on July 14 the Department 
      communicated to the Chinese Embassy your request that the 
      PRC help facilitate the return of Mr. Trie to the United 
      States for questioning or, at a minimum, make him available 
      for a deposition by the Committee and its staff. We also 
      asked the Chinese Government to treat this matter as a high 
      priority in which Secretary Albright is personally 
---------------------------------------------------------------------------
      interested.

Letter from Barbara Larkin, Assistant Secretary of Legislative Affairs, 
to Chairman Burton, July 21, 1997.
---------------------------------------------------------------------------
    \133\ ABC Nightly News (ABC television broadcast, July 27, 1997).
    \134\ Id.
    \135\ Id.
---------------------------------------------------------------------------
    Shortly after the second interview of Trie was broadcast, 
the State Department contacted the Committee with a telephone 
number for a Beijing hotel where Trie was supposed to be 
staying.\136\ The Committee received this information on the 
same day that Trie was scheduled to check-out and all attempts 
to contact Trie at that telephone number were unsuccessful. The 
phone number was absolutely useless to the Committee. 
Nevertheless, the administration continued to use it as an 
example of the great lengths it went to to cooperate with the 
investigation.
---------------------------------------------------------------------------
    \136\ Letter from Barbara Larkin, Assistant Secretary of 
Legislative Affairs, to Chairman Burton, Aug. 8, 1997. Although the 
State Department provided the information to the Committee, it is not 
known how the State Department learned of Trie's location. However, in 
a later letter to the Committee, the State Department seems to imply 
that the Chinese government originally supplied the information to the 
State Department. The letter states, ``Chinese Embassy officials 
recalled, for example, that last summer Beijing provided information 
pursuant to your Committee's request regarding the whereabouts of Yah 
Lin ``Charlie'' Trie. Letter from Barbara Larkin, Assistant Secretary 
of Legislative Affairs, to Chairman Burton, Feb. 13, 1998.
---------------------------------------------------------------------------
            b. Bank Records
    Much of the Committee's investigation is dependent upon 
securing records of bank accounts showing wire transfers and 
the general flow of money to and from accounts. In order to 
show that a contribution was made with foreign money or that it 
was a conduit payment, one must show from where the money came. 
In the case of foreign money, the wire transfers normally lead 
to an overseas account. The Committee is therefore unable to 
trace the source of such funds without the cooperation of the 
foreign government.
    In December 1997, the Committee attempted to identify the 
ultimate sources of identified foreign contributions through 
subpoenas issued to the New York branch of the Bank of China. 
The subpoena requested the production of records from the Bank 
of China branches in Macau and Hong Kong along with those from 
the New York branch. Although the New York branch duly 
complied, the bank refused to supply records from the Macau and 
Hong Kong branches on the basis that the production of those 
documents would violate local laws.\137\ Likewise, the Bank of 
China denied records requested by the Justice Department Task 
Force.\138\
---------------------------------------------------------------------------
    \137\ Letter from Christopher Brady to Committee Counsel, Jan. 13, 
1998.
    \138\ The Need for an Independent Counsel in the Campaign Finance 
Investigation, H. Rept. No. 155, 105th Cong., 2d sess., 137 (1998).
---------------------------------------------------------------------------
            c. Visa Requests
    In January 1998, the Committee requested visas for four 
investigators to enter China and Hong Kong. The Chinese Embassy 
in Washington informed the Committee that it had standing 
orders from the Chinese Foreign Ministry in Beijing to reject 
visa requests from any congressional entity seeking to visit 
China that is involved in the present campaign finance 
investigation.\139\
---------------------------------------------------------------------------
    \139\ Letter from Chairman Burton to Secretary of State Madeleine 
K. Albright, Feb. 4, 1998. With the Chinese takeover of Hong Kong in 
July 1997, the refusal to process the visas extended to Hong Kong as 
well as China.
---------------------------------------------------------------------------
    The Committee asked the State Department to intervene and 
persuade the Chinese government to reconsider its decision. The 
State Department responded that it had urged the Chinese 
government to reconsider its decision to deny Committee staff 
visas, and mentioned Secretary Albright's personal interest in 
the matter.\140\ Not surprisingly, the Chinese government 
maintained its position on the visas. The State Department made 
no further attempts to assist the Committee or the Justice 
Department Task Force in obtaining visas.
---------------------------------------------------------------------------
    \140\ Letter from Barbara Larkin, Assistant Secretary of 
Legislative Affairs, to Chairman Burton, Feb. 13, 1998.
---------------------------------------------------------------------------
    In an effort to find alternative methods of meeting with 
witnesses in China, the Committee made several suggestions to 
the Administration. On March 9, 1998, Chairman Burton wrote 
directly to the President, requesting his assistance.\141\ 
After receiving no response, the Committee wrote again on March 
31, 1998, suggesting that Committee and Justice Department 
investigators accompany the President on his pending trip to 
China.\142\ Although the President visited China with an 
entourage of over 1,000, the Committee and Justice Department 
investigators were not invited.
---------------------------------------------------------------------------
    \141\ Letter from Chairman Burton to President Clinton, Mar. 9, 
1998.
    \142\ Letter from Chairman Burton to President Clinton, Mar. 31, 
1998.
---------------------------------------------------------------------------

2. Taiwan

    As part of its investigation, the Committee found that it 
had numerous witnesses to interview in Taiwan. In January 1998, 
it approached the representative of Taiwan in the United 
States, the Taipei Economic and Cultural Representative's 
Office \143\ (``TECRO'') about a staff delegation visit to 
Taiwan. Although TECRO represented that it would assist the 
Committee, it subsequently decided that the Ministry of Foreign 
Affairs in Taiwan would not facilitate any meetings in Taiwan. 
After extensive discussions with the Committee, TECRO agreed to 
assist the Committee conditioned upon certain ``ground rules'' 
that the delegation would follow.\144\ The Committee agreed to 
the ground rules and arrived in Taiwan on March 10, 1998.
---------------------------------------------------------------------------
    \143\ Taiwan does not have an embassy in the United States, as 
such, TECRO performs many of the functions of an embassy.
    \144\ The ground rules included in pertinent part: the Committee 
would conduct no ``investigations'' in Taiwan; private meetings would 
be referred to as ``exchanges of opinions on issues of mutual concern 
arising out of mutual interest in combating illegal activities''; all 
itineraries shall be transparent; meeting with government officials 
would be arranged by MOFA and meetings with private individuals would 
be arranged by the American Institute in Taiwan [AIT]; and, no 
subpoenas, signing documents, audio or video recording, photographing; 
MOFA reserved the right to attend all meetings. Letter from Stephen 
Chen, TECRO Representative, to Chairman Dan Burton, Feb. 12, 1998.
---------------------------------------------------------------------------
    A key element of the ground rules was the Committee's 
agreement that the American Institute in Taiwan \145\ (``AIT'') 
would coordinate the delegation's activities working closely 
with the Republic of Taiwan's Ministry of Foreign Affairs 
(``MOFA''). Before the delegation's arrival, the Committee had 
requested interviews with approximately 45 individuals living 
in Taiwan. Upon the arrival of the delegation, AIT had 
scheduled numerous interviews. However, although MOFA agreed to 
arrange all requested meetings with government or political 
party officials, it had not done so. The delegation raised the 
matter with MOFA officials its first working day. MOFA claimed 
that it had been unable to secure any meetings with its own 
government officials. At that point, the delegation obtained 
permission for AIT to approach Taiwanese government and party 
officials on its behalf. By March 13th, AIT was able to secure 
a number of additional meetings for the staff delegation.
---------------------------------------------------------------------------
    \145\ The United States does not have an embassy in Taiwan. AIT is 
a quasi-governmental entity which performs many of the functions of an 
embassy.
---------------------------------------------------------------------------
    The following morning, Saturday, March 14th, MOFA asserted 
that there had been a number of ``press leaks'' which made it 
necessary to hold a press conference for what it termed as 
``damage control.'' However, MOFA did not notify AIT or the 
delegation of the planned press event. The press conference, 
which disclosed the names of many potential interviewees, 
resulted in an outcry from the opposition party and an uproar 
in the legislature. At that point, the delegation's mission had 
been seriously compromised.
    Unknown to the Committee, MOFA had written to all 
prospective interviewees prior to the delegation's arrival 
telling them, among other things, that they were under no 
obligation to cooperate with the delegation and identifying a 
number of others with whom meetings were sought. In addition, 
at MOFA's request, AIT had provided MOFA with daily updates on 
the delegation's meeting schedule. Shortly after receiving the 
updates, the scheduled interviews would be canceled. The 
Committee could only conclude that MOFA contacted the 
interviewees to discourage meetings. Efforts by AIT to 
reschedule the meetings were unsuccessful.
    [Supporting documentation follows:]





=======================================================================


                              CHAPTER III

    THE DEMOCRATS' FAILURE TO RETURN ILLEGAL CAMPAIGN CONTRIBUTIONS

=======================================================================


    THE DEMOCRATS' FAILURE TO RETURN ILLEGAL CAMPAIGN CONTRIBUTIONS

       I. The Democratic National Committee's Contribution Review

    On November 26, 1996, the DNC announced that it had 
retained the law firm of Debevoise & Plimpton \1\ to ``advise 
it in connection with questions that had arisen about a number 
of contributions to the DNC.'' \2\ Just before the DNC 
announced its hiring of Debevoise & Plimpton, the Washington 
Post reported that ``for now, the DNC is relying on news 
organizations to all but prove that the donations are not 
legitimate before it returns them.'' \3\ In a deposition before 
the Committee, DNC General Counsel Joseph E. Sandler, Esq. 
summarized the factors--particularly heavy press scrutiny--
leading to the contribution review:
---------------------------------------------------------------------------
    \1\ Serge F. Kovaleski, ``Democrats Open Investigation Into 
Questionable Donations; Specific Queries Won't Be Answered Pending 
Completion,'' the Washington Post, Nov. 27, 1996, at A6.
    \2\ DNC Summary of In-Depth Contribution Review, at 1 (Exhibit 1).
    \3\ Ira Chinoy and Lena H. Sun, ``Unwary DNC Accepted Donations at 
Face Value,'' the Washington Post, Nov. 22, 1996, at A1.

          Counsel. . . . Can you tell me what led up to this 
        in-depth contribution review involving Debevoise & 
        Plimpton . . . ?
          Sandler. Yes. There were many, many questions being 
        raised in the press in October and November of 1996 
        about contributions that had been made by the DNC 
        during 1994, 1995, and 1996. And rather than try to 
        investigate these one at a time, we determined that it 
        would be best if we did a systematic review of these--
        of contributions made during this period to determine 
        which--you know, if there were, to the extent there 
        were contributions that we accepted that should now be 
        refunded.\4\
---------------------------------------------------------------------------
    \4\ Committee Deposition of Joseph E. Sandler, Esq., May 14, 1998, 
27-28.

Specifically, Debevoise & Plimpton was hired to oversee a 
review of select contributions, represent the DNC in 
conjunction with the Department of Justice's (``DOJ'') campaign 
finance investigation, and assist with an improvement of the 
DNC's contribution screening procedures.\5\ According to DNC 
Chairman Fowler, Debevoise & Plimpton's duties were to include 
``preserving and producing relevant documents and preparing 
timely and complete responses to inquiries from applicable 
agencies.'' \6\ Chairman Fowler pledged that:
---------------------------------------------------------------------------
    \5\ ``DNC Hires Law Firm for Contribution Probe,'' Associated 
Press, Nov. 26, 1996.
    \6\ Id.

        We at the DNC are absolutely determined to correct any 
        mistakes that have been made and to ensure that they 
        are not repeated. . . . We will no longer go about this 
        in a piecemeal fashion but will deal with this 
        comprehensively and methodically.\7\
---------------------------------------------------------------------------
    \7\ Id.

The DNC stated that it would no longer answer questions about 
individual contributions until the review was completed.\8\ At 
the time the DNC hired Debevoise & Plimpton in November 1996, 
it had already returned $1,471,800 in contributions, $1,298,800 
of which was raised by DNC Vice Chairman John Huang.\9\ In 
addition, by this time a criminal investigation of Huang's 
fund-raising activities was underway at the Justice Department.
---------------------------------------------------------------------------
    \8\ Serge F. Kovaleski, ``Democrats Open Investigation Into 
Questionable Donations; Specific Queries Won't Be Answered Pending 
Completion,'' the Washington Post, Nov. 27, 1996, at A6.
    \9\ Exhibit 1 DNC Summary of In-Depth Contribution Review, at 4-5; 
see ``DNC Hires Law Firm for Contribution Probe,'' Associated Press, 
Nov. 26, 1996.
---------------------------------------------------------------------------
    In late November 1996, Debevoise & Plimpton hired the 
accounting firm Ernst & Young, L.L.P. to assist in the review 
of questionable contributions.\10\ Additionally, in early 
December 1996, Debevoise & Plimpton hired the Investigative 
Group International (``IGI''), a private investigative firm, to 
assist in the contribution review.\11\
---------------------------------------------------------------------------
    \10\ Id.; see also, Exhibit 1 DNC Summary of In-Depth Contribution 
Review, at 1.
    \11\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, Deposition of Terry F. Lenzner, 43-47, June 23, 
1997.
---------------------------------------------------------------------------
    The DNC's initial contribution review began in late 
November 1996--after the Presidential election--and continued 
through February 1997.\12\ Contributions falling into any one 
of the following seven categories--taken directly from DNC 
guidelines--were reviewed:
---------------------------------------------------------------------------
    \12\ The DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 7; see ``DNC Hires Law Firm for 
Contribution Probe,'' Associated Press, Nov. 26, 1996; see also, 
Exhibit 1 DNC Summary of In-Depth Contribution Review, at 1.
---------------------------------------------------------------------------
          1. Contributions from any contributor who contributed 
        $10,000 or more in any of the years 1994, 1995 or 1996.
          2. Contributions in 1996 for which 430 S. Capitol 
        Street (address of the DNC's headquarters) had been 
        listed as an address.
          3. Contributions solicited by Mr. John Huang where 
        the donor contributed a total of $2,500 or more in the 
        aggregate where the donor was not well known to the 
        DNC.
          4. Contributions made in connection with the April 
        29, 1996 event at the Hsi Lai Buddhist Temple in 
        California.
          5. Contributions made or solicited by Mr. Charles 
        Trie, his wife or his company, Daihatsu International.
          6. Contributions by Mr. Johnny Chung or his company, 
        Automated Intelligence Systems.
          7. Contributions above $5,000 made in connection with 
        any DNC fundraising event targeting the Asian Pacific 
        American community.\13\
---------------------------------------------------------------------------
    \13\ DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 7-8.
---------------------------------------------------------------------------
    Contributions falling into category 1 were reviewed in-
house by the DNC using standard public databases such as Nexis 
and Lexis to verify ``basic information'' \14\ such as 
corporate status, address, etc.\15\ Category 2 contributions 
were evidently also reviewed in-house by the DNC.\16\ In 
contrast, contributions falling into categories 3-7 were 
forwarded to Debevoise & Plimpton which reviewed them in 
conjunction with Ernst & Young.\17\ IGI was utilized to review 
a select group of contributions after Ernst & Young was unable 
to obtain sufficient information to determine the legality or 
appropriateness of the contribution.\18\
---------------------------------------------------------------------------
    \14\ Exhibit 1 DNC Summary of In-Depth Contribution Review, at 2.
    \15\ Id.
    \16\ Id. at 2-3.
    \17\ Id.
    \18\ See Id., at 3; see generally Investigation of Illegal or 
Improper Activities in Connection with the 1996 Federal Election 
Campaign Before the Senate Committee on Governmental Affairs, 
Deposition of Terry F. Lenzner, 43-47, June 23, 1997.
---------------------------------------------------------------------------
    The DNC's in-house contribution review consisted primarily 
of public database searches and attempts to contact 
contributors.\19\ In contrast, the review conducted by Ernst & 
Young under the auspices of Debevoise & Plimpton was 
considerably more extensive. Ernst & Young utilized 
professionals from four different areas: Financial Advisory 
Services-Dispute Resolution & Litigation Services, Financial 
Advisory Services-International Financial Services, the Chinese 
Business Group, and the Assurance and Advisory Business 
Services, as well as translators.\20\ As described in a DNC 
memorandum:
---------------------------------------------------------------------------
    \19\ See Exhibit 1 DNC Summary of In-Depth Contribution Review, at 
2-3.
    \20\ Letter from Daniel G. Lentz of Ernst & Young, L.L.P. to 
Debevoise & Plimpton, Feb. 26, 1997, app. 1, DNC 4298600-DNC 4298601 
(Exhibit 2).

        [Ernst & Young] prepared two questionnaires (one for 
        individuals and one for corporate donors) that it used 
        in telephone interviews. Individual donors were asked 
        to confirm the donor's citizenship, permanent residence 
        status, social security number, the source of the 
        donation and other relevant information. Corporate 
        donors were asked about any possible foreign ownership, 
        the source of the funds (from a domestic U.S. company 
        or from abroad) and other relevant information. 
        Searches of standard databases containing publicly 
        available information were also conducted to verify 
        additional information about the donor. Where the donor 
        requested it, [Ernst & Young] sent a written 
        questionnaire. . . . Where [Ernst & Young] was not able 
        to contact the donor or to obtain sufficient 
        information, further research was conducted under the 
        supervision of Debevoise & Plimpton.\21\
---------------------------------------------------------------------------
    \21\ Exhibit 1 DNC Summary of In-Depth Contribution Review, at 2.

The Ernst & Young auditors kept detailed notes of contacts and 
attempted contacts with contributors and ``other significant 
information obtained'' \22\ in conjunction with telephone 
interviews.\23\ The research work performed by Ernst & Young 
and the Investigative Group International produced an 
impressive amount of concrete information upon which the DNC 
could base its decisions.
---------------------------------------------------------------------------
    \22\ Exhibit 2 Letter from Daniel G. Lentz of Ernst & Young, L.L.P. 
to Debevoise & Plimpton, Feb. 26, 1997, DNC 4298595.
    \23\ Id.
---------------------------------------------------------------------------
    Based on the result of the Ernst & Young interviews, 
contributors' files were categorized as:
          1. Dead End Research (``DER'') if no contact with the 
        contributor was made.\24\ In this case, Alternative 
        Procedures were employed consisting of mailing an 
        interview short form to the contributor via mail to the 
        ``best available address;'' \25\
---------------------------------------------------------------------------
    \24\ Id. at 3, DNC 4298597.
    \25\ Id. at 4, DNC 4298598.
---------------------------------------------------------------------------
          2. Terminated if the contact information was 
        confirmed as ``good'' \26\ but contact with the 
        contributor could not be made after ``reasonable 
        efforts.'' \27\ In this case, Alternative Procedures 
        were employed consisting of mailing an interview short 
        form to the contributor via mail to the ``best 
        available address;'' \28\
---------------------------------------------------------------------------
    \26\ Id. at 3, DNC 4298597.
    \27\ Id.
    \28\ Id. at 4, DNC 4298598.
---------------------------------------------------------------------------
          3. Survey Unsuccessful if the interview had been 
        initiated with the actual contributor . . . but had 
        been terminated by the contributor after either none or 
        a portion of the interview had been completed.'' \29\ 
        In this case, Alternative Procedures were employed 
        consisting of mailing an interview short form to the 
        contributor via mail to the ``best available address;'' 
        \30\
---------------------------------------------------------------------------
    \29\ Id. at 3, DNC 4298597.
    \30\ Id. at 4, DNC 4298598.
---------------------------------------------------------------------------
          4. Substantially Completed ``where the Interviewer 
        obtained as much information as possible from the 
        Contributor on the majority of the questions asked;'' 
        \31\ and
---------------------------------------------------------------------------
    \31\ Id. at 3, DNC 4298597.
---------------------------------------------------------------------------
          5. Completed if ``all steps through the completion of 
        the interview have been performed.'' \32\
---------------------------------------------------------------------------
    \32\ Id.
---------------------------------------------------------------------------
In certain circumstances, what the DNC termed ``Additional 
Procedures'' were used, such as obtaining a credit report when 
a contributor signed and returned an authorization form.\33\
---------------------------------------------------------------------------
    \33\ Id. at 4, DNC 4298598.
---------------------------------------------------------------------------
    The DNC pledged to return any contribution that: (1) may 
not satisfy applicable legal and regulatory requirements, (2) 
may be inappropriate for the DNC to accept under the 
circumstances as the DNC understands them, or (3) for which the 
DNC has been unable to obtain sufficient information to verify 
its legality or appropriateness.\34\ In short, the DNC pledged 
to return contributions in instances of illegality, 
inappropriateness, or insufficient information.
---------------------------------------------------------------------------
    \34\ Exhibit 1 DNC Summary of In-Depth Contribution Review, at 1; 
statement of Judah Best, Debevoise & Plimpton, DNC press conference, 
Feb. 28, 1997, at 1-2 (Exhibit 3).
---------------------------------------------------------------------------
    Pursuant to category 1, if the DNC--in conjunction with 
Ernst & Young--determined that a contribution was made in 
violation of the Federal Election Campaign Act of 1971, as 
Amended (``the Act''), it was to be deemed illegal and returned 
to the contributor or disgorged to the U.S. Treasury.\35\ For 
example, DNC records indicate that contributions made by 
foreign nationals in violation of 2 U.S.C. Sec. 441e(a) of the 
Act \36\ were returned to the donor,\37\ while contributions 
made in the name of another in violation of 2 U.S.C. Sec. 441f 
\38\ were returned to the U.S. Treasury \39\ as explained by 
the DNC:
---------------------------------------------------------------------------
    \35\ FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-39; 
see generally Exhibit 4 Letter from Joseph E. Sandler, Esq., to 
Lawrence Noble, Esq., June 27, 1997, DNC 4298856-DNC 4298857 (citing 
FEC Advisory Opinion 1995-19 and FEC Advisory Opinion 1991-39) 
(enclosures omitted) (Exhibit 4); see also Letter from Joseph E. 
Sandler, Esq., to Lawrence Noble, Esq., Mar. 25, 1998 (Exhibit 5); see 
Letter from Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998 
(enclosures omitted) (Exhibit 6); DNC List of Contributions Returned or 
Disgorged Produced to the Committee on Nov. 20, 1997, at 1-9 (Exhibit 
7).
    \36\ 2 U.S.C. Sec. 441e(a) provides that:

        It shall be unlawful for a foreign national directly or 
      through any other person to make any contribution of money 
      or other thing of value, or to promise expressly or 
      impliedly to make any such contribution, in connection with 
      an election to any political office or in connection with 
      any primary election, convention, or caucus held to select 
      candidates for any political office; or for any person to 
      solicit, accept, or receive any such contribution from a 
      foreign national.
---------------------------------------------------------------------------
    \37\ See generally Exhibit 7 DNC List of Contributions Returned or 
Disgorged Produced to the Committee on Nov. 20, 1997, at 1-9.
    \38\ 2 U.S.C. Sec. 441f provides that:

        No person shall make a contribution in the name of 
      another person or knowingly permit his name to be used to 
      effect such a contribution, and no person shall knowingly 
      accept a contribution made by one person in the name of 
      another person.
---------------------------------------------------------------------------
    \39\ See generally Exhibit 7 DNC List of Contributions Returned or 
Disgorged Produced to the Committee on Nov. 20, 1997, at 1-9; FEC 
Advisory Opinion 1995-19; FEC Advisory Opinion 1991-39; Exhibit 4 
Letter from Joseph E. Sandler, Esq., to Lawrence Noble, Esq., June 27, 
1997 (citing FEC Advisory Opinion 1995-19 and FEC Advisory Opinion 
1991-39); Exhibit 5 Letter from Joseph E. Sandler, Esq., to Lawrence 
Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from Judah Best, Esq., to 
James C. Wilson, Esq., Apr. 15, 1998.

        In accordance with F[ederal] E[lection] C[ommission] 
        guidelines, in those cases in which a donor 
        specifically indicated that he or she did not make the 
        contribution, but the real source of the contribution 
        is not known to the DNC, the contribution has been 
        refunded to the U.S. Treasury.\40\
---------------------------------------------------------------------------
    \40\ DNC press release, ``DNC Refunds Contributions,'' June 27, 
1997, at 2 (Exhibit 8).

For example, foreign national Gilberto Pagan's contribution was 
returned to him while conduit contributions made in 
coordination with Maria Hsia and the International Buddhist 
Progress Society were disgorged to the U.S. Treasury.\41\ This 
policy is consistent with Federal regulations.\42\
---------------------------------------------------------------------------
    \41\ Exhibit 7 DNC List of Contributions Returned or Disgorged 
Produced to the Committee on Nov. 20, 1997, at 6 and 8.
    \42\ See 11 CFR Sec. 103.3(b) (1) and (2).
---------------------------------------------------------------------------
    If a contribution was determined illegal, the DNC generally 
did not reach the issue of appropriateness. But, pursuant to 
category 2, a contribution could have been deemed inappropriate 
notwithstanding the fact that it was legal. In a Committee 
deposition, DNC General Counsel Sandler explained the 
distinction between legality and appropriateness:

          Sandler. Legality goes to the question of whether it 
        is lawful under the Federal Election Campaign Act, 
        under the rules of the Federal Election Commission, for 
        the DNC to accept a contribution. And appropriateness 
        goes to the question of whether a contribution that is 
        legal to accept is nonetheless inappropriate because of 
        the circumstances, background situation, or other 
        factors relating to the particular contributor.
          Counsel. Is it fair to say that the appropriateness 
        standard is fuzzier than the legal standard?
          Sandler. [The a]ppropriateness standard definitely 
        involves matters of judgment on a case-by-case 
        basis.\43\
---------------------------------------------------------------------------
    \43\ Committee Deposition of Joseph E. Sandler, Esq., May 14, 1998, 
6-7.

Whether a contribution was appropriate was an entirely 
subjective ad hoc determination.\44\ Current DNC guidelines 
regarding compliance with campaign finance laws provide 
examples of contributions that may be deemed inappropriate 
including those made by individuals:
---------------------------------------------------------------------------
    \44\ Id. at 7.
---------------------------------------------------------------------------
          1. Convict[ed] of a felony of any nature or of a 
        misdemeanor involving fraud or moral turpitude, or 
        civil judgment or finding involving fraud perpetrated 
        against the government;
          2. [Under a] [p]ending active investigation for 
        criminal misconduct involving fraud or moral turpitude, 
        or civil fraud involving the government;
          3. Convict[ed] for or [under an] active pending 
        criminal investigation into alleged misconduct 
        involving dealing with the government or elected 
        officials, or campaign finance violations;
          4. [Involved in an] [u]nresolved bankruptcy 
        proceeding; and/or
          5. [Who has] [s]ubstantial unsatisfied tax liability 
        or other obligations to the government not being 
        actively contested in good faith.\45\
---------------------------------------------------------------------------
    \45\ Policies and Procedures of the DNC Regarding Compliance with 
Campaign Finance Laws, at 18-19 (Exhibit 9).
---------------------------------------------------------------------------
When a ``substantial question'' regarding the ``appropriateness 
of [a] contribution'' was raised, ``a committee (consisting of 
the DNC's Executive Director, General Counsel, Press 
Spokesperson, Compliance Director, and Research Director) made 
the final determination of whether to return it.'' \46\ DNC 
records indicate that contributions deemed inappropriate were 
returned to the contributor or the contributor's counsel.\47\
---------------------------------------------------------------------------
    \46\ Exhibit 1 DNC Summary of In-Depth Contribution Review, at 3.
    \47\ Exhibit 7 DNC List of Contributions Returned or Disgorged 
Produced to the Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------
    The DNC has returned at least 70 contributions that it 
``deemed inappropriate,'' \48\ most notably the contributions 
of Praitun Kanchanalak (attributed to her daughter-in-law 
Pauline Kanchanalak),\49\ Arief and Soraya Wiriadinata \50\ 
(the son-in-law and daughter of Lippo Group co-founder Hashim 
Ning),\51\ Yah Lin ``Charlie'' and Wang Mei Trie,\52\ Daihatsu 
International Trading, Inc.\53\ (a company controlled by Yah 
Lin ``Charlie'' Trie) \54\ and the Cheyenne Arapaho Tribes.\55\ 
The precise reason why these contributions were ``deemed 
inappropriate'' is unclear. However, at the time they were 
returned, the common thread connecting these contributors was 
intense press scrutiny.\56\
---------------------------------------------------------------------------
    \48\ Id.
    \49\ Id. at 2.
    \50\ Id. at 2-3.
    \51\ Notes of DNC General Counsel Joseph E. Sandler, Esq., DNC 
0829497-DNC 0829535, at 12 (Exhibit 10); see also Glenn R. Simpson and 
Jill Abramson, ``Legal Loopholes Let Overseas Contributors Fill 
Democrats' Coffers--Asian Interests Are Providing Huge Campaign Gifts, 
Gaining Political Clout--A Bust of President Clinton,'' Wall Street 
Journal, Oct. 8, 1996; see generally Committee Deposition of Charles 
DeQueljoe, June 9, 1998, 136-137.
    \52\ Exhibit 7 DNC List of Contributions Returned or Disgorged 
Produced to the Committee on Nov. 20, 1997, at 7.
    \53\ Id. at 5.
    \54\ Daihatsu International Trading, Inc. Business Card of 
President Yah Lin Trie (Exhibit 11).
    \55\ Exhibit 7 DNC List of Contributions Returned or Disgorged 
Produced to the Committee on Nov. 20, 1997, at 4.
    \56\ See, e.g. P. Kanchanalak (her contributions were returned in 
the wake of numerous articles questioning their legality); Arief and 
Soraya Wiriadinata (their contributions were returned in the wake of 
numerous articles questioning their legality); Cheyenne Arapaho Tribes 
(Their contributions were returned on Mar. 13, 1997, in the wake of the 
Washington Post articles, Susan Schmidt, ``Tribes Disappointed After 
Gifts to DNC; Land-Seeking Indians Who Gave Cite Pressure to Hire 
Consultants, Donate More,'' the Washington Post, Mar. 10, 1997, at 
A1.).
---------------------------------------------------------------------------
    Pursuant to category 3, whether insufficient information 
was obtained pursuant to the contribution review was generally 
a subjective determination, however, the DNC established some 
objective criteria to assist with that determination:

        In general, for an individual who had not been 
        interviewed, the minimum test was a social security 
        number, the length of time since it had been issued 
        (which would be indicative of whether the person was a 
        citizen or permanent resident), his or her ownership or 
        possession of a residence or other property and other 
        information that he or she had the wherewithal to make 
        the contribution in question.\57\
---------------------------------------------------------------------------
    \57\ Exhibit 1 DNC Summary of In-Depth Contribution Review, at 3.

---------------------------------------------------------------------------
    In the case of corporations:

        [T]he minimum generally consisted of a confirmation of 
        the company's corporate existence and standing, its 
        revenue from U.S. operations, whether the individuals 
        who participated in the decision to make the 
        contributions possessed social security numbers and for 
        how long, or other information establishing their 
        status as U.S. citizens or permanent residents.\58\
---------------------------------------------------------------------------
    \58\ Id.

According to the DNC's attorney, Judah Best, Esq. of Debevoise 
& Plimpton, sufficient information was information upon which 
the DNC could make an ``informed determination'' \59\ as to the 
legality or appropriateness of a contribution.\60\ In the 
absence of sufficient information, the DNC--pursuant to its own 
policy--was required to return the contribution.\61\ The 
critical test was whether the source of funds used to make the 
contribution was verifiable.\62\
---------------------------------------------------------------------------
    \59\ Exhibit 3 Statement of Judah Best, Debevoise & Plimpton, DNC 
press conference, Feb. 28, 1997, at 4.
    \60\ See generally Exhibit 1 DNC Summary of In-Depth Contribution 
Review, at 1.
    \61\ Id.
    \62\ John King, ``Chairman Acknowledges More Money Will Be 
Returned, Urges Reform,'' Associated Press, Feb. 21, 1997.
---------------------------------------------------------------------------
    The ``insufficient information'' category is particularly 
important because the DNC sometimes faced resistance from 
contributors in response to its contribution review.\63\ 
Moreover, federal authorities have been thwarted in obtaining 
information from contributors regarding their contributions. 
Even requests for basic information such as a contributor's 
address were sometimes refused.\64\ At least 120 individuals 
have fled the country and/or refused to cooperate with 
investigators in the course of the House, Senate and DOJ 
campaign finance investigations.\65\ Of these, at least 79 
individuals have invoked their Fifth Amendment privilege 
against self-incrimination.\66\ As a result, an inability to 
obtain sufficient information is more often the rule rather 
than the exception.
---------------------------------------------------------------------------
    \63\ See, e.g., Discussion of J & M International, Inc., infra.
    \64\ See, e.g., Ernst & Young Contribution Review Materials for 
Helen Chien, DNC 1805309, DNC 1805313, DNC 1805315-DNC 1805316, DNC 
1805321, DNC 1805326-DNC 1805327, DNC 1805329-DNC 1805331, DNC 1805333-
DNC 1805336, at 4 (Exhibit 12).
    \65\ ``Witnesses Who Have Fled or Plead the 5th,'' http://
www.house.gov/reform/oversight/finance/fled.htm, Committee on 
Government Reform and Oversight, U.S. House of Representatives; see 
also Nathan Abse, ``Campaign Finance Probe: 94 Who Aren't Talking,'' 
Washington Post, June 9, 1998, at A13; ``10 New Witnesses Take the 
Fifth, Total Now at 104, Government Reform and Oversight Investigators 
Move Forward in Foreign Money Probe Despite Stonewalling by Crucial 
Witnesses,'' Committee press release, June 23, 1998.
    \66\ Id.
---------------------------------------------------------------------------
    The DNC reviewed the information gathered by Debevoise & 
Plimpton in conjunction with Ernst & Young and IGI and then 
made the final decision as to which contributions to retain, 
return, or disgorge.\67\ According to the DNC, ``the final 
decision on which contributions should be returned was solely 
that of the DNC.'' \68\ Although ``Debevoise & Plimpton made 
recommendations with respect to the disposition of 
contributions, . . . in no instance did the DNC take any action 
inconsistent with counsel's recommendations.'' \69\
---------------------------------------------------------------------------
    \67\ See generally Exhibit 1 DNC Summary of In-Depth Contribution 
Review, at 1.
    \68\ Id. (emphasis added).
    \69\ Id.
---------------------------------------------------------------------------
    In addition to the $1,471,800 returned or disgorged in late 
1996 prior to the contribution review,\70\ on February 28, 
1997, the DNC announced its intention to disgorge or return an 
additional $1,492,051 as a result of its contribution 
review.\71\ DNC Chairman Roy Romer concluded: ``[i]t is clear 
that we did not monitor the contribution process adequately 
enough in the recent past. The DNC made mistakes. Today's 
actions correct those mistakes. . . .'' \72\
---------------------------------------------------------------------------
    \70\ Id. at 4.
    \71\ Id.
    \72\ ``DNC Chairs Romer and Grossman Announce New Compliance 
Procedures and Results of DNC Internal Review,'' DNC press release, 
Feb. 28, 1997, at 2 (Exhibit 13).
---------------------------------------------------------------------------
    During the period March 13, 1997, through June 26, 1997, 
the DNC returned an additional $123,092, including $107,672 to 
the Cheyenne Arapaho Tribes.\73\ On June 27, 1997, the DNC 
returned or disgorged $1,353,800--the DNC announced its 
intention to return $1,348,200 of this $1,353,800 on February 
28, 1997, as discussed below--based on its continuing review of 
contributions.\74\ According to a DNC press release, the June 
27, 1997, disbursements brought the total contributions 
returned or disgorged to $2,825,600.\75\ However, Committee 
calculations based on records provided by the DNC indicate that 
the DNC returned at least $1,943,024 prior to June 27, 1997, 
and $3,296,824 through June 27, 1997.\76\
---------------------------------------------------------------------------
    \73\ Exhibit 1 DNC Summary of In-Depth Contribution Review, at 4.
    \74\ Exhibit 8 DNC press release, ``DNC Refunds Contributions,'' 
June 27, 1997, at 1.
    \75\ Id. at 1.
    \76\ Exhibit 7 DNC List of Contributions Returned or Disgorged 
Produced to the Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------
    Of the $1,492,051 the DNC identified as improper or illegal 
on February 28, 1997, at least $1,348,200 was not returned 
until June 27, 1997, 4 months later, in violation of Federal 
regulations.\77\ A political committee cannot return or 
disgorge prohibited contributions on its own timetable.\78\ 
Federal Election Commission (``FEC'') regulations provide in 
pertinent part that:
---------------------------------------------------------------------------
    \77\ Cf. Sharon LaFraniere and Lena H. Sun ``DNC Returns Another 
$1.5 Million; Refunds to Include Donations from Foreigners and a 
Deceased Woman,'' the Washington Post, Mar. 1, 1997, at A1; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
    \78\ See 11 C.F.R. Sec. 103.3(b)(1)-3.

        If a treasurer [of a political committee] discovers 
        that a previously deposited contribution came from a 
        prohibited source, he or she must refund the 
        contribution within 30 days of making the discovery. 
        This situation might arise, for example, if the 
        treasurer learned that a past contribution was made by 
        a foreign national. . . . If the committee does not 
        have sufficient funds to refund the contribution when 
        the illegality is discovered, the treasurer must use 
        the next funds the committee receives.\79\
---------------------------------------------------------------------------
    \79\ FEC Campaign Guide for Political Party Committees, Aug. 1996, 
at 21 (citing 11 C.F.R. Sec. 103.3(b)(2) (emphasis added) (italics in 
original)).

Despite the air of contrition and self-reformation on display 
at the February 1997, press conference, according to then-DNC 
spokeswomen Amy Weiss Tobe, the DNC had no intention of 
immediately returning the contributions at the time the 
---------------------------------------------------------------------------
announcement was made:

        The lights are on and [our employees] are still getting 
        paychecks. . . .  As we can give back donations, we 
        will. . . . \80\ We hope to do it within the next 
        several months. . . . We've decided the right thing to 
        do is to raise the money and return it when we can.\81\
---------------------------------------------------------------------------
    \80\ Glenn F. Bunting and Ralph Frammolino, ``Democratic Party 
Lacks Funds to Repay Donors Finances: DNC Keeps Finding Contributions 
It Must Return Even As It Runs Up at Least $10 Million in Debt,'' Los 
Angeles Times, Mar. 2, 1997, at A1.
    \81\ Connie Cass, ``Cash-Strapped Democrats Haven't Returned 
Tainted Checks Yet,'' Associated Press, Mar. 12, 1997.

To the Committee's knowledge, the FEC has taken no action 
regarding the DNC's failure to return or disgorge prohibited 
contributions in a timely manner.
    From June 28, 1997, through October 30, 1997, the DNC 
returned or disgorged an additional $286,300,\82\ including two 
illegal contributions from Manlin Foung, Yah Lin ``Charlie'' 
Trie's sister, totaling $22,500 \83\ and a $100,000 
contribution from Global Resource Management, Inc. of Dublin, 
Ohio, due to concerns that it may have originated with a 
foreign source.\84\
---------------------------------------------------------------------------
    \82\ This figure does not include $1,900 returned pursuant to the 
DNC's self-imposed $100,000 contribution limit. See Exhibit 7 DNC List 
of Contributions Returned or Disgorged Produced to the Committee on 
Nov. 20, 1997, at 8-9; Letter from Judah Best, Esq., to Richard D. 
Bennett, Esq., Mar. 13, 1998 (confirming the DNC's return of Global 
Resources Management, Inc.'s $100,000 contribution) (Exhibit 14).
    \83\ Letter from Joseph E. Sandler, Esq., to Lawrence M. Noble, 
Esq., Oct. 20, 1997 (enclosures omitted) (disgorging Manlin Foung's 
contributions to the DNC totaling $22,500) (Exhibit 15).
    \84\ Exhibit 14 Letter from Judah Best, Esq., to Richard D. 
Bennett, Esq., Mar. 13, 1998 (confirming the DNC's return of Global 
Resources Management, Inc.'s $100,000 contribution); Karen Gullo, 
``Democratic Party Returns $100,000 Donation from Ohio Firm,'' 
Associated Press, Oct. 29, 1997.
---------------------------------------------------------------------------
    In a letter to the FEC dated March 25, 1998, the DNC 
disgorged an additional $78,200 to the U.S. Treasury in the 
wake of the Federal grand jury indictments of Yah Lin 
``Charlie'' Trie and Maria Hsia.\85\ The DNC indicated that `` 
.  .  . certain contributions that, at the time they were 
received, did not appear to be unlawful, were in fact 
contributions made in the name of another.'' \86\ Contributions 
returned included those of David Wang and Daniel Wu,\87\ both 
of whom made conduit contributions at the request of Antonio 
Y.P. Pan, \88\ an ex-Lippo executive \89\ and business 
associate of Trie.\90\
---------------------------------------------------------------------------
    \85\ Exhibit 5 Letter from Joseph E. Sandler, Esq., to Lawrence 
Noble, Esq., Mar. 25, 1998; see also Federal Grand Jury Indictment of 
Yah Lin ``Charlie'' Trie, U.S. District Court for the District of 
Columbia, Jan. 28, 1998; Federal Grand Jury Indictment of Maria Hsia, 
U.S. District Court for the District of Columbia, Feb. 28, 1998.
    \86\ Id.
    \87\ Id.
    \88\ Conduit Payments to the Democratic National Committee Before 
the House Committee on Government Reform and Oversight, 105th Cong., 
1st sess., 252-259 (1997) (Testimony of David Wang, Oct. 9, 1997).
    \89\ Tati Group (a company controlled by the Lippo Group) Business 
Card of Antonio Pan (Exhibit 16).
    \90\ Daihatsu International Trading, Inc. Business Card of Chief 
Executive Officer Antonio Pan (Exhibit 17).
---------------------------------------------------------------------------
    On July 24, 1998, after the federal grand jury indictments 
of Pauline Kanchanalak and Duangnet ``Georgie'' Kronenberg, the 
DNC returned $105,000 of Kronenberg's $114,000 in 
contributions.\91\ This brings the total of returned or 
disgorged contributions to at least $3,766,324.
---------------------------------------------------------------------------
    \91\ Letter from Joseph E. Sandler, Esq., to Lawrence M. Noble, 
Esq., July 24, 1998 (Exhibit 18); see also Amy Keller, ``Burton Eyes 
Unreturned DNC Cash,'' Roll Call, July 20, 1998; cf. Federal Grand Jury 
Indictment of Pauline Kanchanalak and Duangnet Kronenberg, U.S. 
District Court for the District of Columbia, July 13, 1998.
---------------------------------------------------------------------------
    Although the DNC's contribution review ignored the 1992 
election cycle,\92\ the review--conducted by Debevoise & 
Plimpton, Ernst & Young and IGI at the direction of the DNC--
gathered or attempted to gather relevant information to assist 
the DNC in determining whether to return a particular 
contribution. At a minimum, the DNC's review resulted in a much 
needed revamping of the DNC's compliance and fundraising 
guidelines. \93\
---------------------------------------------------------------------------
    \92\ See Committee Deposition of Joseph E. Sandler, Esq., May 14, 
1998, 27-28.
    \93\ Exhibit 13 ``DNC Chairs Romer and Grossman Announce New 
Compliance Procedures and Results of DNC Internal Review,'' DNC press 
release, Feb. 28, 1997, at 2.
---------------------------------------------------------------------------
    The efficacy of the DNC's review notwithstanding, the DNC 
has failed to abide by its self-imposed and publicly professed 
guidelines regarding the return of contributions. This failure 
is disturbing and raises serious questions regarding the 
sincerity of the DNC's desire to police itself. Particularly 
troubling is the fact that the DNC in many instances--detailed 
below--has given itself the benefit of the doubt regarding the 
legality or appropriateness of a contribution without 
justification. It must be remembered that the DNC did not 
embark on the contribution review as a self-initiated act of 
reformation. The context is critical: the review was initiated 
only after hundreds (if not thousands) of press articles 
closely scrutinizing the Democrats fund-raising excesses.
    For example, as a matter of DNC practice, the fact that a 
contributor has invoked his or her Fifth Amendment privilege 
against self-incrimination to the House, Senate or the DOJ has 
absolutely no bearing on whether the DNC retains or disgorges a 
contribution,\94\ notwithstanding the fact that--as a matter of 
common sense--an individual's invocation of the Fifth Amendment 
regarding a contribution at a minimum casts doubt on the 
legality of that contribution.\95\
---------------------------------------------------------------------------
    \94\ See, e.g., John Huang, Jane Huang, Duangnet Kronenberg, David 
Wang, and Bie Chuan Ong.
    \95\ Duangnet Kronenberg, David Wang, and Bid Chuan Ong--just to 
name a few--invoked their fifth amendment privilege against self-
incrimination to the Committee, but that invocation did not result in 
the return of their contributions by the DNC in response to the 
invocation. All of their contributions were illegal.
---------------------------------------------------------------------------
    On several occasions, when the DNC could not obtain 
sufficient information to confirm the legality or 
appropriateness of a contribution, the contribution was 
retained. Initially, the DNC represented that it was placing 
the burden on itself to demonstrate why a contribution should 
be retained, but in actuality, the DNC has repeatedly shifted 
the burden to the press and congressional investigators to 
demonstrate why a contribution should be returned.

 II. Illegal and Suspect Contributions Retained or Belatedly Disgorged 
   by the Democratic National Committee and State Democratic Parties

    The following enumerates and discusses contributions 
retained or belatedly disgorged by the DNC, Democratic 
Senatorial Campaign Committee (``DSCC''), Democratic 
Congressional Campaign Committee (``DCCC'') and state 
Democratic parties. Almost all of the contributions at issue 
are presently in the coffers of the original recipients. 
However, a few of the contributions discussed in this report 
were belatedly disgorged to the U.S. Treasury long after 
publicly available information should have put the recipient on 
notice of the contribution's questionable origins.
    Contributions to Republican causes are notably absent from 
the following discussion for good reason. While it is safe to 
assume that mistakes are made during every election cycle by 
both the Democratic and Republican parties, it is no fluke that 
the Republican party has returned only $150,000 in contrast to 
the approximately $3,766,324 returned by the Democratic party. 
These Republican foreign contributions were immediately 
returned by the RNC when identified, in contrast to the months 
and even years it has taken the DNC to return suspect 
contributions. There were no such foreign contributions in the 
1996 election cycle at the RNC.
    The fact is, after almost 2 years of investigating the 
foreign money scandal, it is clear that the problem of foreign 
money being funneled into elections was largely--
overwhelmingly--focused on the Democratic party. It is not only 
the committee which has focused on the foreign money in the 
Democratic party--the press and even the Justice Department 
task force has overwhelmingly focused on the illegal foreign 
money in the Democratic party. Attempts by defensive Democrats 
to shift attention from this fact ignore the simple truth that 
if you follow the foreign money trail, all roads lead 
overwhelmingly to Democratic coffers.
    What explains the vast disparity between the illegal money 
received by Republicans and Democrats? Some of the blame most 
certainly lies with the contribution vetting procedures--and 
lack thereof--employed by the DNC from mid-1994 through the 
1996 Presidential election. The failings of that system have 
been well documented in other forums.\96\ Perhaps more 
importantly, as evidenced by the DNC's own contribution review 
and the congressional campaign finance investigations, the 
overwhelming majority of all contributions determined illegal 
or inappropriate by the DNC can be tied--to varying degrees--to 
a handful of players who were welcomed by the DNC and the White 
House into their inner circle of fund-raisers and contributors 
including: Yah Lin ``Charlie'' Trie, Pauline Kanchanalak, Maria 
Hsia, Johnny Chien Chuen Chung and, most notably, James Riady 
and his protege, John Huang.
---------------------------------------------------------------------------
    \96\ See, e.g., Investigation of Illegal or Improper Activities in 
Connection with the 1996 Federal Election Campaign Before the Senate 
Committee on Governmental Affairs, S. Rept. No. 167, 195th Cong., 2d 
sess., vol. 1, 167-190 (1998).
---------------------------------------------------------------------------
    As discussed in the following excerpt of DNC General 
Counsel Joseph Sandler's deposition, John Huang was hired by 
the DNC at the direct request of President Clinton in response 
to James Riady's complaint that Huang was not being properly 
utilized at the Department of Commerce:

          Sandler. Mr. Huang told me that there was a meeting 
        in the fall of 1995 at the White House that was 
        attended by himself, Mr. James Riady, the President, 
        Bruce Lindsey, and C. Joseph Giroir; and that during 
        that meeting Mr. Riady made the point that Mr. Huang's 
        talents and abilities were not being well utilized in 
        his then current position at the Commerce Department 
        and he could be helpful in some other way. Mr. Huang 
        told me that someone suggested--and he wasn't sure if 
        it was himself or Riady or somebody else in the room--
        that Mr. Huang's capacity to help the administration 
        and re-election effort could be best used if he was 
        given a position at the DNC. And then I was told--well, 
        there were various reports of this, but I was told at 
        some point--I don't remember exactly by who [sic]--that 
        the President spoke to Mr. Rosen and suggested that Mr. 
        Huang be hired by the DNC. . . . Mr. Ickes advised [the 
        DNC] through White House counsel that his recollection 
        was that . . . that Mr. Lindsey spoke to Mr. Ickes 
        following this meeting, and that Mr. Ickes then spoke 
        to Mr. Rosen and Mr. Fowler about the hiring of Mr. 
        Huang. The recollection of others differs on that 
        score. . . .
          Sandler. . . . Mr. Fowler indicated to me . . . that 
        essentially Marvin Rosen and Richard Sullivan showed up 
        in his office with John Huang, and maybe having 
        previously mentioned it to him or talked to him, and 
        talked about the hiring of John Huang and the terms of 
        his employment position and so forth, and that the 
        Chairman [Fowler] agreed to hire him at that point. . . 
        .
          Counsel. All right. Did Mr. Huang tell you what else 
        was discussed at that particular meeting?
          Sandler. [Huang] indicated to me that the basic 
        purpose of the meeting was to visit, social in nature, 
        and that the main substantive point that he recalled 
        being discussed--he gave me the impression that the 
        point that Mr. Riady wanted to convey to the President 
        was what I've already testified to, that Mr. Huang's 
        abilities were being wasted at Commerce. In effect, he 
        said something to the effect that he was a pencil 
        pusher and that he should be utilized in some other 
        way.
          Counsel. Mr. Riady told the President that?
          Sandler. Yes.
          Counsel. All right. Did Mr. Riady initiate the 
        meeting? Was the meeting held at the behest of Mr. 
        Riady?
          Sandler. Yes.
          Counsel. I presume--the meeting was held at the White 
        House; correct?
          Sandler. Yes.
          Counsel. Was the discussion of Mr. Huang moving from 
        the Department of Commerce to the DNC the primary 
        purpose of the meeting?
          Sandler. Mr. Huang gave me the impression that, apart 
        from just a social chit-chat, visiting and so forth, 
        that that was the principal substantive discussion that 
        Mr. Riady wanted--had and wanted to have with the 
        President.\97\
---------------------------------------------------------------------------
    \97\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, 105th Cong., 1st sess., Deposition of Joseph E. 
Sandler, Esq., May 15, 1997, 16-17 and 21-23 (emphasis added).

Even his position and title were specifically created for him. 
---------------------------------------------------------------------------
DNC General Counsel Sandler testified of his concern:

          Sandler. There was a discussion. . . . John Huang had 
        requested business cards with the title, Vice Chair, 
        Finance, of the Democratic National Committee. Our 
        administrative person, . . . came to me, because this 
        was an unusual request, and said is this proper, is 
        this--you know, can we do this, and I raised a 
        question. . . . I had some concerns about whether it 
        was appropriate to give somebody a title for a position 
        that did not, in fact, exist, and I was concerned 
        because there are Vice Chairs of the Democratic 
        National Committee who are elected or who have official 
        positions under our Charter. . . . We also have a 
        National Finance Chair, and we also have Chairs of 
        various Donor Councils, and those are lay positions. I 
        was concerned about a staff person having this 
        position. . . . No staff person has such a title. . . .
          Sandler. And I also discussed it with Richard 
        Sullivan.
          Counsel. All right. And what was the substance of 
        those conversations?
          Sandler. My recollection is that I raised concerns, 
        you know, these concerns with Mr. Watson and with Mr. 
        Sullivan; that Mr. Sullivan indicated that this was 
        important that Mr. Huang have this title for his work 
        in the Asian-Pacific-American community; and, you know, 
        it was my feeling that it wasn't so--my concerns were 
        not of a legal nature or otherwise so compelling as to 
        insist that the cards not be printed with that title in 
        view of Mr. Sullivan's belief that it was important 
        that Mr. Huang have the business cards.
          Counsel. All right. So, having voiced your concern, 
        you ultimately acceded to the request of Mr. Sullivan--
        --
          Sandler. Yes.
          Counsel. . . . that . . . Mr. Huang be given that 
        title, correct?
          Sandler. Yes, or have business cards with that 
        title.\98\
---------------------------------------------------------------------------
    \98\ Id. at 93-95.

    John Huang began his employ at the DNC as Vice Chairman for 
Finance, on December 4, 1995.\99\
---------------------------------------------------------------------------
    \99\ DNC Personnel Change Authorization for John Huang, Dec. 4, 
1995, D 0000005 (Exhibit 19). When allegations of illegal fund-raising 
surfaced in Oct. 1996, regarding Huang, he fled Washington, DC. He 
later sought and received reimbursement from the DNC for his travel 
expenses during this period. In his DNC expense report covering Oct. 
11, 1996, through Oct. 15, 1996, Huang described the purpose of his 
travel as ``stayed away from D.C. return home for materials.'' See 
generally DNC Expense Report of John Huang, Oct. 20, 1996, 0000053 
(Exhibit 20); E Ticket Receipt and Itinerary, 0000054 (Exhibit 21).
---------------------------------------------------------------------------
    John Huang raised $3,422,850 during the 1996 election 
cycle.\100\ Prior to the launching of the DNC's contribution 
review in late November 1996, the DNC returned $1,298,800 in 
contributions raised by Huang\101\ and on February 28, 1997, 
announced the return of an additional $324,550 raised by 
Huang.\102\
---------------------------------------------------------------------------
    \100\ Exhibit 1 DNC Summary of In-Depth Contribution Review, at 5.
    \101\ Id.
    \102\ Id.; see generally DNC Note from DNC Chairman Donald Fowler 
to John Huang, July 4, 1996, DNC 0662886 (praising him for his fund-
raising work and encouraging him to do more) (Exhibit 22).
---------------------------------------------------------------------------
    Huang's fund-raising prowess was beyond question as early 
as 1993, 2 years before Huang began his employ at the DNC. 
Then-Lippo executive Huang attended the September 27, 1993, DNC 
reception/fund-raiser in Los Angeles and received high praise 
from Vice President Gore for his fund-raising:

        And to my friend John Huang and his wife Jane, thank 
        you for being a long time friend and ally. We go back a 
        long time. . . . We are long time friends, and John has 
        been a very faithful and meaningful, productive 
        supporter of the efforts being made by our party, and I 
        want to publicly thank you.\103\
---------------------------------------------------------------------------
    \103\ WHCA Audiotape of Karatz Residence/DNC Reception, Sept. 27, 
1993.

    President Clinton similarly praised Huang for his 
organization of the February 19, 1996, DNC fund-raiser held at 
---------------------------------------------------------------------------
the Hay Adams Hotel in Washington, DC:

        I am virtually overwhelmed by this event tonight. I 
        should have learned by now, I have known John Huang a 
        very long time. At least to be as young as we are, we 
        have known each other a long time. And when he told me 
        this event was going to unfold as it has tonight, I 
        wasn't quite sure I believed him, but he has never told 
        me anything that didn't come to pass, and all of you 
        have made it possible, and I want you to know I am very 
        grateful to you.\104\
---------------------------------------------------------------------------
    \104\ WHCA Videotape of Hay Adams Event, Feb. 19, 1996. It is 
unclear when the President had the conversation with John Huang 
referenced in the excerpt, but from the context of the President's 
statement it appears that Huang estimated the dollar amount to be 
raised at the Feb. 19, 1996, event. Huang was involved in the following 
Asian American fund-raisers: Feb. 19, 1996, President of the United 
States (``POTUS''), Washington, DC.; Apr. 29, 1996, Vice President of 
the United States (``VPOTUS''), Los Angeles, CA; May 13, 1996, POTUS, 
Washington, DC.; July 22, 1996, POTUS, Los Angeles; July 30, 1996, 
POTUS, Washington, DC.; Sept. 18, 1996, VPOTUS, San Francisco, CA; 
August 1996, POTUS, Washington, DC. See DNC Memorandum from Richard 
Sullivan to Chairman Fowler, Oct. 21, 1996 DNC 1227104 (Exhibit 23).

    Of the approximately $706,000 raised at this event, the DNC 
has already returned or disgorged at least $190,000, 27 percent 
of the total raised.\105\ This report enumerates an additional 
$152,500 raised in conjunction with the Hay Adams event that 
should be returned or disgorged by the DNC, bringing the total 
to at least 49 percent of the total raised.
---------------------------------------------------------------------------
    \105\ Exhibit 7 DNC List of Contributions Returned or Disgorged 
Produced to the Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------
    The willingness--perhaps eagerness--of the DNC and the 
President to employ and entrust John Huang as a key fund-raiser 
is of particular import. The behind the scenes machinations of 
Huang are not completely known at this point. However, one 
thing is clear: of all the individuals implicated in the fund-
raising scandal, John Huang's name surfaces more than any 
other. (The fact that the DOJ does not appear to have actively 
pursued Huang is equally troubling and is not altogether an 
unrelated issue.) \106\ In fact, the check tracking forms 
completed by Huang for each contribution raised by him provided 
Committee investigators with a blueprint for the campaign 
finance investigation.\107\ In sum, the Republican party has 
not suffered equally in the campaign finance scandal because it 
did not employ an equivalent of John Huang--the individual 
around which the current campaign finance scandal 
revolves\108\--with direct ties to the President's close friend 
James Riady and the President himself.
---------------------------------------------------------------------------
    \106\ See generally Roberto Suro, ``Prosecutors' Approach to Huang 
Signals Shift in Campaign Probe,'' the Washington Post, Oct. 2, 1998, 
at A17.
    \107\ See, e.g., DNC Check Tracking Form for the July 19, 1996, 
Contribution of Dae Hee Hong, 001034 (Exhibit 24); DNC Check Tracking 
Form for the Aug. 1, 1994, Contributions of Kenneth R. Wynn, DNC 
1276339 and DNC 1276340 (Exhibit 25).
    \108\ See generally Roberto Suro, ``Prosecutors' Approach to Huang 
Signals Shift in Campaign Probe,'' the Washington Post, Oct. 2, 1998, 
at A17 (``Following the 1996 election, however, the DNC returned $1.6 
million raised by Huang because it came from foreign nationals, who are 
ineligible to make campaign contributions, or because the origin of the 
money was cloudy. Since then, Huang has been at the center of 
allegations ranging from the relatively minor claim that the DNC failed 
to adequately screen donations to the still-unsubstantiated charges 
that the government of China attempted to influence the 1996 election 
by directing money to the Clinton campaign.'').
---------------------------------------------------------------------------
    Most of the individuals and entities referenced in the 
following discussion have previously been the subject of the 
DNC's contribution review or the campaign finance 
investigations of the DOJ. In some instances, the information 
referenced was obtained by Committee subpoena and was, of 
course, unavailable to the DNC--and other political 
committees--for its benefit during the contribution review. 
Committee interviews and depositions have also been referenced. 
This information is intended to assist political committees in 
their review of contributions. Some of the information provided 
was produced to the Committee by the DNC itself. Finally, much 
of the information is accessible from publicly available 
databases similar to the ones employed by the DNC during its 
contribution review.
    Since many of the key fund-raisers involved have refused to 
cooperate with the investigation, the committee has in large 
part focused on following the money. While this is a more labor 
intensive effort than having a cooperative witness who might 
explain the various funding schemes and conduit efforts, the 
committee has uncovered hundreds of thousands of dollars in 
political contributions which should be returned because of the 
illegal or questionable sources of such funds. Much of this 
money should have been returned months--even years ago. The 
Committee's investigation continues and has come a long way 
since the early days of the campaign finance scandal when the 
DNC and Democratic Members of Congress cynically deflected the 
legitimate inquiries regarding illegal foreign money as ``Asian 
bashing'' and said there were no illegalities involved.
    The contributions addressed below are divided into two 
separate categories: illegal and suspect. In the following 
context, illegal contributions are those that the Committee has 
sufficient evidence to conclude--100 percent certainty is not 
the operative standard of the DOJ, the Committee or the DNC--
were made in violation of the Act. Illegal contributions should 
be disgorged to the U.S. Treasury pursuant to FEC regulations 
and DNC practice.\109\ Suspect contributions are those that 
fall under one of two categories derived from DNC policy: (1) 
contributions for which the Committee has been unable to obtain 
sufficient information to verify its legality or 
appropriateness as defined by the DNC and/or (2) contributions 
which may be inappropriate--as defined by the DNC--for the 
recipient to retain. Suspect contributions should be returned 
to the contributor or disgorged to the U.S. Treasury pursuant 
to Federal regulations and DNC practice.\110\ The Committee 
welcomes any information--consistent with or contradictory to 
information gathered to date--that may assist it in determining 
the legality or appropriateness of a contribution.
---------------------------------------------------------------------------
    \109\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
    \110\ Id.
---------------------------------------------------------------------------

    Lippo Group Related Contributions During the 1992 Election Cycle

 A. Contributions by James Riady, John Huang and Their Spouses During 
                        the 1992 Election Cycle

        James Riady $325,000 and Aileen Riady $125,000 (Suspect)

    On August 12, 1992, the Lippo Group through Hip Hing 
Holdings, Ltd. (``Hip Hing Holdings''), a Lippo 
Subsidiary,\111\ contributed $50,000 to the DNC.\112\ Five days 
later, on August 17, 1992, John Huang and Agus Setiawan, then-
Lippo/Hip Hing Holdings employees, co-authored a memo to fellow 
Lippo employee Mrs. Ong Bwee Eng requesting that she ``[p]lease 
kindly wire'' a reimbursement from Lippo Group Indonesia in the 
amount of $50,000 specifically for the DNC contribution.\113\ 
(The DNC returned this $50,000 contribution in 1997 after it 
was detailed in a Senate hearing.).\114\
---------------------------------------------------------------------------
    \111\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, 105th Cong., 1st sess., part II, S. Hrg. 105-300, 
3 (1998) (Testimony of Juliana Utomo, July 15, 1997).
    \112\ LippoBank Check No. 2397 from Hip Hing Holdings to the DNC 
Victory Fund Non-Federal Account in the Amount of $50,000, Aug. 12, 
1992, HHH 1263 (Exhibit 26).
    \113\ Memorandum from John Huang and Agus Setiawan to Mrs. Ong Bwee 
Eng, Aug. 17, 1992, HHH 0238 (Exhibit 27).
    \114\ James Rowley, ``The Senate Investigation of Campaign Fund-
raising Abuses,'' Associated Press, July 15, 1997; Lynn Sweet, 
``Democrats to Return $50,000 Foreign Contribution,'' Chicago Sun-
Times, July 16, 1997, at 31.
---------------------------------------------------------------------------
    On August 13, 1992, Lippo Group Deputy Chairman James Riady 
\115\ and his wife Aileen contributed a total of $30,000 to the 
DNC \116\ and $10,000 to the California Democratic party.\117\ 
The following day, then-Governor Bill Clinton--on his way to a 
fund-raiser--took a 5 minute car ride with James Riady as 
discussed in an August 14, 1992, memorandum from then-campaign 
aide Melinda Yee to then-Governor Bill Clinton which states:
---------------------------------------------------------------------------
    \115\ Memorandum from Melinda Yee to Governor Bill Clinton, Aug. 
14, 1992 (Exhibit 28).
    \116\ LippoBank Checks from James T. and Aileen Riady to the DNC, 
Aug. 13, 1992, HHH 1360 (Exhibit 29); see also http://wyl.ewg.org, 
Environmental Working Group Website, Compiled from Federal Election 
Commission [FEC] Data, Last Updated Sept. 10, 1998.
    \117\ Exhibit 29 LippoBank Checks from James T. and Aileen Riady to 
the California Democratic party, Aug. 13, 1992, HHH 1360; http://
wyl.ewg.org, Environmental Working Group Website, Compiled from Federal 
Election Commission [FEC] Data, Last Updated Sept. 10, 1998 
(attributing James T. Riady's $5,000 contribution to the California 
Democratic party to Aileen Riady).

        James Riady is the Deputy Chairman of Lippogroup [sic] 
        and a long-time acquaintance of yours. The group is in 
        financial services in the U.S. and throughout Asia. Mr. 
        Riady lived in Arkansas from 1985-1987 when he was 
---------------------------------------------------------------------------
        president of Worthen Bank in Little Rock.

        He has flown all they [sic] way from Indonesia, where 
        he is now based, to attend the fundraiser. He will be 
        giving $100,000 to this event and has the potential to 
        give much more. He will talk to you about banking 
        issues and international business. This is primarily a 
        courtesy call.\118\

    \118\ Exhibit 28 Memorandum from Melinda Yee to Governor Bill 
Clinton, Aug. 14, 1992, CG92B 00543 (emphasis added); see also Schedule 
of Governor Bill Clinton, Aug. 14, 1992, CG92B 01461 (Exhibit 30).

Over the following weeks leading up to the November election, 
James and Aileen Riady contributed an additional $410,000 to 
state Democratic parties\119\ bringing the total to $450,000 as 
detailed below:
---------------------------------------------------------------------------
    \119\ LippoBank Checks from James and Aileen Riady to Various State 
Democratic Parties, Sept. 30, 1992, through Oct. 15, 1992, HHH 1363 
(Exhibit 31); see also http://wyl.ewg.org, Environmental Working Group 
Website, Compiled from FEC Data, Last Updated Sept. 10, 1998.

----------------------------------------------------------------------------------------------------------------
                                                  Check        FEC                                              
                     Name                       Date\120\   Date\121\             Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
James T. Riady...............................    08/13/92    09/04/92  California Democratic Party....    $5,000
James T. Riady...............................    08/13/92    08/17/92  DNC............................    15,000
James T. Riady...............................    09/30/92  ..........  Michigan Democratic Party......    75,000
James T. Riady...............................    10/05/92  ..........  Ohio Democratic Party..........    75,000
James T. Riady...............................    10/08/92  ..........  Arkansas Democratic Party......     5,000
James T. Riady...............................    10/08/92    10/27/92  Arkansas Democratic Party......    75,000
James T. Riady...............................    10/12/92  ..........  Louisiana Democratic Party.....    75,000
Aileen Riady.................................    08/13/92    09/04/92  California Democratic Party....     5,000
Aileen Riady.................................    08/13/92    08/17/92  DNC............................    15,000
Aileen Riady.................................    10/08/92    10/27/92  Arkansas Democratic Party......     5,000
Aileen Riady.................................    10/12/92  ..........  Georgia Democratic Party.......    50,000
Aileen Riady.................................    10/15/92    10/29/92  North Carolina Democratic Party    50,000
----------------------------------------------------------------------------------------------------------------
\120\ Throughout this document, the ``Check Date'' is taken directly from the contribution check.               
\121\ The ``FEC Date'' is taken from FEC data as provided at http://wyl.ewg.org, Environmental Working Group    
  Website, Compiled from FEC Data, Last Updated Sept. 10, 1998. See also www.tray.com. Experience demonstrates  
  that the date on the contribution check usually leads the FEC date by anywhere from one day to a month.       

After the election, the Riadys contributed $286,000 to the 
Presidential Inaugural Committee,\122\ $86,000 of which was 
given through John Huang,\123\ then-Lippo executive and co-
director of Hip Hing Holdings, Ltd.\124\ The Riadys and the 
Lippo Group contributed a total of $786,000 to Democratic 
causes during the closing months of 1992.\125\
---------------------------------------------------------------------------
    \122\ LippoBank Checks from James T. and Aileen Riady to the 
Presidential Inaugural Committee, Nov. 20, 1992, HHH 1361 (Exhibit 32); 
LippoBank Checks from John and Jane Huang to the Presidential Inaugural 
Committee, Jan. 5, 1993, 001298, 001300, 001302, and 001304 (John Huang 
accidentally dated check no. 1117 Jan. 5, 1992, instead of Jan. 3, 
1992.) (Exhibit 33); LippoBank Check from Bank of Trade to John Huang 
in the Amount of $86,000, Jan. 12, 1993, and LippoBank Deposit Ticket 
of John Huang in the Amount of $86,000, Jan. 13, 1993, L 003318-L 
003319 (Exhibit 34).
    \123\ Exhibit 33 LippoBank Checks from John and Jane Huang to the 
Presidential Inaugural Committee, Jan. 5, 1993, 001298, 001300, 001302, 
and 001304 (John Huang accidentally dated check no. 1117 Jan. 5, 1992, 
instead of Jan. 3, 1992.); Exhibit 34 LippoBank Check from Bank of 
Trade to John Huang in the Amount of $86,000, Jan. 12, 1993, and 
LippoBank Deposit Ticket of John Huang in the Amount of $86,000, Jan. 
13, 1993, L 003318-L 003319. The Presidential Inaugural Committee is 
not bound by the same contribution restrictions as political committees 
such as the DNC and state Democratic parties.
    \124\ Hip Hing Holdings Certificate of Incorporation, State of 
California, HHH 0243 (Exhibit 35).
    \125\ It should be noted that the ethnic-Chinese Riady family, 
whose future is very closely tied to the Most Favored Nation [MFN] 
trading privilege for China and the development of Asian markets, made 
these contributions at a time when then-Presidential candidate Clinton 
was linking the grant of MFN privilege for China to human rights. 
Several months after Bill Clinton was settled in the White House, 
Mochtar Riady sent him a confidential letter dated Mar. 9, 1993, in 
which he implored the President to reverse his campaign stance on MFN. 
The letter states in pertinent part:

      You have continued to positively surprise . . . close 
      friends like me. I appreciate the many kind attention [sic] 
      and courtesies that you have extended to me, my family, and 
      my son, James. I also very much enjoyed and appreciated the 
      very private personal time you and Hillary gave to my 
---------------------------------------------------------------------------
      family during your busy schedule on Inauguration day.

Riady urged President Clinton to:

      Normalize relations with Vietnam. As we speak, I have two 
      of my managers in Vietnam exploring business opportunities. 
      They have been rubbing shoulders with American businessmen, 
      who can now sign deals with Vietnam, but are still 
      prevented from implementing those contracts. . . . Continue 
      economic engagement with China. Washington has implemented 
      over the past decade a policy of promoting Chinese economic 
      reforms while, on a parallel track, pushed for political 
      reforms. If Most Favored Nation status is withdrawn from, 
      or other negative policies are adopted for China by the 
      U.S., it was argued, Chinese entrepreneurs in effect, those 
      pushing hardest for reforms would be hurt the most. I 
      subscribe to the logic behind this argument, and would urge 
      that these basic principles be maintained. We strongly 
      believe, as do many others, that the best way of achieving 
      political reform in China is through capitalist 
      interaction.

Letter from Dr. Mochtar Riady to President Bill Clinton, Mar. 9, 1993, 
EOP 003036-EOP 003039 (Exhibit 36). Of course, President Clinton 
softened his position soon after taking office in early 1993; President 
Clinton approved MFN for China on May 27, 1993. In 1994 he completely 
``de-linked'' China's MFN trading privilege from its human rights 
record. While many would certainly argue that there are sound policy 
reasons for the extension of MFN status for China, President Clinton is 
one of the rare politicians to have so dramatically altered his 
position on this controversial issue. See generally Choi Hak Kim, 
``Mochtar Riady, a Man of Insight, Forbes (Chinese Language Edition), 
October 1993; David Lauter, ``Clinton Blasts Bush's Foreign Policy 
Record,'' Los Angeles Times, Aug. 14, 1992, at A1; Jim Mann, ``Clinton 
Ties China's Trade in Future to Human Rights, Asia: He Extends Favored-
nation Status; Legislators Back Demand That Beijing Improve Policies by 
Next Year,'' Los Angeles Times, May 29, 1993, at A1; ``Clinton Says 
China's Favored Trade Status Will Be Renewed for 1 Year,'' Chicago 
Tribune, May 28, 1993, at 4; John M. Broder and Jim Mann, ``Clinton 
Reverses His Policy, Renews China Trade Status, Commerce: President 
`De-Links' Most-Favored-Nation Privilege from Human Rights. He Admits 
Failure of Earlier Course and Says Broader Strategic Interests Justify 
Switch,'' Los Angeles Times, May 27, 1994.
    DNC officials testified that the 1992 vetting system 
involved an entire group of DNC staff of 6 to 10 people and DNC 
General Counsel Joseph Sandler testified that ``for the 1992 
election a procedure known as Major Donor Screening Committee'' 
was in place.\126\ However, the Committee has received no 
evidence to indicate that certain large contributions were 
vetted in 1992, notably those from the Riadys and their related 
companies and employees. Because the Riadys' contributions were 
made in 1992, they were not subject to the DNC's contribution 
review.\127\ None of the Riady contributions have been returned 
by the DNC or the state parties.\128\
---------------------------------------------------------------------------
    \126\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 1, 
169 (1998).
    \127\ See Committee Deposition of Joseph E. Sandler, Esq., May 14, 
1998, 27-28.
    \128\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
---------------------------------------------------------------------------
    During his years as a Lippo employee, John Huang determined 
where the Riadys should direct their political contributions. 
In a February 17, 1993, memorandum to then-Deputy Assistant to 
the President and Deputy Director of Presidential Personnel 
John Emerson, then-DNC Executive Committee member Maeley Tom 
wrote:

        John Huang, Executive Vice President of Lippo Bank 
        [sic], is the political power that advises the Riady 
        family on issues and where to make contributions. [The 
        Riadys] invested heavily in the Clinton campaign. John 
        is the Riady family's top priority for placement 
        because he is like one of their own.\129\
---------------------------------------------------------------------------
    \129\ Letter from Maeley Tom to John Emerson, Feb. 17, 1993 
(emphasis added) (Exhibit 37).

    Huang was eventually placed at the Department of 
Commerce.\130\
---------------------------------------------------------------------------
    \130\ John Huang began his employ at the Department of Commerce on 
July 18, 1994. See Memorandum from Charles F. Meissner to Ann Hughes, 
et al., July 15, 1994 (Exhibit 38).
---------------------------------------------------------------------------
    FEC data does not record any political contributions by the 
Riadys in their personal capacities after 1992.\131\ However, 
DNC documents suggest that the Riadys may have contributed--
indirectly perhaps through conduits--to the DNC as late as 1994 
and 1996.\132\ A June 11, 1994, DNC memorandum from David 
Mercer to then-DNC Finance Director Richard Sullivan and Fran 
Wakem discusses an invitation for James Riady to the June 21, 
1994, Business Leadership Forum (``BLF'')/White House event 
(which Riady later attended).\133\ After listing James Riady as 
a current member of the BLF--a DNC fund-raising organization 
and ``the principal organization of the nation's top business 
leaders supporting the Democratic Party'' \134\--and one of the 
``Members to Confirm,'' the memorandum describes Riady and his 
relationship with Huang: ``FOB; Former president, Wortham [sic] 
Bank in Little Rock; Clinton/DNC donor thru [sic] John Huang; 
Huang requested his invitation and that we send it to Huang's 
address.'' \135\ Huang was not employed by the DNC at this 
time; \136\ he was still at Lippo. Why was a foreign national 
who was ineligible to legally contribute under Federal election 
law listed as a DNC donor through John Huang?
---------------------------------------------------------------------------
    \131\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998. The Wiriadianas' 
illegal conduit contributions to the DNC during the 1996 election cycle 
appear to be linked to the Riadys:
    Bank records received by the Committee provide strong evidence that 
Hasjim Ning, co-founder of Lippo and longtime friend of Mochtar and 
James Riady, or James Riady directed $450,000 in foreign money to the 
DNC and Democratic campaigns through Dr. Ning's daughter Soraya 
Wiriadinata and her husband Arief Wiriadinata, a landscape architect in 
northern Virginia. These payments followed correspondence between 
President Clinton and Mr. Ning and preceded a visit by Arief 
Wiriadinata with President Clinton at the White House on Dec. 15, 1995, 
at which time he told that President that ``James Riady sent me.'' WHCA 
videotape of White House Coffee, Dec. 15, 1995; White House WAVES 
Record for Arief Wiriadinata (Exhibit 39). President Clinton responded, 
``Yes. I'm glad to see you. Thank you for being here.'' Id.
    In June 1995, Dr. Ning suffered a heart attack while visiting the 
Washington, DC, area and as a result was hospitalized in northern 
Virginia. Alan C. Miller, ``Controversy Swirls Over Donation to 
Democrats,'' Los Angeles Times, Oct. 14, 1996, at A1. During Dr. Ning's 
hospitalization, James Riady personally requested that President 
Clinton send Ning a ``get well'' card. Ruth Marcus and Charles R. 
Babcock, ``Visit Spurred Indonesians' Gift, Says DNC; Party Offers 
Explanation for $425,000 Donation From Couple Who Never Gave Before,'' 
the Washington Post, Oct. 12, 1996, at A21. Mark Middleton hand 
delivered the requested card dated June 19, 1995 to Dr. Ning which 
stated: ``I was so sorry to learn of your health problems. You are in 
my thoughts and prayers during this difficult time.'' Id.; Letter from 
President Bill Clinton to Dr. Hasjim Ning, June 19, 1995, DNC 1227204 
(Exhibit 40). After recuperating and returning to Indonesia, Dr. Ning 
responded to President Clinton in a letter dated Sept. 5, 1995 which 
stated in part: ``. . . I thank you for your prayers and concern. I 
also thank you for sending Mr. Mark Middleton to visit me at that time. 
. . . '' Letter from Dr. Hasjim Ning to President Bill Clinton, Sept. 
5, 1995, DNC 1227205 (Exhibit 41). In a letter dated Nov. 8, 1995, 
President Clinton again wrote Dr. Ning: ``You have been in my thoughts, 
and Hillary joins me in sending best wishes for your continued 
recovery.'' Letter from President Bill Clinton to Dr. Hasjim Ning, Nov. 
8, 1995, DNC 1227206 (Exhibit 42). John Huang, who knew Dr. Ning from 
their mutual association with Lippo, also visited him during his 
hospitalization. Alan C. Miller, ``Controversy Swirls Over Donation to 
Democrats,'' Los Angeles Times, Oct. 14, 1996, at A1; Richard T. 
Cooper, ``How DNC Got Caught in a Donor Dilemma,'' Los Angeles Times, 
Dec. 23, 1996, at A1. During his visit, Huang met Arief and Soraya 
Wiriadinata. Huang recalls that the Wiriadinatas subsequently 
``expressed an interest in supporting the Democratic party and the 
President, and [he] suggested that they contribute to the DNC.'' Id. 
The contributions from the Wiriadinatas began in the fall of 1995.
    On Nov. 2, 1995, Arief and Soraya Wiriadinata opened separate 
checking accounts at the First Union National Bank of Virginia (First 
Union). First Union Account Statement of Arief Wiriadinata, Nov. 2, 
1995 (Exhibit 43); First Union of Virginia Account Statement of Soraya 
Wiriadinata, Nov. 2, 1995 (Exhibit 44). The next day, on Nov. 3, 1995, 
Ms. Soraya Wiriadinata received a $250,000 wire transfer from Dr. Ning 
in Djakarta, Indonesia. Exhibit 44 First Union of Virginia Account 
Statement of Soraya Wiriadinata, Nov. 2, 1995. Similarly, Mr. Arief 
Wiriadinata received a $250,000 wire transfer from Dr. Ning on Nov. 7, 
1995. Exhibit 43 First Union of Virginia Account Statement of Arief 
Wiriadinata, Nov. 2, 1995.
    From Nov. 1995-July 1996, Mr. Wiriadinata and Ms. Wiriadinata each 
contributed $1,000 to Jackson for Congress and $226,000 to the DNC from 
their personal checking accounts at First Union. First Union Check from 
Arief Wiriadinata to the DNC in the amount of $15,000, Nov. 8, 1995 
(Exhibit 45); First Union Check No. 1001 from Arief Wiriadinata to 
Jackson for Congress in the amount of $1,000, Nov. 20, 1995 (Exhibit 
46); First Union Check No. 1005 from Arief Wiriadinata to the DNC in 
the amount of $25,000, Dec. 11, 1995 (Exhibit 47); First Union Check 
No. 1010 from Arief Wiriadinata to the DNC in the amount of $10,000, 
Dec. 15, 1995 (Exhibit 48); First Union Check No. 1015 from Arief 
Wiriadinata to the DNC in the amount of $25,000, Feb. 15, 1996 (Exhibit 
49); First Union Check No. 1016 from Arief Wiriadinata to the DNC in 
the amount of $25,000, May 22, 1996 (Exhibit 50); First Union Check No. 
1020 from Arief Wiriadinata to the DNC in the amount of $25,000, May 
12, 1996 (Exhibit 51); First Union Check No. 1023 from Arief 
Wiriadinata to the DNC in the amount of $25,000, June 25, 1996 (Exhibit 
52); First Union Check No. 1025 from Arief Wiriadinata to the DNC in 
the amount of $25,000, June 6, 1996 (Exhibit 53); Exhibit 43 First 
Union Account Statement of Arief Wiriadinata, Nov. 2, 1995; First Union 
Account Statement of Arief Wiriadinata, Nov. 16, 1995 (Exhibit 54); 
First Union Account Statement of Arief Wiriadinata, Dec. 15, 1995 
(Exhibit 55); First Union Account Statement of Arief Wiriadinata, Jan. 
18, 1996 (Exhibit 56); First Union Account Statement of Arief 
Wiriadinata, Feb. 15, 1996 (Exhibit 57); First Union Account Statement 
of Arief Wiriadinata, Mar. 16, 1996 (Exhibit 58); First Union Account 
Statement of Arief Wiriadinata, May 16, 1996 (Exhibit 59); First Union 
Account Statement of Arief Wiriadinata, June 15, 1996 (Exhibit 60); 
First Union Account Statement of Arief Wiriadinata, July 18, 1996 
(Exhibit 61); First Union Check from Soraya Wiriadinata to the DNC in 
the amount of $15,000, Nov. 8, 1995 (Exhibit 62); First Union Check No. 
1004 from Jackson for Congress in the amount of $1,000, Nov. 20, 1995 
(Exhibit 63); First Union Check No. 1008 from Soraya Wiriadinata to the 
DNC in the amount of $25,000, Dec. 11, 1995 (Exhibit 64); First Union 
Check No. 1012 from Soraya Wiriadinata to the DNC in the amount of 
$25,000, Dec. 13, 1995 (Exhibit 65); First Union Check No. 1015 from 
Soraya Wiriadinata to the DNC in the amount of $10,000, Dec. 15, 1995 
(Exhibit 66); First Union Check No. 1016 from Soraya Wiriadinata to the 
DNC in the amount of $10,000, Dec. 18, 1995 (Exhibit 67); First Union 
Check No. 1022 from Soraya Wiriadinata to the DNC in the amount of 
$25,000, month and day illegible, 1996 (Exhibit 68); First Union Check 
No. 1024 from Soraya Wiriadinata to the DNC in the amount of $25,000, 
June 7, 1996 (Exhibit 69); First Union Check No. 1026 from Soraya 
Wiriadinata to the DNC in the amount of $25,000, May 10, 1996 (Exhibit 
70); First Union Check No. 1028 from Soraya Wiriadinata to the DNC in 
the amount of $25,000, May 10, 1996 (Exhibit 71); DNC Check Tracking 
Form for First Union Check No. 1029 from Soraya Wiriadinata to the DNC 
in the amount of $25,000, June 27, 1996 (Exhibit 72); Exhibit 44 First 
Union Account Statement of Soraya Wiriadinata, Nov. 2, 1995; First 
Union Account Statement of Soraya Wiriadinata, Nov. 16, 1995 (Exhibit 
73); First Union Account Statement of Soraya Wiriadinata, Dec. 15, 1995 
(Exhibit 74); First Union Account Statement of Soraya Wiriadinata, Jan. 
18, 1996 (Exhibit 75); First Union Account Statement of Soraya 
Wiriadinata, Feb. 15, 1996 (Exhibit 76); First Union Account Statement 
of Soraya Wiriadinata, Mar. 16, 1996 (Exhibit 77); First Union Account 
Statement of Soraya Wiriadinata, Apr. 17, 1996 (Exhibit 78); First 
Union Account Statement of Soraya Wiriadinata, May 16, 1996 (Exhibit 
79); First Union Account Statement of Soraya Wiriadinata, June 15, 1996 
(Exhibit 80); First Union Account Statement of Soraya Wiriadinata, July 
18, 1996 (Exhibit 81); First Union Account Statement of Soraya 
Wiriadinata, Aug. 16, 1996 (Exhibit 82); First Union Account Statement 
of Soraya Wiriadinata, Sept. 17, 1996 (Exhibit 83); see also http://
wyl.ewg.org, Environmental Working Group Website, Compiled from FEC 
Data, Last Updated Sept. 10, 1998. Copies of check nos. 1007 and 1013 
to the DNC in the totaling $50,000 were unavailable to the committee. 
Account statements have been provided in their stead. A copy of check 
no. 1029 to the DNC in the amount of $25,000 was unavailable to the 
Committee. An account statement has been provided in its stead. The 
political contributions appear to be the primary reason for the 
establishment of both Arief and Soraya Wiriadinatas' First Union 
accounts. In sum, Dr. Ning wired a total of $500,000 to the 
Wiriadinata's First Union accounts, $452,000 of which was directed to 
Democratic causes within 7 months.
    Dr. Ning died on Dec. 26, 1995. Arief and Soraya Wiriadinata are 
currently residing in Indonesia.
    \132\ With regard to the 1996 election cycle, the ultimate source 
of the $200,000 in Bank Central Asia Travelers Checks discovered by the 
Committee--at least $50,000 of which was funneled illegally into the 
DNC--is yet undetermined, but they were disseminated at least in part 
by former Lippo executive Antonio Pan and Yah Lin ``Charlie'' Trie, an 
associate of John Huang, and were purchased by a yet undetermined 
individual in Djakarta, Indonesia, the international headquarters of 
the Lippo Group. See Discussion of J & M International, Manlin Foung, 
and Joseph Landon, infra;  see generally Letter from Christopher M. 
Curran, Esq., Attorney for Bank Central Asia, to senior investigative 
counsel, Tim Griffin, Esq., July 20, 1998 (Exhibit 84).
    \133\ DNC Memorandum from David Mercer to Richard Sullivan and Fran 
Wakem, June 11, 1994, DNC 1276431-DNC 1276433 (Exhibit 85). John Huang 
began his employ at the Department of Commerce on July 18, 1994. See 
Exhibit 38 Memorandum from Charles F. Meissner to Ann Hughes, et al., 
July 15, 1994; see also U.S. Secret Service Records for Entry into 
White House Complex, EOP 055316-EOP 055318 (showing attendance of Riady 
at June 21, 1994, White House event) (Exhibit 86).
    \134\ DNC BLF Document, GROC 000644 (Exhibit 87). According to the 
DNC, ``[m]embership in the [Business Leadership] Forum requires a 
$10,000 annual contribution for individuals, or $15,000 for 
corporations or PACs. Individuals memberships are non-transferable.'' 
Id.
    \135\ Exhibit 85 DNC Memorandum from David Mercer to Richard 
Sullivan and Fran Wakem, June 11, 1994, DNC 1276433 (emphasis added).
    \136\ Exhibit DNC Personnel Change Authorization for John Huang, 
Dec. 4, 1995, D 0000005.
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    On a June 17, 1994, DNC list of ``Positive Responses'' for 
the Trustee Gala Reservations, James T. Riady is confirmed for 
2 reservations including his guest Aileen Riady and is listed 
as a member of the BLF.\137\
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    \137\ DNC List of Positive Responses for Trustee Gala Reservations, 
June 17, 1994, DNC 1727213-DNC 1727217 (Exhibit 88). Of note is the 
fact that of all the 55 individuals listed as ``Positive Responses'' on 
this list, the only individuals for whom no address, phone number or 
contact information is listed is James T. Riady. Id. at 4.
---------------------------------------------------------------------------
    On June 10, 1996, the DNC held a fund-raiser/dinner at the 
home of Edie and Lew Wasserman in Los Angeles.\138\ The DNC 
``commit list'' prepared in conjunction with that event lists 
the individuals who pledged to contribute and the amount 
pledged.\139\ The commit list indicates that Aileen and James 
Riady pledged to contribute $15,000 in conjunction with the 
Wasserman dinner.\140\
---------------------------------------------------------------------------
    \138\ See DNC Commit List for June 10, 1996, Dinner at the 
Wasserman Residence, June 3, 1996, DNC 3088330-DNC 3088334, at 1-5 
(Exhibit 89).
    \139\ Id.
    \140\ Id. at 4.
---------------------------------------------------------------------------
    On September 16, 1996, DNC Chairman Donald L. Fowler wrote 
James Riady a letter--addressed to the Lippo Village in 
Tangerrang, Indonesia--which provides in pertinent part that:

        Thank you very much for sending me the basket of fruit 
        and snacks. It was a wonderful surprise, and I greatly 
        enjoyed its contents.

        Your friendship is tremendously important to me in this 
        crucial time. As you know, all of us are working 
        diligently to bring about a huge Democratic victory in 
        November, and your gift reminded me of the support of 
        good Democrats for these efforts.

        Thanks again for the thoughtful gift and for all your 
        kindness to Cissy. I look forward to seeing you 
        soon.\141\
---------------------------------------------------------------------------
    \141\ Letter from Donald L. Fowler to James Riady, Sept. 16, 1996, 
DNC 1728039 (emphasis added) (Exhibit 90). The Committee's copy of the 
letter is unsigned.

And on September 18, 1996, DNC Chairman Fowler wrote a thank 
you letter to both Aileen and James Riady in the wake of a 
dinner with the President.\142\ The letter provides in 
pertinent part that:
---------------------------------------------------------------------------
    \142\ Letter from Donald L. Fowler to James and Aileen Riady, Sept. 
18, 1996, F 0040618 (emphasis added) (Exhibit 91). The Committee's copy 
of the letter is signed.

        It was a pleasure seeing you at the dinner with the 
        President recently. Your support enables us to continue 
        assisting the Administration in achieving its ambitious 
        agenda. On behalf of the DNC, I am sincerely grateful 
---------------------------------------------------------------------------
        for your work.

        As you know, we are 7 weeks away from the 1996 
        Presidential Election. We at the DNC are working to 
        strengthen our cooperation with the State Parties, 
        businesses and local leaders. I am confident that with 
        the help of friends like you, we will be victorious in 
        '96 and will continue to move this country forward into 
        the 21st century.
        My door is always open to you; please do not hesitate 
        to call on me if I can be of assistance. I look forward 
        to working closely with you in the months ahead.\143\
---------------------------------------------------------------------------
    \143\ Id.

    It deserves mention that letters--even form letters--
thanking individuals for their support are generally sent in 
response to a political contribution. Additionally, though not 
conclusive of possible post-1992 contributions to the DNC by 
the Riadys, on March 6, 1996, DNC Chairman Fowler wrote what 
appears to be a form fund-raising letter to James Riady asking 
for his support.\144\
---------------------------------------------------------------------------
    \144\ Letter from Donald L. Fowler to James Riady, Mar. 6, 1996, 
DNC 1761242 (Exhibit 92).
---------------------------------------------------------------------------
    Although there is no FEC record of Riady contributions 
after 1992, these documents and the Riadys' attendance at 
numerous fund-raising events \145\ raise logical questions 
concerning whether and through whom the Riadys contributed to 
the DNC during the 1994 and 1996 election cycles and who had 
knowledge of any such schemes.
---------------------------------------------------------------------------
    \145\ James Riady is believed to have attended the May 10, 1995, 
DNC breakfast with Vice President Gore. See DNC Memorandum from Adam 
Crain to David Mercer, Apr. 20, 1995, DNC 3169174 (Exhibit 93); see 
also Letter from Mack McLarty to James T. Riady, Aug. 2, 1996, EOP 
008591 (``I certainly enjoyed seeing you and John Huang at the Winston 
Bryant reception with the President.'') (Exhibit 94).
---------------------------------------------------------------------------
    Due to the fact that neither James nor Aileen Riady are 
U.S. citizens,\146\ the legality of their 1992 contributions is 
questionable. The Act provides in pertinent part that:
---------------------------------------------------------------------------
    \146\ See generally Deposition of James T. Riady, Stephens Group, 
Inc. v. United States, Case No. 91-1458T (U.S. Ct. Fed. Claims), Mar. 
5, 1993, 2; John Solomon, ``Investigators Turn Up First Evidence of 
Clinton Link to Foreign Money,'' Associated Press, June 9, 1998. The 
Committee would like to cite to Immigration and Naturalization Service 
[INS] records regarding the Riadys' permanent resident status. However, 
despite requesting them as early as Feb. 5, 1997, Aug. 13, 1997, and 
Sept. 26, 1997, and as recently as Oct. 1, 1998, the INS through the 
DOJ has yet to produce the Riadys' immigration records to the 
Committee. See Letter from Chairman Dan Burton to the Honorable Doris 
Meissner, Feb. 5, 1997 (Exhibit 95); Letter from Chairman Dan Burton to 
Johnny Stokes, Aug. 13, 1997 (Exhibit 96); Letter from Chairman Dan 
Burton to the Honorable Doris Meissner, Sept. 26, 1997 (Exhibit 97).

        It shall be unlawful for a foreign national directly or 
        through any other person to make any contribution of 
        money . . ., in connection with an election to any 
        political office or in connection with an election to 
        any political office . . .; or for any person to 
        solicit, accept, or receive any such contribution from 
        a foreign national.\147\
---------------------------------------------------------------------------
    \147\ 2 U.S.C. Sec. 441e(a) (emphasis added).

    In other words, foreign nationals are prohibited from 
making political contributions. Unlike most of the other 
provisions of the Act, this prohibition found in 2 U.S.C. 
Sec. 441e(a), ``applies to any election for any political 
office, including state and local offices.'' \148\
---------------------------------------------------------------------------
    \148\ FEC Advisory Opinion No. 1992-16 (emphasis added); see also 
Id.
---------------------------------------------------------------------------
    Although some might argue that 2 U.S.C. Sec. 441e is 
inapplicable to ``soft money'' \149\ and thus, in large part, 
may be inapplicable to the Riadys' contributions, the DNC 
refuses to accept any contributions from foreign nationals as a 
matter of policy as explained by DNC General Counsel Sandler:
---------------------------------------------------------------------------
    \149\ ``Campaign Finance Reform: A Sourcebook,'' Brookings 
Institution, 1997.

          Counsel. -What makes all contributions from foreign 
        nationals to the DNC illegal?
          Sandler. -Foreign nationals as defined in section 
        441e of the Federal Election Campaign Act are illegal. 
        In our view, it is illegal--that section applies to 
        contributions to all of the DNC's accounts; probably as 
        a matter of law does not apply to contributions to the 
        building fund but as a policy matter that's what we 
        instructed our finance staff, all DNC staff, for that 
        matter.
          Counsel. -And by ``all contributions,'' did you mean 
        contributions to both the DNC Federal and non-Federal 
        accounts?
          Sandler. -Correct.
          Counsel. -Is that still the policy of the DNC today?
          Sandler. -Yes.\150\
---------------------------------------------------------------------------
    \150\ Committee Deposition of Joseph E. Sandler, Esq., May 14, 
1998, 25.

    The Committee is unaware of any attempts by State parties 
to argue the legality of accepting a contribution--regardless 
of its technical classification as soft or hard--from foreign 
nationals as defined in the Act.
    The definition of the term ``foreign national'' is divided 
into two separate and distinct parts as excerpted below in 
pertinent part:

    (b) As used in this section, the term ``foreign national'' 
means--
          (1) a foreign principal, as such term is defined by 
        section 611(b) of Title 22, except that the term 
        ``foreign national'' shall not include any individual 
        who is a citizen of the United States; or
          (2) an individual who is not a citizen of the United 
        States and who is not lawfully admitted for permanent 
        residence . . .\151\
---------------------------------------------------------------------------
    \151\ 2 U.S.C. Sec. 441e(b) (1) and (2).

    An individual or entity meeting either definition 
constitutes a ``foreign national'' for purposes of 2 U.S.C. 
Sec. 441e(a).\152\ The term ``foreign national'' does not 
include a U.S. citizen under any circumstances.\153\
---------------------------------------------------------------------------
    \152\ 2 U.S.C. Sec. 441e(b) employs the disjunctive ``or'' between 
subsections (1) and (2).
    \153\ 2 U.S.C. Sec. 441e(b) (1) and (2).
---------------------------------------------------------------------------
    Addressing subsection (b)(2) first, an individual who is 
neither a U.S. citizen nor a permanent resident is a ``foreign 
national'' and is unable to contribute.\154\ The Riadys were 
permanent residents at the time of their contributions.\155\ 
So, applying this definition of a ``foreign national'' without 
further analysis, the Riadys were not prohibited from making 
political contributions during the 1992 election cycle. The 
White House and the DNC evidently agree: White House spokesman 
James Kennedy indicated that ``[i]n 1992, [James Riady] was a 
lawful permanent resident and eligible to contribute to any 
political party. Thus there was no basis for anyone to believe 
that Mr. Riady's contributions to the DNC might be illegal.'' 
\156\ DNC spokesman Rick Hess said even ``the most careful 
vetting procedures'' would not have raised questions about Mr. 
Riady's contributions.\157\
---------------------------------------------------------------------------
    \154\ 2 U.S.C. Sec. 441e(a) and (b)(2).
    \155\ John Solomon, ``Investigators Turn Up First Evidence of 
Clinton Link to Foreign Money,'' Associated Press, June 9, 1998. The 
Committee would like to cite to INS records regarding the Riadys' 
permanent resident status. However, despite requesting them as early as 
Feb. 5, 1997, Aug. 13, 1997, and Sept. 26, 1997, and as recently as 
Oct. 1, 1998, the INS through the DOJ has yet to produce the Riadys' 
immigration records to the Committee. Exhibit 95 Letter from Chairman 
Dan Burton to the Honorable Doris Meissner, Feb. 5, 1997; Exhibit 96 
Letter from Chairman Dan Burton to Johnny Stokes, Aug. 13, 1997; 
Exhibit 97 Letter from Chairman Dan Burton to the Honorable Doris 
Meissner, Sept. 26, 1997.
    \156\ Id.
    \157\ Id.
---------------------------------------------------------------------------
    However, the definition of a ``foreign national'' includes 
more than individuals who are neither U.S. citizens nor 
permanent residents.\158\ Under subsection (b)(1) the term 
``foreign national'' also includes a somewhat broader 
definition which includes permanent residents under certain 
circumstances.\159\ The term ``foreign national'' must be read 
in conjunction with the term ``foreign principal'' as defined 
by 22 U.S.C. Sec. 611(b).\160\ A ``foreign principal'' includes 
``a person outside of the United States, unless it is 
established that such person is an individual and a citizen of 
and domiciled within the United States . . .'' \161\ So, a 
permanent resident who is ``outside of the United States'' is a 
foreign national under the Act and is prohibited from making 
political contributions.\162\
---------------------------------------------------------------------------
    \158\ 2 U.S.C. Sec. 441e(b)(1).
    \159\ Id.; 22 U.S.C. Sec. 611(b).
    \160\ 2 U.S.C. Sec. 441e(b)(1).
    \161\ 22 U.S.C. Sec. 611(b) (emphasis added).
    \162\ 2 U.S.C. Sec. 441e(a) and (b)(1); 22 U.S.C. ( 611(b).
---------------------------------------------------------------------------
    Both Federal jurisprudence and the statutory context 
suggest that an individual residing and domiciled in a foreign 
country is ``a person outside of the United States,'' a 
temporary visit to the United States notwithstanding.\163\ It 
would be nothing short of a ludicrous and disturbing result if 
a permanent resident ``outside of the United States'' were able 
to circumvent the statutory prohibition against political 
contributions by flying to the United States and stepping off 
the plane. Trevor Potter, a former Commissioner of the FEC, 
agrees. According to Potter, the issue of green-card holders 
who donate while outside the United States is untested, but ``a 
careful reading of the law suggests a green-card holder must be 
residing in the country to donate.'' \164\ The privilege of 
contributing to political campaigns and thereby influencing 
elections is not granted to permanent residents who are 
residing ``outside of the United States.'' \165\
---------------------------------------------------------------------------
    \163\ See generally Levy v. I.R.S. Commissioner, Sec. 76 T.C. 228 
(1981) (rejecting literal interpretation of ``a person outside of the 
United States'' in tax law context); 22 U.S.C. Sec. 611(b) (requiring 
U.S. citizenship as well as a U.S. domiciliary to be excluded from 
definition of ``foreign principle;'' citizenship and physical presence 
not sufficient).
    \164\ John Solomon, ``Investigators Turn Up First Evidence of 
Clinton Link to Foreign Money,'' Associated Press, June 9, 1998 
(emphasis added).
    \165\ See generally 2 U.S.C. Sec. 441e(a) and (b)(1); 22 U.S.C. 
Sec. 611(b).
---------------------------------------------------------------------------
    In this case, applying the statutory definition of a 
``foreign national,'' the operative question is: were James and 
Aileen Riady ``outside of the United States?'' \166\ Despite 
the Riadys' alleged permanent resident status at the time of 
their contributions, the aforementioned August 14, 1992, 
memorandum from then-campaign aide Melinda Yee to then-Governor 
Bill Clinton indicates that they were residing in Indonesia: 
``Mr. Riady lived in Arkansas from 1985-1987 when he was 
president of Worthen Bank in Little Rock. . . . He has flown 
all they [sic] way from Indonesia, where he is now based, to 
attend the fund-raiser.'' \167\ Deposition testimony from 
former Lippo executive Charles DeQueljoe is consistent with the 
August 14 memo as indicated by the following excerpt:
---------------------------------------------------------------------------
    \166\ See generally Id.
    \167\ Exhibit 28 Memorandum from Melinda Yee to Governor Bill 
Clinton, Aug. 14, 1992 (emphasis added).

          Counsel. -When did James Riady live in California, if 
        you know?
          DeQueljoe. -I'd be guessing if I told you. I don't 
        really know.
          Counsel. -Do you know when Mr. Riady moved back to 
        Jakarta?
          DeQueljoe. -Well, I was in Jakarta starting in April 
        of 1991; and my impression was that James, although he 
        traveled a lot, that his base was Jakarta.\168\
---------------------------------------------------------------------------
    \168\ Committee Deposition of Charles DeQueljoe, June 9, 1998, 43-
44.

    The Riadys were ``based'' in Indonesia at the time of their 
contributions; \169\ a temporal physical presence to attend a 
fund-raiser or two does not change that. Additionally, in a 
proceeding held on March 5, 1993, unrelated to campaign 
finance, James Riady testified under oath as follows:
---------------------------------------------------------------------------
    \169\ Exhibit 28 Memorandum from Melinda Yee to Governor Bill 
Clinton, Aug. 14, 1992; Committee Deposition of Charles DeQueljoe, June 
9, 1998, 43-44.

          Counsel. What is your citizenship, Mr. Riady?
          Riady. Indonesian.
          Counsel. Do you live in Indonesia?
          Riady. Yes.
          Counsel. What is your address?
          Riady. Jalan Madiun 15, Jakarta.\170\
---------------------------------------------------------------------------
    \170\ Deposition of James T. Riady, Stephens Group, Inc. v. United 
States, Case No. 91-1458T (U.S. Ct. Fed. Claims), Mar. 5, 1993, 2.

The Senate campaign finance investigation concluded that the 
Riadys permanently returned to Indonesia in 1991.\171\ The 
evidence leads to the almost inescapable conclusion that the 
Riadys, although permanent residents, were ``outside of the 
United States'' in 1992 and 1993 and thus, as foreign 
nationals, were prohibited from making political contributions 
during this period.
---------------------------------------------------------------------------
    \171\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 1, 
1120 and 1125 (1998).
---------------------------------------------------------------------------
    Despite repeated demands, the Riadys have refused to 
cooperate with Committee investigators. The Committee is 
continuing its review of the Riadys' contributions. In any 
event, the Riadys' contributions are highly suspect and 
probably illegal and, therefore, should be disgorged to the 
U.S. Treasury.\172\ Moreover, James Riady is believed to be the 
subject of an ``active pending criminal investigation into 
alleged misconduct involving . . . campaign finance 
violations.'' \173\ Therefore, in the alternative, the Riady's 
contributions should be returned based on the DNC's standard of 
appropriateness.
---------------------------------------------------------------------------
    \172\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
    \173\ See generally Exhibit 9 Policies and Procedures of the DNC 
Regarding Compliance with Campaign Finance Laws, at 18-19. Given the 
DOJ investigation of John Huang's fund-raising activities, it is 
reasonable to assume that the Riadys' contributions are included in 
that investigation.
---------------------------------------------------------------------------

          John Huang $13,800 and Jane Huang $22,000 (Suspect)

    During the 1992 election cycle, John and his wife, Jane 
Huang, contributed a total of $35,800 to the DNC, the DSCC and 
the California Democratic party as detailed below: \174\
---------------------------------------------------------------------------
    \174\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998; see also LippoBank 
Account Statement of John and Jane Huang, Aug. 31, 1992, L 004886 
(Exhibit 98); LippoBank Check No. 1036 from John and Jane Huang to the 
DNC Victory Fund in the amount of $5,000, Aug. 12, 1992, L 004909 
(Exhibit 99); LippoBank Account Statement of John and Jane Huang, Sept. 
30, 1992, L 004915 (Exhibit 100); LippoBank Check No. 1034 from John 
and Jane Huang to the California Democratic party in the amount of 
$5,000, Aug. 10, 1992, and LippoBank Check No. 1050 from John and Jane 
Huang to the California Democratic party in the amount of $1,500, Aug. 
31, 1992, L 004919 (Exhibit 101); LippoBank Check No. 1052 from John 
and Jane Huang to the DNC Victory Fund in the amount of $5,000, Sept. 
15, 1992, L 004939 (Exhibit 102); LippoBank Check No. 1053 from John 
and Jane Huang to the California Democratic party in the amount of 
$1,000, Sept., day illegible, 1992, L 004941 (Exhibit 103); LippoBank 
Account Statement of John and Jane Huang, Sept. 30, 1992, L 010715 
(Exhibit 104); LippoBank Check No. 324 from John and Jane Huang to the 
Democratic Victory Fund in the amount of $1,000, Sept. 1, 1992, L 
010723 (Exhibit 105); LippoBank Check No. 325 from John and Jane Huang 
to the DSCC in the amount of $1500, Sept. 8, 1992, L 010724 (Exhibit 
106); LippoBank Check No. 326 from John and Jane Huang to the DNC 
Victory Fund in the amount of $5,000, Sept. 15, 1992, L 010725 (Exhibit 
107); LippoBank Check No. 327 from John and Jane Huang to the 
California Democratic party in the amount of $1,000, L 010726 (Exhibit 
108); LippoBank Account Statement of John and Jane Huang, Oct. 30, 
1992, L 004945 (Exhibit 109); LippoBank Check No. 1081 from John and 
Jane Huang to the DNC in the amount of $2,500, Oct. 27, 1992, L 004969 
(Exhibit 110); LippoBank Account Statement of John and Jane Huang, Nov. 
30, 1992, L 004971 (Exhibit 111); LippoBank Check No. 1087 from John 
and Jane Huang to the DSCC in the amount of $1,000, Oct. 31, 1992, L 
004987 (Exhibit 112); On Nov. 2, 1992, Aileen Riady issued a check to 
John Huang in the amount of $5,000 which Huang deposited on Nov. 4, 
1992. LippoBank Check from Aileen Riady to John Huang in the amount of 
$5,000, Nov. 2, 1992, and LippoBank Deposit Ticket of John Huang in the 
amount of $5,000, Nov. 4, 1992, L 004975 (Exhibit 113); Exhibit 111 
LippoBank Account Statement of John and Jane Huang, Nov. 30, 1992, L 
004971.

----------------------------------------------------------------------------------------------------------------
                     Name                      Check Date   FEC Date              Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
John Huang...................................  ..........    02/04/92  California Democratic Party....      $500
John Huang...................................  ..........    06/01/92  DNC............................       800
John Huang...................................  ..........    07/28/92  DNC............................     5,000
John Huang...................................    08/31/92    09/04/92  California Democratic Party....     1,500
John Huang...................................    09/08/92    09/23/92  DSCC...........................     1,500
John Huang...................................    09/16/92    09/28/92  California Democratic Party....     1,000
John Huang...................................  ..........    10/27/92  Democratic National Committee..     2,500
John Huang...................................    10/31/92    11/10/92  DSCC...........................     1,000
Jane Huang...................................    08/12/92    08/19/92  DNC............................     5,000
Jane Huang...................................    08/10/92    09/04/92  California Democratic Party....     5,000
Jane Huang...................................    09/01/92    09/09/92  DNC............................     1,000
Jane Huang...................................    09/15/92    09/22/92  DNC............................     5,000
Jane Huang...................................    09/15/92    09/22/92  DNC............................     5,000
Jane Huang...................................    09/16/92    09/28/92  California Democratic Party....     1,000
----------------------------------------------------------------------------------------------------------------

In addition to the contributions listed above, during the 
period 1992-1996, John and Jane Huang contributed a total of 
$76,872 to the DNC,\175\ $21,500 to the DSCC,\176\ $8,000 to 
the DCCC,\177\ $12,500 to the California Democratic party \178\ 
and in excess of $50,000 to congressional and senatorial 
candidates.\179\
---------------------------------------------------------------------------
    \175\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998. John Huang: June 
25, 1993, $10,000 to the DNC; Dec. 14, 1993, $10,000 to the DNC; Mar. 
16, 1994, $10,000 to the DNC. Jane Huang: Dec. 14, 1993, $15,000 to the 
DNC; Mar. 16, 1994, $10,000 to the DNC; Apr. 29, 1994, $5,000 to the 
DNC; Aug. 11, 1994, $5,000 to the DNC; Dec. 22, 1994, $5,000 to the 
DNC.
    \176\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998. John Huang: May 7, 
1993, $2,500 to the DSCC; June 15, 1993, $1,000 to the DSCC; Oct. 21, 
1993, $6,750 to the DSCC. Jane Huang: May 7, 1993, $2,500 to the DSCC; 
June 15, 1993, $1,000 to the DSCC; Oct. 21, 1993, $6,750 to the DSCC; 
Nov. 14, 1995, $1,000 to the DSCC.
    \177\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998. Jane Huang: May 
16, 1994, $3,000 to the Democratic Congressional Dinner Committee; Nov. 
17, 1995, $5,000 to the DCCC.
    \178\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998. John Huang: Feb. 
4, 1992, $500 to the California Democratic party. Jane Huang: Apr. 17, 
1994, $2,000 to the California Democratic party; Apr. 26, 1994, $10,000 
to the California Democratic party; LippoBank Check No. 1426 from John 
and Jane Huang to the California Democratic party-Victory 94 in the 
amount of $10,000, L 003843 (Exhibit 114).
    \179\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
---------------------------------------------------------------------------
    Representatives Richard Gephardt,\180\ Howard Berman, 
Joseph Kennedy, Nancy Pelosi, and Senators Carol Moseley-Braun, 
Alfonse D'Amato, John Kerry, Edward Kennedy, and Barbara 
Mikulski have all returned contributions received from either 
John or Jane Huang.\181\ Despite the prompt return of the Huang 
contributions by Representatives and Senators, the DNC has 
retained their contributions and appears determined to keep 
them.\182\ In recent interrogatories to the DNC, the Committee 
requested information regarding contributions made by John 
Huang. The DNC responded:
---------------------------------------------------------------------------
    \180\ Contributions to House Minority Leader Richard A. Gephardt 
(D-MO-3) referenced in this report were made either to his campaign or 
to his Political Action Committee under the name ``The Effective 
Government Committee.'' ``Politicians and Their PACs,'' Associated 
Press, Dec. 13, 1997.
    \181\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \182\ The DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 26-29. FEC data indicates that the 
DNC returned $15,000 to John Huang on Feb. 15, 1994, and $5,000 to Jane 
Huang on Feb. 15, 1994, apparently for administrative reasons.

        All information available to the DNC indicates that Mr. 
        Huang is and at all relevant times has been a U.S. 
        citizen and had a substantial income at this time. No 
        information has been brought to our attention calling 
        into question the legality or appropriateness of the 
        referenced contribution.\183\
---------------------------------------------------------------------------
    \183\ Id. at 28. (emphasis added).

The same response was given regarding Jane Huang's 
contributions.\184\
---------------------------------------------------------------------------
    \184\ Id. at 27.
---------------------------------------------------------------------------
    It has been widely reported that John Huang is presently 
the subject of the DOJ's ``active pending criminal 
investigation into alleged misconduct involving . . . campaign 
finance violations.''\185\ Pursuant to the DNC's own 
guidelines, this information is sufficient to call into 
question the appropriateness of Huang's contributions.\186\ The 
DNC should be aware of the investigation into Huang's fund-
raising activities as a result of the widely-reported DOJ 
investigation of the DNC. Furthermore, the investigation into 
Huang's fund-raising activities has been widely reported in the 
press.
---------------------------------------------------------------------------
    \185\ See generally Exhibit 9 Policies and Procedures of the DNC 
Regarding Compliance with Campaign Finance Laws, at 18-19.
    \186\ Id.
---------------------------------------------------------------------------
    A contribution's link to John Huang is one of the DNC's 
seven categories of contributions applied to determine which 
contributions to review.\187\ ``Contributions solicited by Mr. 
John Huang''--as the DNC put it--were suspicious from the 
inception of the DNC's self-imposed review.\188\ John Huang has 
pled the Fifth Amendment to the Committee \189\ and--except for 
a limited production of documents--both John and Jane Huang 
have refused to cooperate with Committee investigators. The DNC 
returned the contributions individuals solicited by Huang, 
including Kanchanalak, the Wiriadinatas, and the Tries as 
previously indicated but not the Huangs.\190\ Setting aside for 
the moment the issue of legality, if there has ever been a case 
to question the ``appropriateness'' of a contribution, this is 
it. Otherwise, the appropriateness standard is rendered 
meaningless. Furthermore, it is clear from statements of both 
DNC and White House officials that John Huang was dishonest 
with the DNC regarding his contribution vetting procedures and 
information he claimed to have obtained from various 
individuals who were the source of illegal foreign 
contributions.
---------------------------------------------------------------------------
    \187\ The DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 7.
    \188\ Id.
    \189\ Letter from Ty Cobb, Esq., to Chairman Dan Burton, Feb. 18, 
1997 (Exhibit 115).
    \190\ See generally Exhibit 7 DNC List of Contributions Returned or 
Disgorged Produced to the Committee on Nov. 20, 1997, at 2-5 and 7.
---------------------------------------------------------------------------
    It is beyond dispute that John Huang is at the center of 
the current campaign finance scandal and under investigation by 
the DOJ. Much of the money he raised has been determined 
illegal by the DNC itself, DOJ, and House and Senate campaign 
finance investigations. Furthermore, many Members of Congress--
both Democrat and Republican--have returned John and Jane 
Huang's contributions. In any event, the Huangs' contributions 
are highly suspect and, therefore, should be disgorged to the 
U.S. Treasury or returned to the Huangs based on the DNC's own 
criteria of appropriateness.\191\
---------------------------------------------------------------------------
    \191\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

B. Contributions by Other Lippo Employees and Their Spouses During the 
                          1992 Election Cycle

    Shortly before the 1992 Presidential election, in addition 
to James and Aileen Riady and John and Jane Huang, at least 11 
other individuals with direct ties to the Riadys and the Lippo 
Group contributed a total of $200,000 to a variety of 
Democratic causes during September and October 1992. The 
contributions were made in 10 $20,000 blocks, 1 or 2 $20,000 
blocks per family. In every instance, the individuals were 
either a Lippo employee or the spouse of a Lippo employee.
    The DNC supposedly trains its finance staff to look for 
indicia of contributions in the name of another--conduit 
contributions in violation of 2 U.S.C. Sec. 441f. Specifically, 
according to DNC General Counsel Sandler:

        [T]he [indicia] that we typically call [our finance 
        staff's] attention to would be multiple contributions 
        from members--employees of the same corporation; 
        contributions from low-level employees of a corporation 
        or any indication by a donor that a corporation--an 
        individual donor purporting to make a personal 
        contribution, that he or she was going to be reimbursed 
        by a corporation. These are typical indicia of 
        contributions in the name of another.\192\
---------------------------------------------------------------------------
    \192\ Committee Deposition of Joseph E. Sandler, Esq., May 14, 
1998, 23-24 (emphasis added).

As detailed in the following discussion, the timing, amount and 
recipients of the contributions by Lippo employees and their 
spouses suggest that the contributions may have been 
coordinated in some fashion. Notably, many of the contributions 
were directed to the same state--all ``swing states'' except 
Arkansas--Democratic parties, e.g., California, Georgia, 
Louisiana, Michigan, North Carolina, and Ohio. Whether they 
were illegally coordinated remains unanswered. However, at 
least $40,000 of the $200,000 was contributed illegally by Bie 
Chuan Ong and Lucy Jao Ong as discussed below. Given the close 
proximity of the contributions, the existence of troubling 
deposits by some of these contributors immediately prior to the 
contributions, and the fact that most have left the country, 
the Committee believes that there is a sufficient pattern to 
consider all of the contributions illegal or inappropriate. Any 
good faith effort to disgorge illegal or return inappropriate 
contributions would have to include these.

        Bie Chuan Ong $20,000 and Lucy Jao Ong $20,000 (Illegal)

    Bie Chuan Ong is the former Chairman of the Board of 
LippoBank/Bank of Trade \193\ who, in conjunction with his 
wife, Lucy Jao Ong, contributed $40,000 to the DSCC and state 
Democratic parties--some of the same ones targeted by the 
Riadys--during the 1992 election cycle.\194\ In 1991, Bie Chuan 
Ong began serving as a co-director with James Riady and John 
Huang at Hip Hing Holdings.\195\ Bie Chuan Ong's 
responsibilities at Hip Hing Holdings included filing quarterly 
and annual reports pertaining to its real estate activities. 
Hip Hing Holdings owned only one asset, a vacant parking lot on 
Hughes Street in Los Angeles.\196\ His annual salary as an 
executive of Hip Hing Holdings was $24,000.\197\
---------------------------------------------------------------------------
    \193\ Committee Interview of Steve Richmond, July 22, 1997.
    \194\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \195\ Exhibit 35 Hip Hing Holdings, Inc. Certificate of 
Incorporation, State of California, HHH 0243; Hip Hing Holdings Payroll 
Records, HHH 5761, HHH 5758, and HHH 0266 (Exhibit 116); Committee 
Interview of Lucy Jao Ong, Aug. 15, 1997; Committee Interview of Bie 
Chuan Ong, Sept. 9, 1997.
    \196\ Committee Interview of Bie Chuan Ong, Sept. 9, 1997; James 
Warren, ``Funds Hearings Focus on China's Links to Indonesian 
Conglomerate,'' Chicago Tribune, July 16, 1997, at A10.
    \197\ Exhibit 116 Hip Hing Holdings Payroll Records, HHH 5761, HHH 
5758, and HHH 0266.
---------------------------------------------------------------------------
    At the same time he was employed by Hip Hing Holdings, Bie 
Chuan Ong was also a shareholder in Inn Holdings, Inc. (``Inn 
Holdings''),\198\ a California corporation \199\ based in San 
Francisco that serves as the holding company for Marina Inn, an 
inn located in the San Francisco area.\200\ Inn Holdings was 
owned by 23 shareholders at the close of 1992, including Bie 
Chuan Ong and his wife Lucy Jao Ong in addition to John Huang's 
sons, Isaac and Christopher Huang.\201\ As of February 11, 
1996, John Huang owned stock in Inn Holdings valued between 
$15,000-$50,000.\202\
---------------------------------------------------------------------------
    \198\ 1992 U.S. Income Tax Return of Inn Holdings (Exhibit 117). 
These tax records have been heavily redacted due to confidentiality 
concerns.
    \199\ Inn Holdings, Corporate Records, State of California.
    \200\ Committee Interview of Dr. Gilbert Lee, June 19, 1998.
    \201\ Exhibit 117 1992 U.S. Income Tax Return of Inn Holdings Bie 
Chuan Ong is no longer a stockholder in Inn Holdings according to Dr. 
Gilbert Lee, Inn Holdings' registered agent. Committee Interview of Dr. 
Gilbert Lee, June 19, 1998.
    \202\ Executive Branch Personnel Public Financial Disclosure Report 
of John Huang, Feb. 11, 1996, D 0000840-D 0000851, at 6, D 0000846 
(Exhibit 118).
---------------------------------------------------------------------------
    In late September 1992, Four Sisters, a California 
management company, issued a check to Inn Holdings in the 
amount of $40,000 which was deposited into Inn Holdings' 
checking account on September 29, 1992.\203\ On October 20, 
1992, Inn Holdings issued check numbers 1103 and 1104 in the 
amount of $20,000 each to Lucy Jao Ong and Bie Chuan Ong 
respectively.\204\ The checks were allegedly issued so that the 
Ongs could bid on real estate on behalf of Inn Holdings.\205\ 
The memo section of each check bears the notation ``Real Estate 
Auction.'' \206\
---------------------------------------------------------------------------
    \203\ LippoBank Account Statement for Inn Holdings, Oct. 20, 1992 
(Exhibit 119); Committee Interview of Andrew Wong, July 23, 1998.
    \204\ LippoBank/Bank of Trade Check No. 1103 from Inn Holdings to 
Lucy Jao in the amount of $20,000, Oct. 20, 1992, and LippoBank/Bank of 
Trade Check No. 1104 from Inn Holdings to Bie C. Ong in the amount of 
$20,000, Oct. 20, 1992 (Exhibit 120); LippoBank Account Statement of 
Inn Holdings, Nov. 20, 1992 (Exhibit 121).
    \205\ Committee Interview of Dr. Gilbert Lee, June 19, 1998; 
Committee Interview of Andrew Wong, June 24, 1998; Committee Interview 
of Andrew Wong, July 23, 1998.
    \206\ Exhibit 120 LippoBank/Bank of Trade Check No. 1103 from Inn 
Holdings to Lucy Jao [Ong] in the amount of $20,000, Oct. 20, 1992, and 
LippoBank/Bank of Trade Check No. 1104 from Inn Holdings to Bie C. Ong 
in the amount of $20,000, Oct. 20, 1992.
---------------------------------------------------------------------------
    Bank records indicate that Bie and Lucy Ong on October 22, 
1992, deposited the Inn Holdings checks into their personal 
accounts at First Interstate Bank and Security Pacific Bank 
respectively.\207\ And, on or about October 20, 1992, Bie Chuan 
Ong and Lucy Jao Ong then issued a total of eight checks to 
Democratic causes totaling exactly $40,000 as detailed below: 
\208\
---------------------------------------------------------------------------
    \207\ Id.; First Interstate Bank Checking Account Statement of Lucy 
Jao and Bie Chuan Ong, Nov. 5, 1992 (Exhibit 122); First Interstate 
Bank Deposit Ticket in the amount of $20,000 of Lucy Jao Ong and Bie 
Chuan Ong, Oct. 20, 1992 (Exhibit 123).
    \208\ Exhibit 122 First Interstate Bank Checking Account Statement 
of Lucy Jao and Bie Chuan Ong, Nov. 5, 1992; First Interstate Bank 
Check No. 558 from Lucy Jao and Bie Chuan Ong to the Michigan State 
Democratic party in the amount of $5,000, Sept. 30, 1992 (Exhibit 124); 
First Interstate Bank Check No. 559 from Lucy Jao and Bie Chuan Ong to 
the Arkansas State Democratic party in the amount of $5,000, Oct. 19, 
1992 (Exhibit 125); First Interstate Bank Check No. 561 from Lucy Jao 
and Bie Chuan Ong to the California State Democratic party in the 
amount of $5,000, Oct. 9, 1992 (Exhibit 126); Security Pacific Bank 
Check No. 622 from Lucy Jao to the Arkansas State Democratic party in 
the amount of $5,000, Oct. 10, 1992 (Exhibit 127); http://wyl.ewg.org, 
Environmental Working Group Website, Compiled from FEC Data, Last 
Updated Sept. 10, 1998; It should be noted that Bie Chuan Ong listed 
his employer as ``Tons of Toys'' in conjunction with his contributions. 
According to Tiang Hua Ga, Tons of Toys was a company co-owned by Ong 
and a fellow Lippo employee, Joseph Chiang. Committee Interview of 
Tiang Hua Gan, Aug. 15, 1997; see also, Committee Interview of Michael 
Chi, Aug. 28, 1997.

----------------------------------------------------------------------------------------------------------------
                                                  Check                                                         
                     Name                         Date      FEC  Date             Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
Bie Chuan Ong................................    10/09/92    10/21/92  Arkansas Democratic Party......    $5,000
Bie Chuan Ong................................    10/19/92    10/21/92  California Democratic Party....     5,000
Bie Chuan Ong................................  ..........    10/23/92  DSCC...........................     5,000
Bie Chuan Ong................................  ..........    10/23/92  Michigan Democratic Party......     5,000
Lucy Jao Ong.................................    10/10/92    10/21/92  Arkansas Democratic Party......     5,000
Lucy Jao Ong.................................  ..........    10/21/92  California Democratic Party....     5,000
Lucy Jao Ong.................................  ..........    10/22/92  DSCC...........................     5,000
Lucy Jao Ong.................................  ..........    10/23/92  Michigan Democratic Party......     5,000
----------------------------------------------------------------------------------------------------------------

    Notwithstanding the purported purpose--as reflected in the 
memo section of the checks--of the $40,000 from Inn Holdings, 
no real estate was ever purchased with the funds despite the 
passage of 6 years.\209\ Dr. Gilbert Lee, Inn Holdings' 
registered agent, initially described the $40,000 as an advance 
for the purchase of real estate on behalf of Inn Holdings 
consistent with the notation on the checks but subsequently 
during the same interview described the funds as a loan which 
remains outstanding in its entirety.\210\
---------------------------------------------------------------------------
    \209\ Committee Interview of Andrew Wong, June 24, 1998.
    \210\ Committee Interview of Dr. Gilbert Lee, June 19, 1998.
---------------------------------------------------------------------------
    According to Andrew Wong, President of Inn Holdings, he 
approved and signed the checks to Bie Chuan Ong and Lucy Jao 
Ong but is unaware what happened to the money.\211\ However, 
Wong informed a Committee counsel that he had recently spoken 
with Bie Chuan Ong, at which time Ong indicated his intent to 
repay the loan, almost 6 years after its issuance.\212\ Bie 
Chuan Ong never received a salary from and is no longer 
affiliated with Inn Holdings.\213\ Neither Dr. Lee nor Wong 
were aware of any political contributions made by Bie Chuan Ong 
or Lucy Jao Ong.\214\
---------------------------------------------------------------------------
    \211\ Exhibit 120 LippoBank/Bank of Trade Check No. 1103 from Inn 
Holdings to Lucy Jao [Ong] in the amount of $20,000, Oct. 20, 1992, and 
LippoBank/Bank of Trade Check No. 1104 from Inn Holdings to Bie C. Ong 
in the amount of $20,000, Oct. 20, 1992; Committee Interview of Andrew 
Wong, June 24, 1998.
    \212\ Committee Interview of Andrew Wong, June 24, 1998.
    \213\ Committee Interview of Dr. Gilbert Lee, June 19, 1998.
    \214\ Id.; Committee Interview of Andrew Wong, June 24, 1998.
---------------------------------------------------------------------------
    On September 9, 1997, Committee majority and minority 
counsel interviewed Bie Chuan Ong in the presence of his 
attorney regarding his and his wife's political contributions 
totaling $40,000.\215\ He indicated that he knows both John 
Huang and James Riady, with whom he had frequent contact during 
his employ at Hip Hing Holdings.\216\
---------------------------------------------------------------------------
    \215\ Committee Interview of Bie Chuan Ong, Sept. 9, 1997.
    \216\ Id.
---------------------------------------------------------------------------
    When asked if he was aware of Hip Hing Holdings' 
fundraising activities, Ong responded that he ``stayed away 
from that business'' and denied ever having a conversation with 
John Huang regarding fundraising.\217\ According to Ong, he 
never attended a political fundraising event.\218\
---------------------------------------------------------------------------
    \217\ Id.
    \218\ Id.
---------------------------------------------------------------------------
    Bank records and FEC data establish that Bie Chuan Ong and 
Lucy Jao Ong contributed $40,000 to the DSCC and various state 
Democratic parties. However, during the Committee interview, 
Bie Chuan Ong said he did not recall making any political 
contributions in October 1992 even when shown FEC data 
indicating he and his wife had done so.\219\ The $40,000 in 
contributions documented by the Committee did not refresh his 
recollection, but he did claim to have made a $10,000 
contribution with his wife to Dianne Feinstein in early or mid-
1992.\220\ FEC data does not indicate a contribution in any 
amount by Bie Chuan Ong or Lucy Jao Ong to then-Senatorial 
candidate Feinstein in 1992.\221\ It should be noted that it is 
illegal under the Act for an individual to contribute more than 
$1,000 to a U.S. Senate candidate per election, $1,000 primary 
and $1,000 general.\222\
---------------------------------------------------------------------------
    \219\ Id.
    \220\ Id.
    \221\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \222\ 2 U.S.C. Sec. 441a.
---------------------------------------------------------------------------
    During the interview, Ong also advised that he knew former 
Lippo employees Joseph Chiang, Ricor Da Silveira and David Yeh, 
but was unaware of any fund-raising activities by any of these 
individuals and was unaware of their current employment.\223\ 
Ong denied knowing former Lippo employees Felix Ma and Joseph 
Sund.\224\ However, a Tati Group, Ltd.--a Lippo controlled 
---------------------------------------------------------------------------
    \223\ Committee Interview of Bie Chuan Ong, Sept. 9, 1997.
    \224\ Id.
    \225\ Adela Ma, ``Lippo Opts for Leasing,'' South China Morning 
Post, Nov. 16, 1995, at 2.
---------------------------------------------------------------------------
company \225\--memorandum from Joseph Sund to John Huang 
dated March 23, 1993, specifically refers to a ``Bie Ong,'' 
presumably the Bie Chuan Ong at issue here.\226\
---------------------------------------------------------------------------
    \226\ Memorandum from Joseph Sund to John Huang, Mar. 23, 1993, HHH 
4578 and HHH 4579 (Exhibit 128).
---------------------------------------------------------------------------
    A review of the contributions made by Bie Chuan Ong and 
Lucy Jao Ong totaling $40,000 indicates the following:
         1. The funds used for the contributions were provided 
        by Inn Holdings, a company owned in part by John Huang 
        and his sons. Ong's attorney Thomas Zaccarro recently 
        indicated that Ong may have relied on advice from Huang 
        in making the contributions.\227\ ``I'm sure there was 
        some coordination . . . . It's likely that [Huang] may 
        have said to some of his friends, `I think you should 
        contribute to these particular causes,' '' Zaccarro 
        opined; \228\
---------------------------------------------------------------------------
    \227\ Byron York, ``Roots of a Scandal,'' American Spectator, 
October 1998, at 31.
    \228\ Id.
---------------------------------------------------------------------------
          2. The funds were received almost 6 years ago and 
        still have not been used for the purported purpose of 
        purchasing real estate;
          3. Neither Wong nor Dr. Gilbert offered any 
        documentary evidence to indicate that the funds were 
        part of a loan agreement. In fact, the notation on the 
        checks themselves and Committee interviews indicate the 
        contrary;
          4. In a Committee interview, Bie Chuan Ong could not 
        recall having contributed $40,000 in political 
        contributions in conjunction with his wife during the 
        1992 cycle or ever for that matter. The only 
        contribution Bie Chuan Ong recalled making is not in 
        the FEC's records and, regardless, would have been 
        illegal if actually made;
          5. Bie Chuan Ong's annual salary at the time of the 
        contributions was $24,000, making it unlikely that the 
        $40,000 in contributions were made with his own money;
          6. Roger Post, a Four Sisters executive and onetime-
        Inn Holdings stockholder, has failed to return 
        telephone calls made by Committee investigators; and
          7. Bie Chuan Ong invoked his Fifth Amendment 
        privilege against self-incrimination recently in 
        response to the Committee's request to depose him under 
        oath.
    Contributions in the name of another--conduit 
contributions--are illegal. The Act provides that:

        No person shall make a contribution in the name of 
        another person or knowingly permit his name to be used 
        to effect such a contribution, and no person shall 
        knowingly accept a contribution made by one person in 
        the name of another person.\229\
---------------------------------------------------------------------------
    \229\ 2 U.S.C. Sec. 441f.

    In this case, Mr. Ong claimed not to have made 
contributions which originate from his personal bank accounts 
and were made shortly after deposits totaling $40,000 were 
provided by a company with ties to John Huang. Apparently, Inn 
Holdings through Bie Chuan and Lucy Jao Ong contributed $40,000 
to Democratic causes in violation of the Act.
    While the ultimate source of and reason for the conduit 
contributions remains a mystery, there are logical conclusions 
to be drawn: Bie Chuan Ong and Lucy Jao Ong were given $20,000 
each to be used for illegal campaign contributions to the DSCC, 
the Arkansas Democratic party, the California Democratic party, 
and the Michigan Democratic party in violation of 2 U.S.C. 
Sec. 441f. The Ongs' contributions have thus far been retained 
by all recipients, but they should be disgorged to the U.S. 
Treasury in accordance with Federal regulations and DNC 
practice.\230\
---------------------------------------------------------------------------
    \230\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

        Joseph Chiang $20,000 and Donna Chiang $20,000 (Suspect)

    Joseph Chiang is a Lippo executive who, in conjunction with 
his wife, Donna Chiang, contributed $40,000 to the DNC during 
the 1992 election cycle.\231\ As of November 25, 1992, Joseph 
Chiang was the executive director of China Consortium, Ltd., 
the Lippo Group's vehicle for investments in mainland 
China.\232\ A memorandum from John Huang to Jim H. Tuvin dated 
July 9, 1993, listed Felix Ma and Joseph Chiang as points of 
contact at the Lippo controlled Tati Development Limited based 
at the Lippo Centre in Hong Kong.\233\
---------------------------------------------------------------------------
    \231\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \232\ ``Asian Pacific Brief: Lippo to Take Key Stake in Chinese 
Venture,'' The Asian Wall Street Journal, Nov. 25, 1992, at 4.
    \233\ Memorandum from John Huang to Jim H. Tuvin, July 9, 1993 
(Exhibit 129).
---------------------------------------------------------------------------
    On or about September 22, 1992, Joseph and Donna Chiang 
issued four checks to the DNC totaling $40,000 in conjunction 
with the Gore Economic Event on September 25, 1992, as detailed 
below: \234\
---------------------------------------------------------------------------
    \234\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998; Bank of America 
Check No. 7583 from Joseph S. or Donna Chiang to the DNC Victory Fund 
in the amount of $10,000, Sept. 22, 1992 (Exhibit 130); DNC Check 
Tracking Form for Bank of America Check No. 7583 from Joseph S. or 
Donna Chiang to the DNC Victory Fund in the amount of $10,000, Sept. 
22, 1992, DNC 3310331 (Exhibit 131); Bank of America Check No. 7576 
from Joseph S. or Donna Chiang to the DNC Victory Fund in the amount of 
$10,000, Sept. 18, 1992, Bank of America Check No. 7876 from Joseph S. 
or Donna Chiang to the DNC Victory Fund in the amount of $10,000, Sept. 
22, 1992, Bank of America Check No. 7872 from Joseph S. or Donna Chiang 
to the DNC Victory Fund in the amount of $10,000, Sept. 18, 1992 
(Exhibit 132); DNC Check Tracking Form for Bank of America Check No. 
7876 from Joseph S. or Donna Chiang to the DNC Victory Fund in the 
amount of $10,000, Sept. 22, 1992, DNC 3310330 (Exhibit 133); Exhibit 
150 List of DNC Contributors for Sept. 25, 1992, Gore Economic Event, 
DNC 4125867.2. It should be noted that Joseph Chiang listed his 
employer as ``Merchants West'' in conjunction with his Oct. 7, 1992, 
contribution to the DNC. Merchants West is a company specializing in 
the export of various materials from China. Merchants West purchased 
Tons of Toys, a company co-owned by Bie Chuan Ong. Committee Interview 
of Steve Richmond, July 22, 1997. All of Joseph and Donna Chiang's 
contributions for which the Committee has obtained DNC contribution 
information were solicited by Bob Burkett. Exhibit 131 DNC Check 
Tracking Form for Bank of America Check No. 7583 from Joseph S. or 
Donna Chiang to the DNC Victory Fund in the amount of $10,000, Sept. 
22, 1992, DNC 3310331; Exhibit 133 DNC Check Tracking Form for Bank of 
America Check No. 7876 from Joseph S. or Donna Chiang to the DNC 
Victory Fund in the amount of $10,000, Sept. 22, 1992, DNC 3310330.

----------------------------------------------------------------------------------------------------------------
                                                  Check                                                         
                     Name                         Date      FEC Date              Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
Joseph Chiang................................    09/18/92    09/28/92  DNC............................   $10,000
Joseph Chiang................................    09/22/92    10/07/92  DNC............................   $10,000
Donna Chiang.................................    09/18/92    09/28/92  DNC............................   $10,000
Donna Chiang.................................    09/22/92    10/07/92  DNC............................   $10,000
----------------------------------------------------------------------------------------------------------------

    On September 25, 1992, the day of the Gore fund-raiser, L & 
W Supply Global, Inc. (``L & W Supply'') of Anaheim, 
California,\235\ issued a check to Donna Chiang in the amount 
of $40,000,\236\ the precise amount of the Chiangs' 
contributions to the DNC. Ms. Chiang deposited the check into 
her joint account with her husband, Joseph Chiang--the same 
account out of which the four contributions to the DNC were 
made \237\--that same day,\238\ 6 days before any of the 
contributions checks cleared their account.\239\ At the time of 
the deposit, the Chiangs' checking account balance was 
$8,014.64.\240\ In sum, the funds for the Chiangs' 
contributions were provided by L & W Supply Global and thus 
appear to be conduit contributions in violation of 2 U.S.C. 
Sec. 441f.
---------------------------------------------------------------------------
    \235\ Donna Chiang listed L & W Supply as her employer at the time 
of her 1992 contributions to the DNC. http://wyl.ewg.org, Environmental 
Working Group Website, Compiled from FEC Data, Last Updated Sept. 10, 
1998.
    \236\ Bank of America Check No. 121 from L & W Supply to Donna 
Chiang in the amount of $40,000, Sept. 25, 1992, and Bank of America 
Deposit Ticket of Joseph S. or Donna Chiang in the amount of $40,000, 
Sept. 25, 1992 (Exhibit 134). Donna Chiang also received a check from L 
& W Supply in the amount of $8,000, Aug. 25, 1992, for an unknown 
reason. Bank of America Check No. 1281 from L & W Supply to Donna 
Chiang in the amount of Aug. 25, 1992, and Bank of America Deposit 
Ticket of Joseph S. or Donna Chiang in the amount of $8,000, Aug. 25, 
1992 (Exhibit 135).
    \237\ Exhibit 130 Bank of America Check No. 7583 from Joseph S. or 
Donna Chiang to the DNC Victory Fund in the amount of $10,000, Sept. 
22, 1992; Exhibit 131 DNC Check Tracking Form for Bank of America Check 
No. 7583 from Joseph S. or Donna Chiang to the DNC Victory Fund in the 
amount of $10,000, Sept. 22, 1992, DNC 3310331; Exhibit 132 Bank of 
America Check No. 7576 from Joseph S. or Donna Chiang to the DNC 
Victory Fund in the amount of $10,000, Sept. 18, 1992, Bank of America 
Check No. 7876 from Joseph S. or Donna Chiang to the DNC Victory Fund 
in the amount of $10,000, Sept. 22, 1992, and Bank of America Check No. 
7872 from Joseph S. or Donna Chiang to the DNC Victory Fund in the 
amount of $10,000, Sept. 18, 1992; Exhibit 133 DNC Check Tracking Form 
for Bank of America Check No. 7876 from Joseph S. or Donna Chiang to 
the DNC Victory Fund in the amount of $10,000, Sept. 22, 1992, DNC 
3310330; Bank of America Account Statement of Joseph, Donna and 
Josephine Chiang, Oct. 29, 1992 (Exhibit 136).
    \238\ Exhibit 134 Bank of America Check No. 121 from L & W Supply 
to Donna Chiang in the amount of $40,000, Sept. 25, 1992, and Bank of 
America Deposit Ticket of Joseph S. or Donna Chiang in the amount of 
$40,000, Sept. 25, 1992; Bank of America Account Statement of Joseph or 
Donna Chiang, Sept. 29, 1992 (Exhibit 137).
    \239\ Exhibit 136 Bank of America Account Statement of Joseph, 
Donna and Josephine Chiang, Oct. 29, 1992.
    \240\ Exhibit. 137 Bank of America Account Statement of Joseph or 
Donna Chiang, Sept. 29, 1992.
---------------------------------------------------------------------------
    The Chiangs are believed to be residing in Hong Kong. The 
Committee has been unable to contact Joseph and Donna Chiang or 
identify the ultimate source of the funds used for the 
contributions but is continuing its review.
    Again, the Chiangs' 1992 contributions were made at the 
same time as the Riadys' contributions and other illegal 
contributions from Lippo related individuals, e.g., Bie and 
Lucy Jao Ong. The DNC has retained the Chiangs' contributions 
totaling $40,000.\241\ However, the Chiangs' contributions 
appear to be conduit contributions in violation of 2 U.S.C. 
Sec. 441f and, therefore, should be disgorged to the U.S. 
Treasury.\242\
---------------------------------------------------------------------------
    \241\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \242\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

   Ricor Da Silveira $15,000 and Brenda Da Silveira $5,000 (Suspect)

    Ricor Da Silveira is a Lippo executive who, in conjunction 
with his wife, Brenda Da Silveira, contributed $20,000 to the 
DSCC and state Democratic parties--many of the same ones 
targeted by the Riadys-during the 1992 election cycle.\243\ 
Ricor Da Silviera has served as an executive for several Lippo 
controlled companies.\244\ In 1992, he served as an executive 
at Hip Hing Holdings, but became Morning Star, Inc.'s finance 
director after its acquisition by Lippo on December 28, 
1992.\245\ After Lippo sold its interest in Morning Star on 
December 8, 1993, he became a director of Lippo Asia, Ltd.\246\ 
As early as November 3, 1996, and as recent as August 12, 1997, 
he was serving as the managing director of Lippo Investments 
Management based in Hong Kong and a director in other Lippo 
related companies including Guo Tai Lippo Securities, Edmund de 
Rothschild Lippo Company, Ltd., and Weyfang Yongchange Food 
Industries in China.\247\
---------------------------------------------------------------------------
    \243\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \244\ Although it is unclear whether Ricor Da Silveira was employed 
by James Riady in Arkansas, It appears from press reports that Ricor 
and Brenda Da Silveira owned property in 1985, during the period that 
James Riady was involved with Stephens, Inc. ``Deeds,'' Arkansas 
Gazette, June 23, 1985, at D7.
    \245\ Rosa Ocampo, ``Morning Star Trying to Rise As China Play,'' 
South China Morning Post, Dec. 29, 1992, at 3.
    \246\ Amy Chew, ``MUI accepts Lippo explanation,'' South China 
Morning Post, June 4, 1994, at 2; ``HK's Lippo Unit/China/Fund--Full 
Investment by 7th Year,'' Dow Jones International News, July 12, 1995.
    \247\ Tan Lee Hock, ``Indonesia Has Made It Harder to Punt on the 
Currency, But Many Still See Worthwhile Gains,'' South China Morning 
Post, Nov. 3, 1996, at 9.
---------------------------------------------------------------------------
    During the period October 19-22, 1992, Ricor and Brenda 
DaSilviera issued four checks to Democratic causes totaling 
$20,000 as detailed below: \248\
---------------------------------------------------------------------------
    \248\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998. LippoBank Checking 
Account Statement of Ricor F. Da Silveira and Brenda W. Da Silveira, 
Nov. 16, 1992, L 010807 (Exhibit 138); LippoBank Check No. 2203 from 
Ricor F. or Brenda W. Da Silveira to the DSCC in the amount of $5,000, 
Oct. 19, 1992, and LippoBank Check No. 2206 from Ricor F. or Brenda W. 
Da Silveira to the DSCC in the amount of $5,000, Oct. 19, 1992, L 
010816 and L 010817 (Exhibit 139); LippoBank Check No. 2224 from Ricor 
F. or Brenda W. Da Silveira to the DSCC in the amount of $5,000, Oct. 
22, 1992, L 010818 and L 010819 (Exhibit 140); LippoBank Check No. 2209 
from Ricor F. or Brenda W. Da Silveira to the Michigan State Democratic 
party in the amount of $5,000, Oct. 21, 1992, L 010820 and L 010821 
(Exhibit 141). In addition, Ricor DaSilviera contributed $1,000 to Sen. 
Edward M. Kennedy in March 1993.

----------------------------------------------------------------------------------------------------------------
                     Name                      Check Date   FEC Date              Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
Ricor Da Silveira............................    10/19/92    10/27/92  DSCC...........................    $5,000
Ricor Da Silveira............................    10/21/92    10/27/92  Michigan Democratic Party......    $5,000
Ricor Da Silveira............................    10/22/92    10/27/92  Arkansas Democratic Party......    $5,000
Brenda Da Silveira...........................    10/19/92    10/27/92  DSCC...........................    $5,000
----------------------------------------------------------------------------------------------------------------

    Ricor Da Silveira's annual salary as an executive of Hip 
Hing Holdings was between $63,000 and $88,200 at the time of 
the 1992 contributions.\249\
---------------------------------------------------------------------------
    \249\ Exhibit 116 Hip Hing Holdings Payroll Records, HHH 5761, HHH 
5758, and HHH 0266.
---------------------------------------------------------------------------
    Within days of issuing the checks, Ricor and Brenda Da 
Silveira received two wire transfers in the amount of $9,500 
and $9,300, on October 27, 1992, and October 28, 1992, 
respectively into their joint account at LippoBank.\250\ Both 
wire transfers originated from Ricor DaSilviera's bank account 
at the Hong Kong Chinese Bank,\251\ a bank located in Hong Kong 
and controlled by the Riadys and the Chinese government.\252\ 
To date, the Committee has received no cooperation from any 
foreign banks or foreign governments in obtaining bank records 
which would enable to the Committee to trace the ultimate 
origin of the funds.
---------------------------------------------------------------------------
    \250\ LippoBank Wire Transfer Records of Ricor F. Da Silviera, Oct. 
27, 1992 (Exhibit 142) and LippoBank Wire Transfer Records of Ricor F. 
Da Silviera, Oct. 28, 1992 (Exhibit 143).
    \251\ Id.
    \252\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 1, 
1120 (1998).
---------------------------------------------------------------------------
    The Committee has been unable to contact Ricor and Brenda 
Da Silveira or identify the ultimate source of the funds used 
for the contributions but is continuing its review. The DSCC, 
the Arkansas Democratic party, and the Michigan Democratic 
party have retained the Da Silveiras' contributions.\253\ 
However, the Da Silveiras' contributions are suspect and, 
therefore, the contributions should be disgorged to the U.S. 
Treasury.\254\
---------------------------------------------------------------------------
    \253\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \254\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

         David Yeh $20,000 and Christina Yeh $20,000 (Suspect)

    David Yeh is a Lippo executive who, in conjunction with his 
wife, Christina Yeh, contributed $40,000 to the DNC during the 
1992 election cycle.\255\ David Yeh's relationship with the 
Riadys predates 1984 at which time the directors of Worthen 
Bank based in Little Rock, Arkansas, named James Riady 
president.\256\ Worthen then allowed Riady to bring some of his 
Lippo employees from Asia to Little Rock.\257\ One member of 
that team was David Yeh who was placed in charge of Worthen's 
international division with offices in New York and Los 
Angeles.\258\ In that position, Yeh earned $187,000, one of the 
five highest paid officers at Worthen.\259\ In late 1986, Yeh 
was fired by the Worthen board, and the Worthen international 
unit was dissolved.\260\
---------------------------------------------------------------------------
    \255\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \256\ Paul Sperry, ``National Issue Worthen: A Riady Piggy Bank?,'' 
Investor's Business Daily, Dec. 30, 1996, at A1.
    \257\ Id.
    \258\ Id.
    \259\ Id.
    \260\ Id.
---------------------------------------------------------------------------
    In the early 1990s, David Yeh served as the president of 
LippoBank, Los Angeles,\261\ and in September 1993, he served 
as the Managing Director of Lippo Realty, Ltd. believed to be 
located in Hong Kong.\262\
---------------------------------------------------------------------------
    \261\ Committee Interview of Bie Chuan Ong, Sept. 9, 1997.
    \262\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998; see generally 
Susan Schmidt and Sharon LaFraniere, ``Counsel Probes Lippo Links at 
White House,'' the Washington Post, Mar. 5, 1997, at A1.
---------------------------------------------------------------------------
    On or about August 18, 1992, David and Christina Yeh issued 
eight checks to the DNC totaling $40,000 in conjunction with 
the Gore Economic Event fund-raiser held on September 29, 1992, 
as detailed below: \263\
---------------------------------------------------------------------------
    \263\ Bank of America Check No. 206 from David and Christina M.K. 
Yeh to the DNC Victory Fund in the amount of $5,000, Aug. 3, 1992, Bank 
of America Check No. 207 from David and Christina M.K. Yeh to the DNC 
Victory Fund in the amount of $5,000, Aug. 8, 1992, and Bank of America 
Check No. 209 from David and Christina M.K. Yeh to the DNC Victory Fund 
in the amount of $5,000, Aug. 18, 1992 (Exhibit 144); Bank of America 
Check No. 249 from David and Christina M.K. Yeh to Woo for Mayor in the 
amount of $1,000, May 23, 1993, Bank of America Check No. 245 from 
David and Christina M.K. Yeh to Woo for mayor in the amount of $1,000, 
May 22, 1993, and Bank of America Check No. 208 from David and 
Christina M.K. Yeh to the DNC Victory Fund in the amount of $5,000, 
Aug. 18, 1992 (Exhibit 145); DNC Check Tracking Form for Bank of 
America Check No. 208 from David and Christina M.K. Yeh to the DNC 
Victory Fund in the amount of $5,000, Aug. 18, 1992, DNC 3310341 
(Exhibit 146); DNC Check Tracking Form for Bank of America Check No. 
209 from David and Christina M.K. Yeh to the DNC Victory Fund in the 
amount of $5,000, Aug. 18, 1992, DNC 3310342 (Exhibit 147); DNC Check 
Tracking Form for LippoBank Check No. 943 from David and Christina M. 
K. Yeh to the DNC Victory Fund in the amount of $5,000, Aug. 23, 1992, 
DNC 3310339 (Exhibit 148); DNC Check Tracking Form for LippoBank Check 
No. 944 from David and Christina M.K. Yeh to the DNC Victory Fund in 
the amount of $5,000, Aug. 28, 1992, DNC 3310340 (Exhibit 149); List of 
DNC Contributors for Sept. 29, 1992, Gore Economic Event, DNC 4125867.2 
and DNC 4125867.3 (Exhibit 150); http://wyl.ewg.org, Environmental 
Working Group Website, Compiled from FEC Data, Last Updated Sept. 10, 
1998. All of David and Christina Yeh's 1992 contributions for which the 
Committee has obtained DNC contribution information were solicited by 
Bob Burkett. Exhibit 146 DNC Check Tracking Form for Bank of America 
Check No. 208 from David and Christina M.K. Yeh to the DNC Victory Fund 
in the amount of $5,000, Aug. 18, 1992, DNC 3310341; Exhibit 147 DNC 
Check Tracking Form for Bank of America Check No. 209 from David and 
Christina M.K. Yeh to the DNC Victory Fund in the amount of $5,000, 
Aug. 18, 1992, DNC 3310342; Exhibit 148 DNC Check Tracking Form for 
Bank of America Check No. 943 from David and Christina M.K. Yeh to the 
DNC Victory Fund in the amount of $5,000, Aug. 23, 1992, DNC 3310339; 
Exhibit 149 DNC Check Tracking Form for Bank of America Check No. 944 
from David and Christina M.K. Yeh to the DNC Victory Fund in the amount 
of $5,000, Aug. 28, 1992, DNC 3310340. David Yeh's annual salary as an 
executive of Hip Hing Holdings was $73,333 as of Dec. 28, 1990. Exhibit 
116 Hip Hing Holdings Payroll Records, HHH 5761 and HHH 5758.

----------------------------------------------------------------------------------------------------------------
                                                  Check                                                         
                     Name                         Date      FEC Date              Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
David Yeh....................................    08/03/92    09/29/92  DNC............................    $5,000
David Yeh....................................    08/08/92    09/29/92  DNC............................    $5,000
David Yeh....................................    08/18/92    10/07/92  DNC............................    $5,000
David Yeh....................................    08/18/92    10/07/92  DNC............................    $5,000
Christina Yeh................................  ..........    09/29/92  DNC............................    $5,000
Christina Yeh................................  ..........    09/29/92  DNC............................    $5,000
Christina Yeh................................  ..........    10/07/92  DNC............................    $5,000
Christina Yeh................................  ..........    10/07/92  DNC............................    $5,000
----------------------------------------------------------------------------------------------------------------

    On September 21, 1992--before any of his 1992 contribution 
checks to the DNC cleared his account\264\--David Yeh received 
a wire transfer in the amount of $19,985 into his checking 
account at Bank of America.\265\ His account balance was 
$3,368.63 at the time of the transfer.\266\ The wire transfer 
originated from an unidentified account within the United 
States.\267\
---------------------------------------------------------------------------
    \264\ Bank of America Account Statement for David and Christina 
M.K. Yeh, Oct. 8, 1992 (Exhibit 151); Bank of America Account Statement 
for David and Christina M.K. Yeh, Nov. 5, 1992 (Exhibit 152).
    \265\ Exhibit 151 Bank of America Account Statement for David and 
Christina M.K. Yeh, Oct. 8, 1992. In addition to David and Christina 
Yeh, Lippo employee Ricor Da Silveira is a signatory on the personal 
checking account of the Yehs held at Bank of America. Bank of America 
Master Agreement (Exhibit 153).
    \266\ Id.
    \267\ Bank of America was unable to locate the wire transfer report 
for this transaction. Bank of America Subpoena Processing Department 
No. 5473 List of Requested Items Not Produced to the Committee, Sept. 
29, 1998 (Exhibit 154). As a result, the only information available to 
the Committee regarding this $19,985 wire transfer is detailed on the 
account statement. The wire transfer appears to be a domestically 
initiated transaction rather than an internationally initiated 
transaction because it is described as a ``fedwire'' rather than an 
``international money transfer,'' the description given to wire 
transfers originating abroad. Exhibit 151 Bank of America Account 
Statement for David and Christina M.K. Yeh, Oct. 8, 1992; cf. Bank of 
America Account Statement for David and Christina M.K. Yeh, Oct. 7, 
1993 (Exhibit 155).
---------------------------------------------------------------------------
    Christina Yeh made her 1992 contributions from her and 
David Yeh's checking account at LippoBank.\268\ The Committee 
has subpoenaed her bank records and is awaiting their delivery.
---------------------------------------------------------------------------
    \268\ See Exhibit 148 DNC Check Tracking Form for LippoBank Check 
No. 943 from David and Christina M.K. Yeh to the DNC Victory Fund in 
the amount of $5,000, Aug. 23, 1992, DNC 3310339; Exhibit 149 DNC Check 
Tracking Form for LippoBank Check No. 944 from David and Christina M.K. 
Yeh to the DNC Victory Fund in the amount of $5,000, Aug. 28, 1992, DNC 
3310340.
---------------------------------------------------------------------------
    In addition to the foregoing, the Yehs contributed an 
additional $20,000 to the DNC \269\ and $12,000 to 
congressional and senatorial candidates between 1990 and 
1994.\270\
---------------------------------------------------------------------------
    \269\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998. On Sept. 28, 
1993--before his Sept. 27, 1993, check to the DNC cleared his account, 
David Yeh received a wire transfer in the amount of $20,000 into his 
checking account at the Bank of America. Bank of America Check No. 0104 
from David and Christina M.K. Yeh to the DNC in the amount of $10,000, 
Sept. 27, 1993, and Bank of America Check No. 0105 from David and 
Christina M.K. Yeh to the DNC in the amount of $10,000, Sept. 27, 1993 
(Exhibit 156); Exhibit 155 Bank of America Account Statement for David 
and Christina M.K. Yeh, Oct. 7, 1993; Bank of America Account Statement 
of David and Christina M.K. Yeh, Nov. 5, 1993 (Exhibit 157); Bank of 
America Wire Transfer Report of David and Christina M.K. Yeh, Sept. 28, 
1993 (Exhibit 158). His account balance was $13,050.47 at the time of 
the transfer. Exhibit 155 Bank of America Account Statement for David 
and Christina M.K. Yeh, Oct. 7, 1993. The wire transfer originated from 
what appears to be David Yeh's bank account at the Hong Kong Chinese 
Bank, a bank located in Hong Kong and controlled by the Riadys and the 
Chinese Government. Exhibit 158 Bank of America Wire Transfer Report of 
David and Christina M.K. Yeh, Sept. 28, 1993; Investigation of Illegal 
or Improper Activities in Connection with the 1996 Federal Election 
Campaign Before the Senate Committee on Governmental Affairs, S. Rept. 
No. 167, 195th Cong., 2d sess., vol. 1, 1120 (1998).
    \270\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998; David Yeh: Sept. 
28, 1990, $1,000 to Senator Harvey B. Gantt; June 10, 1993, $1,000 to 
Senator Charles S. Robb; Oct. 15, 1993, $10,000 to the DNC; Oct. 25, 
1993, $1,000 to Senator James R. Sasser (D-TN); Dec. 23, 1993, $1,000 
to Senator Larry Pressler (R-SD); May 23, 1994, $1,000 to 
Representative Joseph P. Kennedy (D-MA-8); Sept. 30, 1994, $1,000 to 
Representative Mark Takano (D-CA-43); Oct. 11, 1994, $2,000 to the 
Effective Government Committee. Christina Yeh: June 10, 1993, $1,000 to 
Senator Charles S. Robb (D-VA); Oct. 15, 1993, $10,000 to the DNC; Oct. 
25, 1993, $1,000 to Senator James R. Sasser (D-TN); Dec. 23, 1993, 
$1,000 to Senator Larry Pressler (R-SD); May 23, 1994, $1,000 to 
Representative Joseph P. Kennedy (D-MA-8); Exhibit Bank of America 
Check No. 0104 from David and Christina M.K. Yeh to the DNC in the 
amount of $10,000, Sept. 27, 1993, and Bank of America Check No. 0105 
from David and Christina M.K. Yeh to the DNC in the amount of $10,000, 
Sept. 27, 1993; DNC Check Tracking Form for Bank of America Check No. 
0104 from David and Christina M.K. Yeh to the DNC in the amount of 
$10,000, Sept. 27, 1993, DNC 0039320 (Exhibit 159); DNC Check Tracking 
Form for Bank of America Check No. 0105 from David and Christina M.K. 
Yeh to the DNC in the amount of $10,000, Sept. 27, 1993, DNC 0039322 
(Exhibit 160). See also Bank of America Check No. 283 from David and 
Christina M.K. Yeh to Citizens for Joe Kennedy in the amount of $1,000, 
Apr. 18, 1994, Bank of America Check No. 285 from David and Christina 
M.K. Yeh to Citizens for Joe Kennedy in the amount of $1,000, Apr. 18, 
1994, and Bank of America Check No. 0112 from David and Christina M.K. 
Yeh to Gray Davis 1994 Committee in the amount of $1,000, Nov. 30, 1993 
(Exhibit 161); Bank of America Check No. 0115 from David and Christina 
M.K. Yeh to Friends of Larry Pressler in the amount of $1,000, Dec. 1, 
1993, Bank of America Check No. 0117 from David and Christina M.K. Yeh 
to Friends of Larry Pressler in the amount of $1,000, Dec. 1, 1993, and 
Bank of America Check No. 0114 from David and Christina M.K. Yeh to 
Gray Davis 1994 Committee in the amount of $1,000, Nov. 30, 1993 
(Exhibit 162); Bank of America Check No. 0101 from David and Christina 
M.K. Yeh to Sasser for Senate Committee in the amount of $1,000, Sept. 
16, 1993, Bank of America Check No. 246 from David and Christina M.K. 
Yeh to Friends of Robb for Senate in the amount of $1,000, May 22, 
1993, and Bank of America Check No. 250 from David and Christina M.K. 
Yeh to Robb for Senate in the amount of $1,000, May 23, 1993 (Exhibit 
163).
---------------------------------------------------------------------------
    The Yehs' 1993 contributions to the DNC totaling $20,000 
were made in conjunction with the September 27, 1993, dinner 
featuring Vice President Al Gore.\271\ Both David and Christina 
Yehs' $10,000 contributions were solicited by John Huang.\272\ 
According to DNC documents relating to that event, David Yeh 
was a ``permanent U.S. citizen living abroad'' at the time of 
the contribution.\273\
---------------------------------------------------------------------------
    \271\ Exhibit 159 DNC Check Tracking Form for Bank of America Check 
No. 0104 from David and Christina M.K. Yeh to the DNC in the amount of 
$10,000, Sept. 27, 1993, DNC 0039320; Exhibit 160 DNC Check Tracking 
Form for Bank of America Check No. 0105 from David and Christina M.K. 
Yeh to the DNC in the amount of $10,000, Sept. 27, 1993, DNC 0039322.
    \272\ Id.
    \273\ Id.
---------------------------------------------------------------------------
    Former Lippo executive Bie Chuan Ong told Committee 
counsels that he knows David Yeh but is unaware of any fund-
raising activities by Yeh and is unaware of his current 
employment.\274\ The Committee believes that David and 
Christina Yeh are currently residing in Hong Kong and have been 
there since 1992.\275\ According to press accounts and former 
Lippo executive Charles DeQueljoe, as of June 1998, David Yeh 
was serving as executive director of Lippo Limited in Hong 
Kong.\276\
---------------------------------------------------------------------------
    \274\ Committee Interview of Bie Chuan Ong, Sept. 9, 1997.
    \275\ Committee Interview of Betty Wong, Aug. 18, 1997.
    \276\ Joseph Lo, ``Lippo Chief Rules Out Expansion,'' South China 
Morning Post, June 30, 1998, at 2; see also, Committee Deposition of 
Charles DeQueljoe, 53-54.
---------------------------------------------------------------------------
    In recent interrogatories to the DNC, the Committee 
requested information regarding contributions made by David 
Yeh. The DNC responded:

        To our knowledge, the referenced contribution from 
        David Yeh does not fall into any of the seven 
        categories involved in the DNC's review of prior 
        contributions. . . . Further, no information has been 
        brought to our attention calling into question the 
        legality or appropriateness of Mr. Yeh's 
        contribution.\277\
---------------------------------------------------------------------------
    \277\ DNC Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, 19-20.

The same response was given regarding Christina Yeh's 
contributions.\278\ The DNC has retained the Yehs' 
contributions.
---------------------------------------------------------------------------
    \278\ Id. at 18-19.
---------------------------------------------------------------------------
    The Committee has been unable to identify the ultimate 
source of the funds used for the contributions because the Yehs 
are residing outside the United States, but the Committee is 
continuing its review of their contributions. That fact 
notwithstanding, on March 19, 1997, House Minority Leader Dick 
Gephardt returned $22,000 in campaign contributions, which 
included $2,000 contributed by Lippo executive David Yeh.\279\ 
Gephardt returned an additional $10,500 contributed by other 
individuals with ties to Lippo, including Agus Setiawan, 
$2,000; Joseph Sund, $2,500; Susanto Widjaja, $1,000; and 
Charles and Susan DeQueljoe, $5,000.\280\ According to 
Gephardt's press secretary, Laura Nichols, ``[Gephardt] didn't 
feel it would be appropriate to retain those contributions. . . 
. There is a question about the actual source of these funds.'' 
\281\
---------------------------------------------------------------------------
    \279\ ``Gephardt Returns $22,000,'' Associated Press, Mar. 19, 
1997.
    \280\ Id.
    \281\ Id. (emphasis added).
---------------------------------------------------------------------------
    FEC data indicates that David and Christina Yeh each 
contributed $1,000 to Senator Larry Pressler in December 
1993.\282\ Senator Pressler returned the Yehs' contributions in 
October 1996,\283\ apparently upon learning of their potential 
link to the Lippo Group.\284\ In May 1994, Representative 
Joseph Kennedy received $1,000 contributions from both David 
and Christina Yeh but returned the contributions in February 
and March 1997 respectively.\285\
---------------------------------------------------------------------------
    \282\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \283\ Id.
    \284\ Rapid City Journal, Mar. 16, 1997.
    \285\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
---------------------------------------------------------------------------
    As previously indicated, the DNC has retained the Yehs' 
contributions totaling $60,000. However, applying the DNC's own 
standards of review, given the unavailability of the Yehs and 
the questionable status of these contributions, the DNC should 
follow the practice of House Minority Leader Richard Gephardt, 
Representative Joseph Kennedy and Senator Pressler: the Yehs' 
contributions are suspect and, therefore, should be disgorged 
to the U.S. Treasury.\286\
---------------------------------------------------------------------------
    \286\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

             Felix Ma $15,000 and Mary Ma $25,000 (Suspect)

    During August and September 1992, Felix Ma, a Lippo 
executive,\287\ in conjunction with his wife, Mary Ma, issued 
eight checks to the DSCC and various state Democratic parties--
many of the same ones targeted by the Riadys--totaling $40,000 
as detailed below: \288\
---------------------------------------------------------------------------
    \287\ See Memorandum from John Huang to M.C. Lee and Felix Ma, Aug. 
24, 1993 (Exhibit 164).
    \288\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998; DNC Check Tracking 
Form for LippoBank Check No. 189 from Felix or Mary L.M. Ma to the Ohio 
State Democratic party Federal Account in the amount of $5,000, Sept. 
30, 1992 (Exhibit 165); Ohio State Democratic party Check Tracking Form 
for Check No. 239 from Felix or Mary L.M. Ma to the Ohio State 
Democratic party in the amount of $5,000, Sept. 20, 1992 (Exhibit 166); 
LippoBank Check No. 239 from Felix or Mary L.M. Ma to the Ohio State 
Democratic party in the amount of $5,000, Sept. 20, 1992 (Exhibit 167); 
LippoBank Check No. 195 from Felix or Mary L.M. Ma to the DSCC in the 
amount of $5,000, Sept. 25, 1992, and LippoBank Check No. 196 from 
Felix or Mary L.M. Ma to the DSCC in the amount of $5,000, Sept. 30, 
1992 (Exhibit 168); LippoBank Check No. 194 from Felix or Mary L.M. Ma 
to the Michigan State Democratic party in the amount of $5,000, Sept. 
15, 1992 (Exhibit 169); LippoBank Check No. 189 from Felix or Mary L.M. 
Ma to the Ohio State Democratic party in the amount of $5,000, Sept. 
30, 1992, LippoBank Check No. 186 from Felix or Mary L.M. Ma to the 
DSCC in the amount of $5,000, Aug. 30, 1992, and LippoBank Check No. 
187 from Felix or Mary L.M. Ma to the Michigan State Democratic party 
in the amount of $5,000, Sept. 10, 1992 (Exhibit 170); LippoBank 
Checking Account Statement of Felix Ma or Mary L.M. Ma, Sept. 25, 1992 
(Exhibit 171); LippoBank Checking Account Statement of Felix Ma or Mary 
L.M. Ma, Oct. 26, 1992 (Exhibit 172); LippoBank Checking Account 
Statement of Felix Ma or Mary L.M. Ma, Nov. 25, 1992 (Exhibit 173).

----------------------------------------------------------------------------------------------------------------
                                                Check                                                           
                    Name                        Date      FEC Date              Recipient               Amount  
----------------------------------------------------------------------------------------------------------------
Felix Ma...................................    08/30/92    10/23/92  DSCC..........................       $5,000
Felix Ma...................................    09/10/92    10/23/92  Michigan Democratic Party.....        5,000
Felix Ma...................................    09/30/92    10/23/92  Ohio Democratic Party.........        5,000
Mary Ma....................................    09/15/92    10/27/92  Michigan Democratic Party.....        5,000
Mary Ma....................................    09/25/92    10/22/92  DSCC..........................  \289\ 5,000
Mary Ma....................................    09/30/92  ..........  DSCC..........................  \290\ 5,000
Mary Ma....................................  ..........    10/23/92  Missouri Democratic Party.....  \291\ 5,000
Mary Ma....................................  ..........    10/28/92  Ohio Democratic Party.........        5,000
----------------------------------------------------------------------------------------------------------------
\289\ Contrary to FEC data, bank records indicate that this contribution was made by Mary Ma not Felix Ma. This 
  discrepancy appears to be an administrative error. Exhibit 168 LippoBank Check No. 195 from Felix or Mary L.M.
  Ma to the DSCC in the amount of $5,000, Sept. 25, 1992.                                                       
\290\ The FEC data does not list Mary Ma's $5,000 contribution to the DSCC although her bank records indicate   
  that she did contribute to the DSCC, and the DSCC did negotiate the check. This appears to be an              
  administrative error. See Ex. 168 LippoBank Check No. 196 from Felix or Mary L.M. Ma to the DSCC in the amount
  of $5,000, Sept. 30, 1992.                                                                                    
\291\ The FEC data indicates that Felix Ma contributed $5,000 to the Missouri Democratic party, but the Mas'    
  bank records do not confirm that. This appears to be an administrative error. http://wyl.ewg.org,             
  Environmental Working Group Website, Compiled from FEC Data, Last Updated Sept. 10, 1998.                     

    On the DNC's information card for Felix Ma's contribution 
to the Ohio Democratic party, he described himself as the 
director of Lippo Hong Kong \292\ and as of March 1993, 
continued to serve in that position.\293\
---------------------------------------------------------------------------
    \292\ Exhibit 165 DNC Check Tracking Form for LippoBank Check No. 
189 from Felix or Mary L.M. Ma to the Ohio State Democratic party 
Federal Account in the amount of $5,000, Sept. 30, 1992.
    \293\ Kenneth Ko, ``Henderson in $2.43b Yantai deal,'' South China 
Morning Post, Mar. 27, 1993, at 2.
---------------------------------------------------------------------------
    The funds used for the $40,000 in contributions detailed 
above appear to have originated, at least in part, with 
California Land Merchants, a company currently under review by 
the Committee.\294\ A check issued by California Land Merchants 
totaling $15,000 was deposited into the LippoBank account of 
Felix and Mary Ma on September 10, 1992.\295\ An additional 
$15,000 from an unidentified source was deposited in that same 
account on September 2, 1992.\296\
---------------------------------------------------------------------------
    \294\ A deposit of check no. 295 from California Land Merchants in 
the amount of $15,000 was deposited into the LippoBank account of Felix 
and Mary Ma on Sept. 3, 1992. The check bounced and was re-deposited on 
Sept. 10, 1992. Exhibit 171 LippoBank Checking Account Statement of 
Felix Ma or Mary L.M. Ma, Sept. 25, 1992; LippoBank Deposit Ticket in 
the amount of $15,000 of Felix Ma or Mary L.M. Ma, Sept. 3, 1992, and 
Sierra National Bank Check No. 295 from California Land Merchants to 
Felix and Mary Ma in the amount of $15,000, Sept. 1, 1992, (Exhibit 
174); LippoBank Deposit Ticket of Felix Ma or Mary L.M. Ma in the 
amount of $15,000, Sept. 10, 1992, and Sierra National Bank Check from 
California Land Merchants to Felix and Mary Ma in the amount of 
$15,000, Sept. 1, 1992 (Exhibit 175).
    \295\ Id.
    \296\ LippoBank Deposit Ticket of Felix Ma or Mary L.M. Ma in the 
amount of $15,000, Sept. 2, 1992, and a Check to Felix or Mary Ma from 
an illegible source in the amount of $15,000, date illegible (Exhibit 
176).
---------------------------------------------------------------------------
    On August 24, 1993, John Huang wrote a memorandum to Felix 
Ma which states in pertinent part:

        Senator Larry Pressler is coming to Shanghai. See if we 
        might be able to arrange a dinner in Shanghai for him 
        on Tuesday, August 31, 1993 at 6:00 p.m.\297\
---------------------------------------------------------------------------
    \297\ Exhibit Memorandum from John Huang to M.C. Lee and Felix Ma, 
Aug. 24, 1993.

    FEC data indicates that Felix and Mary Ma each contributed 
$1,000 to Senator Larry Pressler in December 1993.\298\ Senator 
Pressler returned the Mas' contributions in October 1996 \299\ 
apparently upon learning of their link to the Lippo Group.\300\ 
In addition to the foregoing, the Mas contributed $20,000 to 
the DNC and $15,500 to congressional and senatorial candidates 
between 1993 and 1995.\301\
---------------------------------------------------------------------------
    \298\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \299\ Id.
    \300\ Rapid City Journal, Mar. 16, 1997.
    \301\ Felix Ma: June 10, 1993, $1,000 to Senator Charles S. Robb 
(D-VA); July 17, 1993, $1,000 to Representative Gary L. Ackerman (D-NY-
7); Aug. 10, 1993, $1,000 to Senator Harris L. Wofford (D-PA); Oct. 15, 
1993, $10,000 to the DNC; Oct. 25, 1993, $1,000 to Senator James R. 
Sasser (D-TN); Dec. 6, 1993, $1,000 to Senator Edward M. Kennedy (D-
MA); May 23, 1994, $2,000 to Senator Dianne Feinstein (D-CA); May 23, 
1994, $500 to Senator Dianne Feinstein (D-CA); July 18, 1994, $1,000 to 
Senator Dianne Feinstein (D-CA). Mary Ma: June 10, 1993, $1,000 to 
Senator Charles S. Robb (D-VA); July 17, 1993, $1,000 to Representative 
Gary L. Ackerman (D-NY-7); Oct. 25, 1993, $1,000 to Senator James R. 
Sasser (D-TN); May 23, 1994, $2,000 to Senator Dianne Feinstein (D-CA); 
May 23, 1994, $500 to Senator Dianne Feinstein (D-CA); July 18, 1994, 
$1,000 to Senator Dianne Feinstein (D-CA); Oct. 15, 1993, $10,000 to 
the DNC; Dec. 8, 1995, $500 to John C. Edwards (D-AR-2). http://
wyl.ewg.org, Environmental Working Group Website, Compiled from FEC 
Data, Last Updated Sept. 10, 1998; DNC Check Tracking Form for 
LippoBank Check No. 258 from Felix Ma or Mary L.M. Ma to the DNC in the 
amount of $10,000, Sept. 30, 1993, DNC 0039321 (Exhibit 177); DNC Check 
Tracking Form for LippoBank Check No. 259 from Felix Ma or Mary L.M. Ma 
to the DNC in the amount of $10,000, Sept. 30, 1993, DNC 0039319 
(Exhibit 178); Exhibit 179 LippoBank Checking Account Statement of 
Felix Ma or Mary L.M. Ma, Oct. 25, 1993 (Exhibit 179); LippoBank Check 
No. 258 from Felix Ma or Mary L.M. Ma to the DNC in the amount of 
$10,000, Sept. 30, 1993, and LippoBank Check No. 259 from Felix Ma or 
Mary L.M. Ma to the DNC in the amount of $10,000, Sept. 30, 1993 
(Exhibit 180).
---------------------------------------------------------------------------
    In recent interrogatories to the DNC, the Committee 
requested information regarding contributions made by Felix Ma. 
The DNC responded:

        To our knowledge, the referenced contribution from Mr. 
        Ma does not fall into any of the seven categories 
        involved in the DNC's review of prior contributions. . 
        . . Further, no information has been brought to our 
        attention calling into question the legality or 
        appropriateness of the referenced contribution.\302\
---------------------------------------------------------------------------
    \302\ DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 16-17.

The same response was given regarding Mary Ma's 
contributions.\303\ As is evident from their response, the DNC 
has retained the Mas' contributions.
---------------------------------------------------------------------------
    \303\ Id. at 17-18.
---------------------------------------------------------------------------
    The Committee has been unable to locate Felix and Mary Ma 
or identify the ultimate source of the funds used for the 
contributions but is continuing its review. However, on March 
10, 1997, Senator Dianne Feinstein announced the return of 
$12,000 in contributions to her senatorial campaign which 
included $2,000 contributed by Felix Ma and $2,000 by Mary 
Ma.\304\ Feinstein also returned an additional $8,000 
contributed by other individuals with ties to Lippo, including 
Joseph Sund, $2,000; Charles DeQueljoe, $2,000; Susan Hene-
DeQueljoe, $2,000; and Kenneth Wynn, $2,000.\305\ According to 
Bill Chandler, Feinstein's state director based in San 
Francisco, ``[t]he senator believes these contributions to be 
legal but because of the uproar over LippoBank she wanted to 
exert extreme caution and return the funds. . . .'' These are 
all the contributions we know to be related to Lippo Bank.\306\
---------------------------------------------------------------------------
    \304\ Judy Holland and Charles J. Lewis, ``China Donor Saga Widens: 
Boxer, Pelosi Say They, Too, Were Warned by FBI,'' San Francisco 
Examiner, Mar. 10, 1997, at A1.
    \305\ Id.
    \306\ Id.
---------------------------------------------------------------------------
    In December 1993, Senator Edward M. Kennedy received a 
$1,000 contribution from Felix Ma but returned the contribution 
in December 1996.\307\ The DNC, DSCC, the Ohio Democratic 
party, the Michigan Democratic party and the Missouri 
Democratic party have retained the Mas' contributions.\308\ 
However, applying the DNC's own standards of review, given the 
unavailability of the Mas and the questionable status of these 
contributions, the DNC, DSCC and state parties should follow 
the practice of Senators Feinstein, Kennedy and Pressler: the 
Mas' contributions are suspect and, therefore, should be 
disgorged to the U.S. Treasury.\309\
---------------------------------------------------------------------------
    \307\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \308\ See Id.
    \309\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

                     Joseph Sund $20,000 (Suspect)

    Joseph Sund is a Lippo executive who contributed $20,000 to 
Democratic causes--again many of the same ones targeted by the 
Riadys--during the 1992 election cycle.\310\ Joseph Sund has 
served as an executive for a variety of Lippo controlled 
companies including Tati Group Limited of Hong Kong.\311\ As of 
December 31, 1996, Sund was employed in the Lippo Group's real 
estate brokerage office in Beijing, China.\312\ Sund, 
simultaneous with his employment at Lippo, served as President 
of Pacific Trade Enterprises, Inc., a New York corporation, as 
late as September 30, 1993.\313\
---------------------------------------------------------------------------
    \310\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \311\ Exhibit 128 Memorandum from Joseph Sund to John Huang, Mar. 
23, 1993, HHH 4578 and HHH 4579; Memorandum from Joseph Sund to John 
Huang, Apr. 9, 1993, HHH 4589 (Exhibit 181).
    \312\ Gwen Lyle and Mark Wu, ``China: Housing Construction 
Market,'' Industry Sector Analysis, Dec. 31, 1996.
    \313\ New York Department of State, Corporate Records.
---------------------------------------------------------------------------
    During the period September 23-30, 1992, Joseph Sund issued 
three checks to Democratic causes totaling $20,000 as detailed 
below: \314\
---------------------------------------------------------------------------
    \314\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998; Exhibit 150 List 
of DNC Contributors for Sept. 25, 1992, Gore Economic Event, DNC 
4125867.2; DNC Finance Executive Summary for Joseph T. Sund, Apr. 24, 
1998, DNC 4368568 (Exhibit 182); Independence Savings Bank Check No. 
104 from Joseph Tat Sund to the Michigan State Democratic party/Federal 
Account in the amount of $5,000, Sept. 30, 1992, Independence Savings 
Bank Check No. 105 from Joseph Tat Sund to the DNC Victory Fund in the 
amount of $10,000, Sept. 24, 1992, and Independence Savings Bank Check 
No. 106 from Joseph Tat Sund to the Arkansas State Democratic party in 
the amount of $5,000, Sept. 23, 1992 (Exhibit 183); DNC Check Tracking 
Form for Independence Savings Bank Check No. 105 from Joseph Tat Sund 
to the DNC Victory Fund in the amount of $10,000, Sept. 24, 1992, DNC 
3310338 (Exhibit 184). The Committee has received DNC contribution 
information only for Sund's 1992 contribution to the DNC, which was 
solicited by Bob Burkett. Id.

----------------------------------------------------------------------------------------------------------------
                                                  Check                                                         
                     Name                         Date      FEC Date              Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
Joseph Sund..................................    09/24/92    09/28/92  DNC............................   $10,000
Joseph Sund..................................    09/30/92    10/21/92  Arkansas Democratic Party......     5,000
Joseph Sund..................................  ..........    10/23/92  Michigan Democratic Party......     5,000
----------------------------------------------------------------------------------------------------------------

    The extent of Joseph Sund's other fund-raising activity is 
unclear. However, on August 26, 1993, LippoBank employee Dewi 
C. Tirto wrote a memorandum to Joseph Sund which states in 
pertinent part:

        John Huang asked me to inform you that Senator Pressler 
        will be staying at [sic] Portman Hotel in Shanghai. 
        FYI, the following are Committee assignments of Senator 
        Pressler: Commerce, Science & Transportation--Foreign 
        Relations--Juciary [sic]--Small Business--Special 
        Aging.\315\
---------------------------------------------------------------------------
    \315\ Memorandum from Dewi C. Tirto to Joseph Sund, Aug. 26, 1993, 
HHH 4588 (Exhibit 185).

FEC data indicates that Joseph and his wife Hylen Sund each 
contributed $1,000 to Senator Larry Pressler in December 
1993.\316\ Senator Pressler returned the Sunds' contributions 
in October 1996, apparently upon learning of their potential 
link to the Lippo Group.\317\ In addition to the foregoing, the 
Sunds contributed $20,000 to the DNC and $13,500 to 
congressional and senatorial candidates.\318\
---------------------------------------------------------------------------
    \316\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \317\ Id.
    \318\ Id.; Manufacturers Hanover Check No. 4107 from Joseph Sund 
and Hylen Sund to the DNC in the amount of $5,000, Sept. 27, 1993, DNC 
0102552 (Exhibit 186); Manufacturers Hanover Check No. 4108 from Joseph 
Sund and Hylen Sund to the DNC in the amount of $5,000, Sept. 30, 1993, 
DNC 0102553 (Exhibit 187); Manufacturers Hanover Check No. 211 from 
Pacific Trade Enterprises, Inc. to the DNC in the amount of $10,000, 
Sept. 28, 1993, DNC 0102895 (Exhibit 188) (Joseph Sund contributed 
$10,000 to the DNC on Sept. 30, 1993, through his company Pacific Trade 
Enterprises, Inc.); http://wyl.ewg.org, Environmental Working Group 
Website, Compiled from FEC Data, Last Updated Sept. 10, 1998. Joseph 
Sund: June 30, 1993, $1,000 to Senator Charles S. Robb (D-VA); July 7, 
1993, $1,000 to Representative Gary L. Ackerman (D-NY-7); July 15, 
1993, $1,000 to Senator Paul Simon (D-IL); Aug. 10, 1993, $1,000 to 
Senator Harris L. Wofford (D-PA); Sept. 30, 1993, $5,000 to the DNC; 
Sept. 30, 1993, $5,000 to the DNC; May 24, 1994, $5,000 to Senator 
Dianne Feinstein (D-CA); Oct. 11, 1994, $2,500 to the Effective 
Government Committee. Hylen Sund: June 10, 1993, $1,000 to Senator 
Charles S. Robb (D-VA); July 1, 1994, $2,000 to Senator Dianne 
Feinstein (D-CA). Joseph Sund contributed $10,000 to the DNC on Sept. 
30, 1993, through his company Pacific Trade Enterprises, Inc.
---------------------------------------------------------------------------
    In recent interrogatories to the DNC, the Committee 
requested information regarding a contribution made by Joseph 
Sund. The DNC responded:

        To our knowledge, the referenced contribution from 
        Joseph Sund does not fall into any of the seven 
        categories involved in the DNC's review of prior 
        contributions. . . . Further, no information has been 
        brought to our attention calling into question the 
        legality or appropriateness of Mr. Sund's 
        contribution.\319\
---------------------------------------------------------------------------
    \319\ DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 10-11.

As is evident from their response, the DNC has retained Joseph 
Sund's contributions.
    The Committee has located Joseph Sund who--according to his 
attorney--is residing in China and is currently engaged in 
discussions with his attorneys to secure his testimony. The 
Committee has thus far been unable to identify the ultimate 
source of the funds used for the contributions due to lack of 
cooperation from Sund, but is continuing its review. That fact 
notwithstanding, as detailed earlier, on March 19, 1997, House 
Minority Leader Dick Gephardt returned $22,000 in campaign 
contributions which included $2,500 contributed by former Lippo 
executive Joseph Sund.\320\ Similarly, Joseph Sund's $2,000 
contribution to Senator Dianne Feinstein was one of six 
returned in March 1997 because of the contributors' ties to the 
Lippo Group.\321\ Apparently, Senator Feinstein, like 
Representative Gephardt, had concerns over the ultimate source 
of the funds, although Senator Feinstein has yet to return the 
$2,000 contributed to her campaign by Hylen Sund in 1994.\322\
---------------------------------------------------------------------------
    \320\ ``Gephardt Returns $22,000,'' Associated Press, Mar. 19, 
1997, at A37.
    \321\ ``China Donor Saga Widens: Boxer, Pelosi Say They, Too, Were 
Warned by FBI,'' San Francisco Examiner, Mar. 10, 1997.
    \322\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
---------------------------------------------------------------------------
    The DNC, the Arkansas Democratic party and the Michigan 
Democratic party have retained Joseph Sund's 
contributions.\323\ However, applying the DNC's own standards 
of review, given the unavailability of Sund and the 
questionable status of these contributions, the DNC and state 
parties should follow the practice of House Minority Leader 
Richard Gephardt, Senator Feinstein and Senator Pressler: 
Sund's contributions are suspect and, therefore, should be 
disgorged to the U.S. Treasury.\324\
---------------------------------------------------------------------------
    \323\ Id.
    \324\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

C. Contributions by Lippo Controlled Entities During the 1994 Election 
                                 Cycle

 Hip Hing Holdings $22,500, San Jose Holdings $15,000, and Toy Center 
                       Holdings $17,500 (Suspect)

    On September 27, 1993, the DNC held a fund-raiser in Los 
Angeles featuring Vice President Al Gore.\325\ In addition to 
John and Jane Huang, Agus Setiawan, then-Vice President of 
Marketing for LippoBank, and Jueren Shen, a foreign national 
and chairman of the China Resources Group--a company owned and 
operated by the Communist Chinese government and identified as 
a Chinese intelligence gathering operation \326\--were also in 
attendance.\327\ In conjunction with this event, three Lippo-
related companies contributed a total of $45,000 to the DNC as 
detailed below.
---------------------------------------------------------------------------
    \325\ Letter from John Huang to Jack Quinn, Oct. 7, 1993, EOP 
049490 (Exhibit 189); Karatz Residence DNC Reception Logistics and 
Guest List, EOP 000959-EOP 000964 (Exhibit 190).
    \326\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 2, 
2504 (1998).
    \327\ Exhibit 190 Karatz Residence DNC Reception Logistics and 
Guest List, EOP 000959-EOP 000964.
---------------------------------------------------------------------------
    On September 23, 1993, in conjunction with this event, 
Lippo Group subsidiaries Hip Hing Holdings, San Jose Holdings, 
Inc. (``San Jose Holdings'') and Toy Center Holdings of 
California, Inc. (``Toy Center Holdings'') \328\ each 
contributed $15,000 to the DNC under the signature of then-
Lippo executives John Huang and Agus Setiawan.\329\ Hip Hing 
Holdings also contributed $2,500 to the DNC on May 29, 
1993,\330\ and $5,000 to the California Democratic party on 
September 29, 1993.\331\ On May 28, 1993, Toy Center Holdings 
contributed an additional $2,500 to the DNC.\332\ All three 
subsidiaries generated negative net income for the fiscal year 
ending December 31, 1993, during which the contributions were 
made.
---------------------------------------------------------------------------
    \328\ List of Directors and Officers for Lippo Group Companies in 
USA, June 1, 1990, HHH 0850, HHH 0847, and HHH 0849 (Exhibit 191); see 
also Investigation of Illegal or Improper Activities in Connection with 
the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 2, 
2504 (1998) citing Investigation of Illegal or Improper Activities in 
Connection with the 1996 Federal Election Campaign Before the Senate 
Committee on Governmental Affairs, 105th Cong., 1st sess., part II, S. 
Hrg. 105-300, 13 (1998) (Testimony of Juliana Utomo, July 15, 1997).
    \329\ DNC Check Tracking Form for LippoBank Check No. 2626 from Hip 
Hing Holdings to the DNC in the amount of $15,000, Sept. 23, 1993, DNC 
0102897 (Exhibit 192); DNC Check Tracking Form for LippoBank Check No. 
1692 from San Jose Holdings to the DNC in the amount of $15,000, Sept. 
27, 1993, DNC 0102898 (Exhibit 193); DNC Check Tracking Form for 
LippoBank Check No. 1458 from Toy Center Holdings to the DNC in the 
amount of $15,000, Sept. 23, 1993, DNC 0102896 (Exhibit 194). According 
to FEC data, Toy Center Holdings also contributed $2,500 to the DNC in 
July 1993; the FEC date is July 15, 1993. On Sept. 27, 1993, Calbot 
Holdings, Inc., another Lippo subsidiary, contributed $40,000 to the 
DNC also under the signatures of John Huang and Agus Setiawan. Bank of 
Trade/Lippo Group Check No. 1092 from Calbot Holdings to the DNC in the 
amount of $40,000, Sept. 27, 1993, CHI 0035 and CHI 0200 (Exhibit 195). 
The Committee is investigating the origins of this contribution.
    \330\ DNC Check Tracking Form for LippoBank Check No. 2572 from Hip 
Hing Holdings to the DNC in the amount of $2,500, May 28, 1993, DNC 
0052705 (Exhibit 196).
    \331\ LippoBank Check No. 2628 from Hip Hing Holdings to the 
California Democratic party in the amount of $5,000, Sept. 29, 1993, 
HHH 0484 and HHH 0485 (Exhibit 197).
    \332\ LippoBank Check No. 1418 from Toy Center Holdings to the DNC 
in the amount of $2,500, May 28, 1993, TCH 0048 and TCH 0049 (Exhibit 
198); DNC Check Tracking Form for LippoBank Check No. 1418 from Toy 
Center Holdings to the DNC in the amount of $2,500, May 28, 1993, DNC 
0052706 (Exhibit 199).
---------------------------------------------------------------------------
    According to documents produced to the Committee, during 
the fiscal year ending December 31, 1993, Hip Hing Holdings 
generated a gross income of only $35,200 and a negative net 
income of -$493,802.93.\333\ Of its $35,200 in gross income, 
$32,960 was expended on ``Contribution [sic] and Donations.'' 
\334\ Hip Hing Holdings' only asset at the time of the 
contribution was a vacant parking lot in Los Angeles.\335\
---------------------------------------------------------------------------
    \333\ Hip Hing Holdings Income Statement for the Period Ending Dec. 
31, 1993, HHH 0043 (Exhibit 200).
    \334\ Id.
    \335\ James Warren, ``Funds Hearings Focus on China's Links to 
Indonesian Conglomerate,'' Chicago Tribune, July 15, 1997.
---------------------------------------------------------------------------
    San Jose Holdings, a real estate holding company,\336\ 
generated a gross income of $172,108 and a negative net income 
of -$65,177.09.\337\ Of its $172,108 in gross income, $35,150 
was expended on ``Contribution[s] and Donations.'' \338\
---------------------------------------------------------------------------
    \336\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 1, 
1123 (1998).
    \337\ San Jose Holdings Income Statement for the Period Ending Dec. 
31, 1993 (Exhibit 201).
    \338\ Id.
---------------------------------------------------------------------------
    Finally, Toy Center Holdings generated a gross income of 
$132,404.24 and a negative net income of -$26,886.67.\339\ Of 
its $132,404.24 in gross income, $33,550 was expended on 
``Contribution [sic] and Donations.'' \340\ The details of the 
business conducted by Toy Center Holdings are unknown to the 
Committee.
---------------------------------------------------------------------------
    \339\ Toy Center Holdings Income Statement for the Period Ending 
Dec. 31, 1993 (Exhibit 202).
    \340\ Id.
---------------------------------------------------------------------------
    In recent interrogatories to the DNC, the Committee 
requested information regarding the September 23, 1993, 
contributions of Hip Hing Holdings, San Jose Holdings, and Toy 
Center Holdings. The DNC responded:

        To our knowledge, the referenced contribution from Hip 
        Hing Holdings, Ltd. does not fall into any of the seven 
        categories involved in the DNC's review of prior 
        contributions. . . . Further, no information has been 
        brought to our attention calling into question the 
        legality or appropriateness of the contribution from 
        Hip Hing Holdings, Ltd. . . . \341\
---------------------------------------------------------------------------
    \341\ DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 13-14.

Pursuant to its review of the subsidiaries' contributions, the 
DNC reviewed information developed by the Senate Campaign 
Finance Investigation including the majority and minority 
reports.\342\ In proclaiming the legality of the subsidiaries' 
contributions in its response to the Committee's 
interrogatories, the DNC quoted and relied upon the following 
passage excerpted from the Senate Minority Report:
---------------------------------------------------------------------------
    \342\ Id. at 12-14.

        In September 1993, the DNC received additional 
        contributions from Hip Hing Holdings and from two other 
        holding companies: San Jose Holdings and Toy Center 
        Holdings. Hip Hing Holdings and Toy Center Holdings 
        each made $17,500 in contributions to the DNC while San 
        Jose Holdings contributed $15,000. Unlike the 
        contribution in 1992, however, [of $50,000 from Hip 
        Hing Holdings], the requests for reimbursement for the 
        months in which the contributions were made do not 
        contain requests for reimbursements of these 
        contributions. Also, unlike the $50,000 contribution 
        from Hip Hing Holdings in 1992, each of the companies 
        generated sufficient rental income to support the cost 
        of the 1993 contributions. In 1993, Hip Hing Holdings 
        generated $35,200 in income from rental of the 
        undeveloped property, while San Jose Holdings generated 
        $155,979 in income, and Toy Center Holdings generated 
        $167,000 in income. Accordingly, unlike the 1992 
        contribution, there is no evidence that the 1993 
        contributions made by Lippo-related entities were 
        reimbursed with money from abroad.\343\
---------------------------------------------------------------------------
    \343\ Id. at 12 (emphasis added in original text) (citations 
omitted in original text) (citing Investigation of Illegal or Improper 
Activities in Connection with the 1996 Federal Election Campaign Before 
the Senate Committee on Governmental Affairs, S. Rept. No. 167, 105th 
Cong., 2d sess., vol. 4, 4793 (1998)).

An identical response was given regarding the contributions of 
San Jose Holdings \344\ and Toy Center Holdings,\345\ and as 
evidenced by the foregoing responses, the DNC has retained the 
$45,000 in contributions.\346\
---------------------------------------------------------------------------
    \344\ DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 14-15.
    \345\ Id. at 11-12.
    \346\ Id. at 11-15.
---------------------------------------------------------------------------
    The $50,000 contribution to the DNC referenced in the 
Senate Minority Report was made by Hip Hing Holdings in August 
1992.\347\ Hip Hing Holdings was immediately thereafter 
reimbursed in the amount of $50,000 by the Lippo Group in 
Indonesia.\348\ In July 1997, the DNC immediately returned the 
$50,000 that it received from Hip Hing Holdings after learning 
of its foreign origin from a Senate hearing.\349\ In the case 
of the subsidiaries' 1993 contributions totaling $45,000, the 
DNC has retained them based upon the fact that the subsidiaries 
were not reimbursed for the contributions by a foreign source, 
namely the Lippo Group.\350\ On this point, the Minority Report 
and the DNC appear to be correct: ``. . . unlike the 1992 
[$50,000] contribution [by Hip Hing Holdings], there is no 
evidence that the 1993 contributions made by Lippo-related 
entities were reimbursed with money from abroad.'' \351\
---------------------------------------------------------------------------
    \347\ Exhibit 26 LippoBank Check No. 2397 from Hip Hing Holdings to 
the DNC Victory Fund Non-Federal Account in the amount of $50,000, Aug. 
12, 1992, HHH 1263.
    \348\ Exhibit 27 Memorandum from John Huang and Agus Setiawan to 
Mrs. Ong Bwee Eng, Aug. 17, 1992, HHH 0238.
    \349\ James Rowley, ``The Senate Investigation of Campaign Fund-
raising Abuses,'' Associated Press, July 15, 1997; Lynn Sweet, 
``Democrats to Return $50,000 Foreign Contribution,'' Chicago Sun-
Times, July 16, 1997, at 31.
    \350\ DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 12-15.
    \351\Id. at 12 (emphasis added in original text) (citations omitted 
in original text) (citing Investigation of Illegal or Improper 
Activities in Connection with the 1996 Federal Election Campaign Before 
the Senate Committee on Governmental Affairs, S. Rept. No. 167, 105th 
Cong., 2d sess., vol. 4, 4793 (1998)).
---------------------------------------------------------------------------
    However, the DNC's reliance on the example of Hip Hing 
Holdings' August 1992 contribution in deciding to retain the 
subsidiaries' 1993 contributions is misplaced. The 1993 
contributions are illegal based on James Riady's immigration 
status. At the time of the contribution, Riady was a permanent 
resident ``outside of the United States'' and thus ineligible 
to make political contributions in his personal capacity. But 
more importantly in this case, having established that--despite 
his permanent resident status--Riady has been a foreign 
national pursuant to 2 U.S.C. 441(e)a since 1991, Riady was 
also ineligible to participate in the decision of a U.S. 
corporation to make a political contribution. Pursuant to FEC 
regulations:

        A foreign national shall not direct, dictate, control, 
        or directly or indirectly participate in the 
        decisionmaking process of any person, such as a 
        corporation, labor organization, or political 
        committee, with regard to such person's federal or 
        nonfederal election-related activities, such as 
        decisions concerning the making of contributions or 
        expenditures in connection with elections for any 
        local, state, or federal office or decisions concerning 
        the administration of a political office.\352\
---------------------------------------------------------------------------
    \352\ FEC Advisory Opinion 1992-16 (citing 11 C.F.R. 
Sec. 110.4(A)(3)) (emphasis added).

As in the case of the other contributions by Lippo 
subsidiaries, if Riady played any part whatsoever in any of the 
subsidiaries' decisions to contribute to the DNC, that decision 
is tainted by Riadys involvement and the resulting contribution 
is illegal.
    Moreover, the 1993 contributions by Hip Hing Holdings, San 
Jose Holdings and Toy Center Holdings are legally suspect, not 
because they each were reimbursed for their contributions, but 
because the contributions were not made from profits as 
required by FEC Advisory Opinion 1992-96 which states in 
pertinent part that ``[t]he domestic subsidiary of a foreign 
corporation may make political contributions even though it 
received subsidies from its foreign parent if the contributions 
are made from domestic profits.'' \353\ In this case, the 
contributions were made during a period in which the 
subsidiaries suffered major losses and are legally suspect as a 
result.
---------------------------------------------------------------------------
    \353\ FEC Advisory Opinion 1992-96; Investigation of Illegal or 
Improper Activities in Connection with the 1996 Federal Election 
Campaign Before the Senate Committee on Governmental Affairs, S. Rept. 
No. 167, 105th Cong., 2d sess., vol. 1, 1124 (1998) (citing FEC 
Advisory Opinion 1992-96).
---------------------------------------------------------------------------
    If made today, pursuant to current DNC policy, these 
contributions would not be accepted. According to DNC counsel 
Joseph Sandler, ``[w]e don't accept checks from U.S. 
subsidiaries of foreign corporations as a matter of policy, not 
of law. So, we would not accept a check from a U.S. subsidiary 
regardless of the circumstances under our current policy.'' 
\354\
---------------------------------------------------------------------------
    \354\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, 105th Cong., 1st sess., Deposition of Joseph E. 
Sandler, Esq., May 15, 1997, 79 (emphasis added).
---------------------------------------------------------------------------
    While there is insufficient evidence to declare the 
subsidiaries' $52,500 in contributions illegal due to 
insufficient information regarding James Riady's participation 
in the decisions to contribute, they are highly suspect and 
should be returned to the contributors or disgorged to the U.S. 
Treasury based on the DNC's own criteria of 
appropriateness.\355\ The Committee is continuing its review of 
the contributions.
---------------------------------------------------------------------------
    \355\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

    Arkansas International Development Corporation $25,000 (Suspect)

    DNC check tracking forms and supporting finance documents 
indicate that the Arkansas International Development 
Corporation (``AIDC'')--a corporation initially funded by P.T. 
Masindo, a subsidiary of the Lippo Group, in the amount of 
$50,000 \356\--contributed $25,000 to the DNC on November 25, 
1993.\357\ On one check tracking form produced to the 
Committee, ``James Riotti'' [sic] was listed as the contact for 
the contribution.\358\ A second check tracking form for the 
same $25,000 contribution has ``James Riotti'' [sic] marked 
through and ``Joe Giroir'' written instead.\359\ This 
contribution was attributed to a BLF fund-raiser noted as ``CA-
Dinner.'' \360\ Supporting documents describe the fund-raiser 
as the ``Los Angeles Event Pres. Clinton'' held on December 17, 
1993.\361\
---------------------------------------------------------------------------
    \356\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, Deposition of C.J. ``Joe'' Giroir, Jr., 15-16, 
Apr. 30, 1997; see generally Letter from C. Joseph Giroir, Jr., Esq., 
to Winardi Setiaputra, Sept. 21, 1995, AIDC 000005-AIDC 000006 (AIDC II 
was also funded in part by the Lippo Group.) (Exhibit 203).
    \357\ DNC Check Tracking Form for Worthen Check No. 1010 from AIDC 
to the DNC in the amount of $25,000, Dec. 25, 1993, DNC 0048739 
(Exhibit 204); DNC Check Tracking Form for Worthen Check No. 1010 from 
AIDC to the DNC in the amount of $25,000, Dec. 25, 1993, DNC 1410240 
(Exhibit 205).
    \358\ Exhibit 204 DNC Check Tracking Form for Worthen Check No. 
1010 from AIDC to the DNC in the amount of $25,000, Dec. 25, 1993, DNC 
0048739.
    \359\ Exhibit 205 DNC Check Tracking Form for Worthen Check No. 
1010 from AIDC to the DNC in the amount of $25,000, Dec. 25, 1993, DNC 
1410240.
    \360\ Exhibit 204 DNC Check Tracking Form for Worthen Check No. 
1010 from AIDC to the DNC in the amount of $25,000, Dec. 25, 1993, DNC 
0048739; Exhibit 205 DNC Check Tracking Form for Worthen Check No. 1010 
from AIDC to the DNC in the amount of $25,000, Dec. 25, 1993, DNC 
1410240.
    \361\ List of DNC Contributors, 12/1/95 to 2/29/96, DNC 4125867.17 
(Exhibit 206); see also DNC Detail Posting of Mr. James Riotti of AIDC 
Dec. 17, 1993, DNC 0048107 (Exhibit 207).
---------------------------------------------------------------------------
    In an undated DNC memorandum from Ann Braziel to former 
White House aide Mark Middleton regarding ``Arkansas Follow-
up,'' Braziel wrote, ``[h]ere are some more prospects/past 
donors that we couldn't identify. Do you have any information 
or advice on them?'' \362\ The first individual enumerated is: 
``Mr. James Riotti [sic] Arkansas International Development 
Corp $25k in 1993.'' \363\
---------------------------------------------------------------------------
    \362\ DNC Memorandum from Ann Braziel to Mark Middleton, undated, 
DNC 3001579-DNC 3001580 (Exhibit 208).
    \363\ Id.
---------------------------------------------------------------------------
    The ``James Riotti'' referenced is in fact ``James Riady'' 
of the Lippo Group.\364\ As previously discussed, the Committee 
has no FEC records of political contributions made by James 
Riady in his personal capacity after 1992. It is, however, 
beyond dispute that the AIDC contributed $25,000 to the DNC on 
December 25, 1993. At the time of the contribution, Riady was a 
permanent resident ``outside of the United States'' and thus 
ineligible to participate in the decision of a U.S. corporation 
to make a political contribution. In short, if Riady played any 
part whatsoever in the AIDC's decision to contribute $25,000 to 
the DNC, the contribution is illegal. Precisely how Riady's 
name came to be associated with this remains a mystery. But in 
any event, based on the documents excerpted above and the DNC's 
attribution of the $25,000 contribution--exactly one-half of 
the initial capital infusion provided by the Lippo Group to 
start AIDC--to Riady, it strains credibility to believe that he 
played no role in the AIDC's decision to contribute.\365\
---------------------------------------------------------------------------
    \364\ In recent interrogatories to the DNC, the Committee requested 
information regarding the $25,000 contribution made by the AIDC. DNC's 
Responses to the Committee's June 23, 1998, Interrogatories, Aug. 6, 
1998, at 29. The DNC responded in pertinent part that:

        The contribution was not made by ``James Riotti,'' but by 
      [sic] Arkansas International Development Corporation. It 
      was deposited into the DNC's non-federal corporate account 
      as a corporate contribution. ``James Riotti'' was listed as 
      a ``contact'' for the company on the check tracking form. I 
      have not identified any information indicating whether this 
---------------------------------------------------------------------------
      is the correct name and spelling for this person.

Id. at 30-31. The Committee does not dispute the DNC's characterization 
of the contribution as a corporate contribution made by the AIDC. But 
while the DNC is apparently unable to confirm that ``James Riotti'' 
[sic] associated with the AIDC is ``James Riady'' of the Lippo Group, 
the Committee has gathered overwhelming evidence that ``James Riotti'' 
is in fact ``James Riady'' based on a number of factors including, but 
not limited to: the Lippo Group's association with the AIDC, James 
Riady's association with C.J. ``Joe'' Giroir, James Riady's history of 
contributing to Democratic causes, and his association with a number of 
Democratic Arkansans including President Clinton and Mark Middleton.
---------------------------------------------------------------------------
    \365\ C.J. ``Joe'' Giroir, Esq., was questioned about an AIDC 
disbursement relating to Webster Hubbell. The dialog went as follows:

        Counsel. Did you have any reticence about [making a 
      contribution to the Hubbell Family Trust], was it something 
      that you thought about?
        Giroir. Well, I didn't want to do it without discussing 
      it with James Riady because I didn't consider it to be a 
      proper business expense for AIDC. And, so, I wanted to be 
      sure that he was in concurrence with me that it would be 
      okay to do.

So, on at least one occasion Giroir consulted with James Riady 
regarding the disbursements that he did not consider ``a proper 
business expense.'' Whether a contribution to the DNC would constitute 
``a proper business expense'' to Giroir is an unanswered question. 
Investigation of Illegal or Improper Activities in Connection with the 
1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, Deposition of C.J. ``Joe'' Giroir, Jr., 251-253, 
Apr. 30, 1997.
    Due to insufficient information regarding James Riady's 
participation in the AIDC's decision to contribute, the 
Committee cannot conclude with 100% certainty that the 
contribution is illegal. The evidence available to the 
Committee does, however, strongly indicate that the AIDC's 
$25,000 contribution is illegal and should be disgorged to the 
U.S. Treasury pursuant to Federal law.\366\ The Committee is 
continuing its review of the contributions.
---------------------------------------------------------------------------
    \366\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

        D. The Political Involvement and Influence of the Riadys

    The Riadys, John and Jane Huang and most of the Lippo 
employees and their spouses who made contributions have either 
fled the country or pled the Fifth Amendment in order to avoid 
incriminating themselves. Against that backdrop, the foregoing 
contributions appear to be part of a larger scheme and pattern 
of illegal--or at a minimum, questionable--contributions 
involving the Riadys, their companies, and their employees. 
Their combined 1992 contributions to the Arkansas Democratic 
party, for example, were 23 percent of all contributions 
received by the Arkansas party from individuals for the 1992 
election cycle.\367\ President Clinton was clearly informed in 
August 1992--around the time that the Riadys contributed over 
$450,000 to Democratic causes--that James Riady was living and 
based abroad and that his interests were primarily vested in 
Asia. Given President Clinton and James Riady's close 
friendship, many questions regarding the President's knowledge 
of the Riadys' political contributions remain to be answered.
---------------------------------------------------------------------------
    \367\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
---------------------------------------------------------------------------

Yah Lin ``Charlie'' Trie Related Contributions During the 1996 Election 
                                 Cycle

                       Lei Chu $12,500 (Illegal)

    Lei Chu, a onetime close advisor of and assistant to Yah 
Lin ``Charlie'' Trie,\368\ played a key role in Trie's service 
as a member of the Commission on United States-Pacific Trade 
and Investment Policy, otherwise known as the Bingaman 
Commission. Chu drafted a number of policy proposals for the 
Commission on Trie's behalf and participated in Commission 
meetings.\369\ After attending several meetings, she was 
prohibited from Commission participation by the Chairman of the 
Commission due to concerns over her ties to foreign 
corporations.\370\
---------------------------------------------------------------------------
    \368\ Lei Chu apparently also has ties to Peter Chen, a one-time 
employee of the Lippo Group. See Memorandum from Peter Chen to Joe 
Giroir, Antonio Pan, et al., Aug. 12, 1994, AIDC 000972 (Exhibit 209). 
Chu served as the Vice President of Sun Union Limited of Hong Kong 
under Sun Union President Peter Chen. Sun Union Limited Business Card 
of President Peter Chen, A 0003245 (Exhibit 210); Sun Union Limited 
Business Card of Vice President Lei Chu, A 0003246 (Exhibit 211).
    \369\ Proposal of the U.S.-Asia Trading Partnership Program 
(USATP), May 14, 1996 (Exhibit 212); ``Recommendations for what we can 
do in U.S.-Asian Trade Policy Formulation,'' Aug. 1, 1996 (Exhibit 
213); ``Commission on U.S.-Pacific Trade and Investment Policy: Some 
Recommendations Before the Asia Trip,'' Aug. 25, 1996 (Exhibit 214).
    \370\ Committee Interview of Clyde Prestowitz, Feb. 18, 1998.
---------------------------------------------------------------------------
    On February 18, 1996, Lei Chu flew on China Airlines from 
Taipei, Taiwan to Los Angeles, California.\371\ The following 
day she attended the DNC's February 19, 1996, fund-raiser at 
the Hay Adams Hotel in Washington, DC.\372\ This was John 
Huang's first DNC fund-raiser.\373\ At this fund-raiser the 
President lauded Huang for his fund-raising prowess as 
excerpted previously. Trie was also in attendance.\374\ A 
photograph from the event shows John Huang and then-DNC 
Chairman Donald Fowler holding a poster size check from the 
Asian Pacific Leadership to the DNC in the amount of 
$1,000,000.\375\ The Hay Adams fund-raiser failed to raise the 
funds expected.\376\ In order to make up for the shortfall, 
conduit contributions were made at the request of and with 
funds provided by Trie and ex-Lippo executive Antonio Pan in 
order to reach the $1,000,000 goal.\377\
---------------------------------------------------------------------------
    \371\ U.S. Customs Records for Lei Chu (Exhibit 215).
    \372\ Photograph of Lei Chu at the DNC Feb. 19, 1996, Fund-raiser, 
Hay-Adams Hotel, Washington, DC (Exhibit 216).
    \373\ See generally DNC Briefing for the President of the United 
States, DNC Asian Pacific American Leadership Council Dinner, Feb. 19, 
1996, Hay-Adams Hotel, Washington, DC, DNC 1579590-DNC 1579600 (Exhibit 
217).
    \374\ Photograph of Presidential table at the DNC Feb. 19, 1996, 
Fund-raiser, Hay-Adams Hotel, Washington, DC (Exhibit 218); List of 
Attendees for the Hay Adams event, Feb. 19, 1996, EOP 058577, EOP 
058579-EOP 058580 (Exhibit 219).
    \375\ Photograph of then-DNC Vice Chairman John Huang and Then-DNC 
Chairman Donald Fowler at the DNC Feb. 19, 1996, Fund-raiser, Hay-Adams 
Hotel, Washington, DC (Exhibit 220).
    \376\ See Committee Interview of Tony Hsu, Sept. 3, 1997.
    \377\ See Id.; see, e.g., Discussion of J & M International, Inc., 
Manlin Foung, and Joseph Landon, infra.
---------------------------------------------------------------------------
    The following day, on February 20, 1996, Chu established a 
checking account at the Citizens Bank of Washington with an 
initial cash deposit of $12,520.\378\ On that same day, Chu 
issued starter check no. 90--the first check ever written on 
that account--in the amount of $12,500 to the DNC \379\ in 
conjunction with the Hay Adams fund-raiser.\380\ That check 
cleared Chu's account on February 26, 1996,\381\ and was the 
sole check written from that account during the period February 
1996-July 1996.\382\ It should be noted that check no. 90 to 
the DNC--a check drawn on a Washington, DC, bank--bears a 
Garland, Texas, address in unidentified handwriting.\383\
---------------------------------------------------------------------------
    \378\ Citizens Bank Signature Card of Lei Chu (Exhibit 221); 
Citizens Bank Deposit Ticket of Lei Chu in the amount of $12,520, Feb. 
20, 1996 (Exhibit 222); Citizens Bank Cash In Ticket of Lei Chu 
(Exhibit 223); Citizens Bank Checking Account Statement of Lei Chu, 
Mar. 15, 1996 (Exhibit 224); Currency Transaction Report by Form 4789 
for Lei Chu, H01805 (Exhibit 225).
    \379\ Exhibit 224 Citizens Bank Checking Account Statement of Lei 
Chu, Mar. 15, 1996; Citizens Bank Check No. 90 from Lei Chu to the DNC 
in the amount of $12,500 (Exhibit 226).
    \380\ DNC Check Tracking Form for Citizens Bank Check No. 90 from 
Lei Chu to the DNC in the amount of $12,500, 000525 (Exhibit 227).
    \381\ Exhibit 224 Citizens Bank Checking Account Statement of Lei 
Chu, Mar. 15, 1996.
    \382\ Id.; Citizens Bank Checking Account Statement of Lei Chu, 
Apr. 15, 1996 (Exhibit 228); Citizens Bank Checking Account Statement 
of Lei Chu, May 15, 1996 (Exhibit 229); Citizens Bank Checking Account 
Statement of Lei Chu, June 17, 1996 (Exhibit 230); Citizens Bank 
Checking Account Statement of Lei Chu, July 16, 1996 (Exhibit 231).
    \383\ Exhibit 226 Citizens Bank Check No. 90 from Lei Chu to the 
DNC in the amount of $12,500.
---------------------------------------------------------------------------
    DNC contribution information lists John Huang as the DNC 
Contact for Chu's contribution.\384\ Trie solicited her 
contribution and his telephone number was provided as Chu's 
contact number.\385\ It was Chu's apparent link to Huang and 
Trie that led to a review of her contribution.\386\ Ernst & 
Young was unable to confirm the Garland, Texas, address 
provided by Chu.\387\ In addition, the notation ``Bad #'' was 
inscribed by the Ernst & Young auditor beside the telephone 
numbers provided by Chu.\388\ The Research Information Form was 
labeled ``No Info.'' \389\ Finally, Chu's Ernst & Young file 
was labeled ``DER'' for Dead End Research.\390\ The DNC 
received no helpful information as a result of its review. Chu 
has fled the United States and is believed to be living in 
Taiwan.\391\ The Committee has been unable to contact her.
---------------------------------------------------------------------------
    \384\ Exhibit 227 DNC Check Tracking Form for Citizens Bank Check 
No. 90 from Lei Chu to the DNC in the amount of $12,500, 000525.
    \385\ Id.
    \386\ DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 36-37.
    \387\ Ernst & Young Contribution Review Materials for Lei Chu, DNC 
1804805, DNC 1804808, DNC 1804810, and DNC 1804821-DNC 1804822, at 2 
and 4 (Exhibit 232).
    \388\ Id. at 5.
    \389\ Id. at 4.
    \390\ Id. at 1. The Committee has received no evidence of IGI's 
participation in this audit.
    \391\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, Interview of Mr. and Mrs. Chu Shuo Po, May 22, 
1997.
---------------------------------------------------------------------------
    In recent interrogatories to the DNC, the Committee 
requested information regarding Chu's contribution. The DNC 
responded:

        The DNC has not returned the referenced contribution 
        from Lei Chu because the information developed during 
        the DNC's review of prior contributions met the 
        criteria for retaining a contribution as set forth in 
        ``DNC In-Depth Contribution Review,'' at page 3.\392\
---------------------------------------------------------------------------
    \392\ DNC's Response to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 37.

Despite the paucity of information gathered pursuant to the 
Ernst & Young review, the DNC decided to retain Chu's $12,500 
contribution.\393\ That fact notwithstanding, based on Trie's 
proven history of using conduits to contribute to the DNC \394\ 
and the suspicious activity evidenced by Lei Chu's bank 
records, the evidence indicates that her $12,500 was an illegal 
conduit contribution in violation of 2 U.S.C. Sec. 441f. 
Therefore, pursuant to Federal regulations and DNC practice, 
the DNC should disgorge Chu's $12,500 contribution to the U.S. 
Treasury.\395\
---------------------------------------------------------------------------
    \393\ Id.
    \394\ It deserves mention that Trie was given credit by the DNC for 
soliciting the $100,000 contribution of Jimswood International, Inc. 
(``Jimswood'') of Los Angeles, CA. Almost every contribution for which 
Trie was listed as the solicitor has been determined to be illegal. 
However, the Committee has determined Jimswood's contribution to be 
legal. Interestingly, this is not an instance of Trie soliciting a 
legal contribution. Instead, according to Davisson Wu of Jimswood, Trie 
did not solicit the $100,000 contribution. Wu is uncertain why Trie was 
given credit for soliciting his contribution. See generally Letter from 
Roy H. Aron to Tim Griffin, Esq., Sept. 17, 1998 (discussing Jimswood's 
contribution and complementing the Committee's investigation for its 
professionalism) (Exhibit 233).
    \395\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

              J & M International, Inc. $25,000 (Illegal)

    On February 17, 1996, ex-Lippo executive and business 
associate of Trie, Antonio Pan, entered the United States at 
John F. Kennedy International Airport, New York, New York.\396\ 
Two days later, on February 19, 1996, Pan, Trie, and Huang 
attended the DNC Hay Adams Hotel fund-raiser.\397\ The next 
day, at 2:45 p.m., Pan, Trie's business partner Ng Lap Seng 
a.k.a. Mr. Wu, Trie's personal assistant Lei Chu and 
approximately 15 other individuals entered the White House for 
a tour arranged by DNC White House Liaison Susan Lavine.\398\
---------------------------------------------------------------------------
    \396\ U.S. Customs Records for Antonio Y.P. Pan (Exhibit 234).
    \397\ Photograph of Antonio Y.P. Pan at the DNC Feb. 19, 1996, 
Fund-raiser, Hay-Adams Hotel, Washington, DC (Exhibit 235); Photograph 
of Yah Lin ``Charlie'' Trie at the DNC Feb. 19, 1996, Fund-raiser, Hay-
Adams Hotel, Washington, DC (Exhibit 236); Photograph of John and Jane 
Huang at the DNC Feb. 19, 1996, Fund-raiser, Hay-Adams Hotel, 
Washington, DC (Exhibit 237).
    \398\ White House Memorandum from Molly (Last Name Unknown) to 
WAVES, Feb. 20, 1996, EOP 056859 (Exhibit 238).
---------------------------------------------------------------------------
    On February 22, 1996, Pan visited his long-time friend Su 
Cheng Bin in Flushing, New York.\399\ Pan asked Su if he was 
interested in attending a DNC fund-raiser where President 
Clinton would be in attendance.\400\ Su declined.\401\ Pan then 
inquired if Su had any friends who might be interested in 
attending.\402\ Su suggested his friend Jack Ho, President of J 
& M International, Inc. (``J & M''), a travel agency, and 
subsequently that same day introduced Pan to Ho in a meeting at 
the Sheraton LaGuardia East Hotel.\403\ Pan explained to Ho and 
Su that, due to his immigration status, he was unable to 
contribute to the DNC legally and, therefore, needed Ho to 
contribute on his behalf.\404\ Although Su was wary of this 
arrangement, Ho agreed to do as Pan requested.\405\
---------------------------------------------------------------------------
    \399\ Committee Interview of Su Cheng Bin, Aug. 13, 1998.
    \400\ Id.
    \401\ Id.
    \402\ Id.
    \403\ Id.
    \404\ Id.
    \405\ Id.
---------------------------------------------------------------------------
    At the same February 22, 1996, meeting of Pan, Su, and Ho, 
ex-Lippo executive Pan delivered to Jack Ho 35 $1,000 Bank 
Central Asia travelers check totaling $35,000,\406\ all of 
which were purchased as part of a $200,000 block in Jakarta, 
Indonesia--home of the Lippo Group and the Riadys.\407\ At 
Pan's request, Ho cashed $10,000 in travelers checks for Pan at 
Citibank, 38-11-17 Main Street, Flushing, New York: Ho cashed 
five of the checks totaling $5,000 \408\ and deposited the 
other five totaling $5,000.\409\ Ho then immediately cashed a 
check in the amount of $5,000.\410\ Ho then handed the $10,000 
cash over to Pan.\411\
---------------------------------------------------------------------------
    \406\ Id.; Bank Central Asia Travelers Checks Nos. 109 3255 610 009 
through 109 3255 610 043 (Exhibit 239); see Citibank Checking Account 
Statement for J & M International, Feb. 23, 1996 (Exhibit 240); 
Citibank Deposit Ticket and Deposited Items of J & M International in 
the amount of $5,000, Feb. 22, 1996 (Exhibit 241); Citibank Deposit 
Ticket and Deposited Items of J & M International in the amount of 
$25,000, Feb. 22, 1996 (Exhibit 242).
    \407\ See generally Exhibit 84 Letter from Christopher M. Curran, 
Esq., Attorney for Bank Central Asia, to Committee Senior Investigative 
Counsel Tim Griffin, Esq., July 20, 1998.
    \408\ Exhibit 239 Bank Central Asia Travelers Checks Nos. 109 3255 
610 039 through 109 3255 610 043.
    \409\ Exhibit 240 Citibank Checking Account Statement for J & M 
International, Feb. 23, 1996; Exhibit 241 Citibank Deposit Ticket and 
Deposited Items of J & M International in the amount of $5,000, Feb. 
22, 1996.
    \410\ Citibank Check No. 728 from J & M International to Cash in 
the amount of $5,000, Feb. 22, 1996 (Exhibit 243).
    \411\ Committee Interview of Jack Ho, July 30, 1998; see generally 
Id.
---------------------------------------------------------------------------
    Ho divided the cashing of the $10,000 into multiple 
transactions apparently at the instruction of Pan in an effort 
to circumvent the generation of a cash transaction report 
(``CTR'').\412\ Under Federal law, a CTR must be filed in 
conjunction with any cash transaction involving $10,000 or 
more.\413\ It is a Federal crime to avoid the generation of a 
CTR purposefully \414\--a practice commonly referred to as 
``smurfing'' \415\--which appears to be the case here.
---------------------------------------------------------------------------
    \412\ See generally 31 U.S.C. Sec. 5313; 31 C.F.R. Sec. 103.22.
    \413\ Id.
    \414\ 31 U.S.C. Sec. 5322.
    \415\ ``Smurfs, Money Laundering, and the Federal Criminal Law: The 
Crime of Structuring Transaction,'' Sarah N. Welling, 41 Fla. L. Rev. 
287, 288, Spring 1989.
---------------------------------------------------------------------------
    During that same visit to Citibank, Ho deposited $25,000 in 
travelers checks into the account of J & M \416\ and 
immediately thereafter issued a check in the amount of $25,000 
\417\ to the DNC in conjunction with the DNC's Asian Dinner 
fund-raiser at the Hay Adams Hotel, a fund-raiser that had been 
held 3 days prior.\418\ As indicated previously, the Hay Adams 
fund-raiser failed to raise the funds expected.\419\ That 
shortfall explains Huang's attribution of Ho's contribution to 
the Hay Adams fund-raiser.\420\ Similarly, as discussed below, 
in conjunction with the Hay Adams event, Trie and Pan funneled 
$25,000 through Trie's sister, Manlin Foung, and her boyfriend, 
Joseph Landon--$12,500 each--on the same day, February 22, 
1996, several days after the Hay Adams fund-raiser.\421\
---------------------------------------------------------------------------
    \416\ Exhibit 240 Citibank Checking Account Statement for J & M 
International, Feb. 23, 1996; Exhibit 242 Citibank Deposit Ticket and 
Deposited Items of J & M International in the amount of $25,000, Feb. 
22, 1996; Exhibit 239 Bank Central Asia Travelers Checks Nos. 109 3255 
610 014 through 109 3255 610 038.
    \417\ Citibank Check No. 730 from J & M International to the DNC in 
the amount of $25,000, Feb. 23, 1996 (Exhibit 244); Citibank Checking 
Account Statement of J & M International, Mar. 22, 1996 (Exhibit 245).
    \418\ DNC Check Tracking Form for Citibank Check No. 730 from J & M 
to the DNC in the amount of $25,000, 000524 (Exhibit 246).
    \419\ Committee Interview of Tony Hsu, Sept. 3, 1997.
    \420\ See generally Exhibit 246 DNC Check Tracking Form for 
Citibank Check No. 730 from J & M to the DNC in the amount of $25,000, 
000524.
    \421\ Committee Deposition of Manlin Foung, Sept. 29, 1997; 
Committee Interview of Joseph Landon, Sept. 4, 1997; see Amerasia Bank 
Signature Card of Antonio Pan, Feb. 22, 1996 (Exhibit 247); Amerasia 
Bank Personal New Account Application of Antonio Pan, Feb. 22, 1996 
(Exhibit 248); Amerasia Bank Savings Account Statement of Antonio Pan, 
Mar. 31, 1996 (Exhibit 249); Amerasia Bank Savings Deposit Ticket of 
Antonio Pan, Feb. 22, 1996 (Exhibit 250); Amerasia Bank Savings 
Withdrawal Ticket of Antonio Pan, Feb. 22, 1996 (Exhibit 251); Amerasia 
Bank Applications of Antonio Pan for three $5,000 Cashier's Checks to 
Manlin Foung, Feb. 22, 1996 (Exhibit 252); Amerasia Bank Applications 
of Antonio Pan for two $5,000 Cashier's Checks to Joe Landon, Feb. 22, 
1996 (Exhibit 253); Three $5,000 Amerasia Bank Cashier's Checks to 
Manlin Foung, Feb. 22, 1996 (Exhibit 254); Two $5,000 Amerasia Bank 
Cashier's Checks to Joe Landon, Feb. 22, 1996 (Exhibit 255); Currency 
Transaction Report by Form 4789 for Antonio Pan, Feb. 22, 1996 (Exhibit 
256); Amerasia Bank Savings Account Statements of Antonio Pan, June 30, 
1996, Sept. 30, 1996, Dec. 31, 1996, Mar. 31, 1997, and June 30, 1997 
(showing no other account activity from Mar. 31, 1996, through June 30, 
1997) (Exhibit 257); see also Travis Federal Credit Union Deposit 
Ticket of Manlin Foung in the $14,500, Feb. 23, 1996 (Exhibit 258); 
Three Deposited $5,000 Amerasia Bank Cashier's Checks to Manlin Foung, 
Feb. 22, 1996 (Exhibit 259); Travis Federal Credit Union Check No. 390 
from Manlin Foung to the DNC in the amount of $12,500, Feb. 19, 1996 
(Exhibit 260); Travis Federal Credit Union Posted Transaction Register 
for the Checking Account of Manlin Foung (Exhibit 261); DNC Check 
Tracking Form for Travis Federal Credit Union Check No. 390 from Manlin 
Foung to the DNC in the amount of $12,500, Feb. 19, 1996 (Exhibit 262); 
DNC Check Tracking Form for Travis Federal Credit Union Check No. 1337 
from Joseph Landon to the DNC in the amount of $12,500, Feb. 19, 1996 
(Exhibit 263); see also http://wyl.ewg.org, Environmental Working Group 
Website, Compiled from FEC Data, Last Updated Sept. 10, 1998.
---------------------------------------------------------------------------
    A document produced to the Committee by the DNC lists Trie 
as the solicitor and John Huang as the DNC contact for J & M's 
contribution.\422\ It was Ho's apparent link to Trie and Huang 
that led to an Ernst & Young review of his contribution.\423\ 
The auditor unsuccessfully attempted to contact Ho on at least 
five separate occasions.\424\ On one such occasion, December 9, 
1996, the auditor contacted Maria Ho, Jack Ho's wife, regarding 
J & M's contribution.\425\ The auditor noted that ``[s]he was 
not willing to talk to us.'' \426\ Subsequently, on December 
17, 1996, the auditor made her final attempt to reach Jack 
Ho.\427\ Her handwritten notes were as follows:
---------------------------------------------------------------------------
    \422\ Exhibit 246 DNC Check Tracking Form for Citibank Check No. 
730 from J & M to the DNC in the amount of $25,000, 000524.
    \423\ See DNC's Responses to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 7.
    \424\ Ernst & Young Contribution Review Materials for Jack Ho/J & M 
International, DNC 1802501, DNC 1802504, DNC 1802505-DNC 1802506, and 
DNC 1802508, at 2 (Exhibit 264).
    \425\ Id.
    \426\ Id.
    \427\ Id.

        Spoke with receptionist. She said Jack Ho was not in 
        the office & that they do not need to answer any 
        questions. Very angry & hung up on me.\428\
---------------------------------------------------------------------------
    \428\ Id.

The DNC received no helpful information as a result of its 
review. Ho's Ernst & Young file was labeled ``Term[inated].'' 
\429\
---------------------------------------------------------------------------
    \429\ Id. at 1.
---------------------------------------------------------------------------
    After the Ernst & Young review, IGI gathered a limited 
amount of additional publicly available information regarding 
Ho and J & M.\430\ The DNC did not receive any information 
directly from Jack Ho regarding his contributions.\431\ 
However, through IGI, the DNC was able to determine that his 
Social Security number had been valid for over 30 years at the 
time of the contribution \432\ and that his home had an 
assessed value of $272,500.\433\ This information evidently 
provided the DNC with the minimum information needed to 
conclude that the contribution was legal and appropriate; the 
DNC retained the contribution.
---------------------------------------------------------------------------
    \430\ IGI Contribution Review Materials for Jack Ho/J & M 
International, HS 006020-HS 006031, at 1-12 (Exhibit 265). Experience 
indicates that ``IGI Contribution Review Materials'' often contain 
documents generated pursuant to the Ernst & Young Contribution review 
process. The converse is not true because the Ernst & Young phase was 
conducted prior to the IGI phase.
    \431\ See Exhibit 264 Ernst & Young Contribution Review Materials 
for Jack Ho/J & M International, DNC 1802501, DNC 1802504, DNC 1802505-
DNC 1802506, and DNC 1802508, at 2.
    \432\ Exhibit 265 IGI Contribution Review Materials for Jack Ho/J & 
M International, HS 006020-HS 006031, at 6. The DNC was also able to 
determine that Maria Ho's Social Security number had been valid for 
approximately 30 years. Id.
    \433\ Id.
---------------------------------------------------------------------------
    Despite the paucity of information gathered pursuant to the 
Ernst & Young and IGI reviews, the DNC decided to retain the 
contribution in the face of mounting evidence that both Trie 
and Huang were generating illegal contributions. The DNC 
apparently decided that it had sufficient information to 
declare the $25,000 contribution appropriate and retain it 
without one scintilla of cooperation from Ho. DNC Spokesman 
Rick Hess indicated recently that:

        [The DNC] would have returned [the $25,000] if we had 
        any hint that they were [sic] foreign sources or if the 
        company had insufficient funds. Every indication was 
        that it was legal and proper.\434\
---------------------------------------------------------------------------
    \434\ Mary Ann Akers, ``GOP Probers Report $50,000 in Illegal 
Donations via Trie,'' Washington Times, Aug. 5, 1998.

    The exact opposite is true: there was practically no 
information indicating the contribution was ``legal and 
proper.'' The DNC's determination notwithstanding, based on 
Committee interviews and the conclusive activity evidenced by 
Ho's bank records, J & M's $25,000 was an illegal conduit 
contribution in violation of 2 U.S.C. Sec. 441f. In addition, 
the funds used to make the contribution--the travelers checks--
ultimately originated in Indonesia. Therefore, pursuant to 
Federal regulations and DNC practice, the DNC should disgorge J 
& M's illegal $25,000 contribution to the U.S. Treasury.\435\
---------------------------------------------------------------------------
    \435\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq. to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

    Ted Sioeng Related Contributions During the 1996 Election Cycle

    During the 1996 Federal election cycle, courted by fund-
raiser John Huang, Ted Sioeng's family and associates 
contributed $400,000 to the DNC.\436\ A review of bank records 
strongly suggests that $310,000 of the contributions were 
ultimately funded from foreign accounts in Hong Kong and 
Indonesia. The remaining $90,000, while funded from U.S. 
receipts, remains suspect due to large and continuing foreign 
subsidies to the family's U.S. businesses from family patriarch 
and Belize national Ted Sioeng. The result of these subsidies 
was often a commingling of domestic receipts and foreign funds 
in accounts from which political contributions were made.
---------------------------------------------------------------------------
    \436\ Note that Sioeng and his company, Panda Estates, contributed 
a total of $100,000 to California State Treasurer Matt Fong in 1995. 
Matt Fong returned the money in Apr. 1997.
---------------------------------------------------------------------------
    Additional questions are raised by the Sioeng family's 
deafening silence on the subject of its political 
contributions. All of the Sioeng family members and those 
associates closest to the family have either asserted the Fifth 
Amendment, left the country, or are foreign nationals who have 
refused to be interviewed. The fact that the people most likely 
to know about the Sioeng family's political contributions 
uniformly have refused to talk to the Committee about the 
contributions, casts great doubt on whether they meet 
applicable legal and regulatory requirements, or are 
appropriate for the DNC to retain under the circumstances.
    The Committee remains particularly concerned about Sioeng-
related contributions because of Sioeng's close ties to the 
government of the People's Republic of China (``PRC''). In the 
report of its investigation into campaign finance abuses, the 
Senate Committee on Governmental Affairs stated the following 
about Sioeng's PRC connections:

        The Committee has learned that Sioeng worked, and 
        perhaps still works, on behalf of the Chinese 
        government. Sioeng regularly communicated with PRC 
        embassy and consular officials at various locations in 
        the United States, and, before the campaign finance 
        scandal broke, he traveled to Beijing frequently where 
        he reported to and was briefed by Chinese communist 
        party officials. . . . The Committee has received 
        information that [indicted DNC fund-raiser Maria] Hsia 
        worked with Ted Sioeng and John Huang to solicit 
        contributions from Chinese nationals in the United 
        States and abroad for Democratic causes.\437\
---------------------------------------------------------------------------
    \437\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 2, 
2505-2507 (1998).
---------------------------------------------------------------------------

   A. Jessica Elnitiarta and Panda Estates Investment, Inc.; Jessica 
                     Elnitiarta $100,000 (Illegal)

    Jessica Elnitiarta is Ted Sioeng's oldest daughter. She is 
a U.S. citizen who, at her father's behest, runs the family 
businesses in the United States. She also makes more political 
contributions than any other family member. On February 19, 
1996, Jessica Elnitiarta wrote a personal check for $100,000 to 
the DNC \438\ against a bank account balance of only 
$9,225.\439\ Elnitiarta took steps to cover the check 3 days 
later: on February 22, 1996, Elnitiarta, using a power of 
attorney, transferred $200,000 from the personal bank account 
of Ted Sioeng's sister, Yanti Ardi,\440\ an Indonesian 
national, to her own account. This $200,000 came from a 
$518,434 wire transfer 10 days earlier from Pristine 
Investments in Hong Kong.\441\ It is likely that Pristine 
Investments is owned or controlled by Ted Sioeng.
---------------------------------------------------------------------------
    \438\ DNC Check Tracking Form for Grand National Bank Check No. 575 
from Jessica G. Elnitiarta to the DNC in the amount of $100,000, Feb. 
19, 1996 (Exhibit 266).
    \439\ Grand National Bank Account Statement of Jessica G. 
Elnitiarta, Feb. 29, 1996 (Exhibit 267).
    \440\ Grand National Bank Customer Authorization for Funds Transfer 
of Jessica Elnitiarta in the amount of $200,000, Feb. 22, 1996 (Exhibit 
268).
    \441\ Grand National Bank Credit Ticket of Yanti Ardi in the amount 
of $518,433.56, Feb. 12, 1996, and Wire Transfer Report of Yanti Ardi 
and Pristine Investments in the amount of $518,434, Feb. 12, 1996 
(Exhibit 269).
---------------------------------------------------------------------------
    In short, this $100,000 contribution was funded by 
ineligible foreign money and should be returned by the DNC. 
This transfer of funds from foreign sources is part of a 
pattern that recurs throughout the brief but curious history of 
Sioeng-related contributions to the DNC.

   Panda Estates Investment, Inc. $100,000 ($60,000 Illegal/$40,000 
                                Suspect)

    On July 12, 1996, Jessica Elnitiarta, as president of Panda 
Estates Investment, Inc. (``Panda Estates''), signed a $100,000 
company check to the DNC \442\ against a negative bank account 
balance of -$599.\443\ The check cleared the bank on July 25, 
1996, causing a negative bank balance of $100,125.\444\ On July 
26, 1996, Elnitiarta transferred -$100,000 from a Panda Estates 
receipts account toward the overdraft.\445\ Of this transfer, 
$60,000 came from Yanti Ardi's personal bank account,\446\ 
which in turn was funded by a $1,652,480 wire transfer on June 
28, 1996 from R.T. Enterprises in Hong Kong.\447\ The remaining 
$40,000 was funded by a transfer from a Panda Estates receipts 
account that consisted of domestic rents collected for the 
month of July 1996.\448\ In short, this contribution of 
$100,000 was funded primarily with foreign money and, hence, 
should be returned.
---------------------------------------------------------------------------
    \442\ DNC Check Tracking Form for Grand National Bank Check No. 
1632 from Panda Estates to the DNC in the amount of $100,000, July 12, 
1996 (signed by Jessica Elnitiarta) (Exhibit 270).
    \443\ Grand National Bank Account Statement of Panda Estates Bank 
Statement, July 31, 1996 (Exhibit 271).
    \444\ Id.
    \445\ Grand National Bank Customer Authorization for Funds Transfer 
of Panda Estates in the amount of $100,000, July 26, 1996 (Exhibit 
272).
    \446\ Grand National Bank Deposit Ticket of Panda Estates in the 
amount of $60,000, July 26, 1996, and Grand National Bank Deposited 
Check No. 2309 from Yanti Ardi to Panda Estates in the amount of 
$60,000, July 26, 1996 (signed by Jessica Elnitiarta) (Exhibit 273).
    \447\ Grand National Bank Credit Ticket of Yanti Ardi in the amount 
of $1,652,479.98, June 28, 1996, and Grand National Bank Wire Transfer 
Report of Yanti Ardi and R.T. Enterprises in the amount of $1,652,480, 
June 28, 1996 (Exhibit 274). Based upon an analysis of bank records and 
financial transactions, it appears that R.T. Enterprises is a Sioeng 
owned or controlled company. The Sioeng family attorneys refused the 
Committee's requests to share information on this and other foreign 
entities with clear financial ties to Sioeng's holdings in the United 
States.
    \448\ Grand National Bank Account Statement of Panda Estates, July 
31, 1996 (showing seventeen deposits of July rents into the Panda 
Estates receipts bank account totaling $48,411 from July 5 through July 
22, 1996) (Exhibit 275).
---------------------------------------------------------------------------

            Panda Estates Investment, Inc. $50,000 (Suspect)

    On July 29, 1996, Jessica Elnitiarta signed a $50,000 
company check to the DNC \449\ from Panda Estates against a 
negative bank account balance of -$2,351.\450\ The check 
cleared the bank on August 5, 1996 causing a -$48,198 
overdraft.\451\ The next day, Elnitiarta covered part of the 
overdraft through a $40,000 transfer of domestic rental 
receipts for the month of August 1996.\452\ The remaining 
overdraft was covered by an August 6, 1996 transfer of $10,000 
from the bank account of Code 3 USA (``Code 3''), the family's 
gun and ammunition business, operated by Elnitiarta's husband, 
Ridwan Dinata.\453\ This transfer came from an August 5, 1996 
advance of $10,000 against Code 3's $250,000 bank credit 
line.\454\ On September 10, 1996, Elnitiarta appears to have 
repaid Code 3 the $10,000 from her personal bank account.\455\
---------------------------------------------------------------------------
    \449\ DNC Check Tracking Form for Grand National Bank Check No. 
1652 from Panda Estates to the DNC in the amount of $50,000, July 29, 
1996 (signed by Jessica Elnitiarta) (Exhibit 276).
    \450\ Grand National Bank Account Statement of Panda Estates, July 
31, 1996 (Exhibit 277).
    \451\ Grand National Bank Account Statement of Panda Estates, Aug. 
30, 1996 (Exhibit 278).
    \452\ Grand National Bank Customer Authorization for Funds Transfer 
of Panda Estates in the amount of $40,000, Aug. 6, 1996 (transfer from 
Panda Estates receipts account to Panda Estates disbursement account) 
(Exhibit 279).
    \453\ Grand National Bank Customer Authorization for Funds Transfer 
of Code 3 in the amount of $10,000, Aug. 6, 1996 (Ridwan Dinata's 
transfer of $10,000 from Code 3's account to Panda Estates' Account) 
(Exhibit 280).
    \454\ Grand National Bank Customer Authorization for Funds Transfer 
of Ridwan Dinata in the amount of $10,000, Aug. 5, 1996 (telephone 
transfer of $10,000 from Code 3's loan account to its checking account) 
(Exhibit 281).
    \455\ Grand National Bank Deposit Ticket of Code 3 in the amount of 
$10,000, Sept. 10, 1996, and Grand National Bank Check No. 255 from 
Jessica Elnitiarta to Code 3 in the amount of $10,000, Sept. 10, 1996 
(Exhibit 282).
---------------------------------------------------------------------------
    In conclusion, this $50,000 contribution appears to have 
been funded by domestic rental receipts. Nevertheless, Ted 
Sioeng's probable involvement with this and the two other DNC 
contributions made by his daughter, Jessica, raises troubling 
and severe doubts about the legality of the $50,000 
contribution.

                               conclusion

    Ted Sioeng's probable involvement with the $250,000 in 
contributions made to the DNC by Jessica Elnitiarta and her 
company raises serious questions about the legality of those 
contributions, all of which have been retained by the DNC.
    Note that the DNC is adamant that it has not seen 
information about the Panda Estates and Elnitiarta 
contributions sufficiently troubling to return the money. On 
May 14, 1998, the Committee deposed DNC General Counsel Sandler 
on the subject of the Sioeng-related contributions as well as 
DNC guidelines concerning what types of contributions it 
accepts and retains. Prior to the deposition, Sandler had never 
seen records of the bank accounts from which the Elnitiarta and 
Panda Estates contributions were made.\456\ Confronted with 
records that showed Elnitiarta's contribution was made with 
foreign money, Sandler became incensed, insisting that the 
``information tells us virtually nothing that we would need to 
know to determine whether the contribution was an illegal 
contribution in the name of another,'' and that the foreign 
money may have been Elnitiarta's.\457\ Of course, the point is, 
the Committee has no way of directly determining whether the 
foreign money was Elnitiarta's as she and her entire family 
refuse to discuss the contribution. While this remains 
troubling to the Committee, it apparently does not to the DNC.
---------------------------------------------------------------------------
    \456\ Committee Deposition of Joseph E. Sandler, May 14, 1998, 103.
    \457\ Id. at 121-122.
---------------------------------------------------------------------------
    When shown that a large portion of the contribution made by 
Panda Estates came from foreign funds, Sandler put forward the 
confusing contention that, even if one could trace a 
corporation's political contribution to a foreign source, the 
contribution would still be legal if the company had sufficient 
income over some longer period, say a year.\458\ This argument 
makes no intuitive sense and is contradicted by FEC practice 
and precedent.\459\ Moreover, whether or not Ted Sioeng made 
actual conduit contributions through his daughter and family 
business, Panda Estates Investment, his likely participation in 
the decision to have Panda Estates contribute to the DNC 
violates Federal campaign regulations. FEC regulations prohibit 
individuals who are foreign nationals from directing, 
dictating, controlling, or participating in decisionmaking 
processes through which a domestic corporation decides to make 
a political contribution.\460\ Committee witnesses have 
indicated that Ted Sioeng played a significant role in his 
daughter's business decisions. Given that Jessica Elnitiarta 
has pled the Fifth Amendment to the Committee, there should be 
a presumption that the foreign money is not entirely legal, and 
it should be returned.
---------------------------------------------------------------------------
    \458\ Id. at 162.
    \459\ See FEC Advisory Opinion 1992-16 (Noting in the context of a 
U.S. subsidiary of a foreign company that ``the subsidiary must be able 
to demonstrate through a reasonable accounting method that it has 
sufficient funds in its account, other than funds given or loaned by 
its foreign national parent, from which the contribution is made. See 
by analogy 11 CFR (102.5(b)(1)(ii).'').
    \460\ See 11 CFR Sec. 110.4(a)(3). Note that the prohibition 
extends to persons as well. Hence, under Federal regulations, a foreign 
national may not ``directly or indirectly participate in the decision-
making process of any person'' with regard to a political contribution. 
Id.
---------------------------------------------------------------------------
    California Treasurer, Matt Fong received a total of 
$100,000 in contributions from Ted Sioeng and his company Panda 
Estates Investment. In stark contrast to the DNC, Fong returned 
these contributions in April 1997, immediately after questions 
were raised regarding their legality in the press.

               B. Loh Sun International $50,000 (Suspect)

    On July 29, 1996, the same day as Jessica Elnitiarta wrote 
the above $50,000 check to the DNC, Ted Sioeng associate Kent 
La, a U.S. permanent resident, also wrote a $50,000 check to 
the DNC.\461\ La is president of Loh Sun International, a Los 
Angeles-based importer of Chinese cigarettes and other 
commodities. Kent La signed a company check to the DNC against 
a July 29, 1996 bank balance of $262,185.\462\ Five days 
earlier, on July 24, 1996, the company account had received a 
$97,555 wire transfer from R.T. Enterprises in Hong Kong,\463\ 
which appears to be owned or controlled by Ted Sioeng. Although 
documentation of the wire transfer indicates the funds were for 
``Hongtashan Advertising,'' \464\ the amount of the transfer 
and its proximity to Loh Sun's contribution to the DNC raise 
questions about its true purpose and use.
---------------------------------------------------------------------------
    \461\ DNC Check Tracking Form for United Pacific Bank Check No. 
3881 from Loh Sun International to the DNC in the amount of $50,000, 
July 29, 1996 (signed by Kent La) (Exhibit 283).
    \462\ United Pacific Account Statement of Loh Sun International, 
July 31, 1996 (Exhibit 284).
    \463\ United Pacific Bank Credit Ticket of Loh Sun International in 
the amount of $97,555, July 24, 1996, and United Pacific Bank Wire 
Transfer Report of Loh Sun International and R.T. Enterprises in the 
amount of $97,555, July 24, 1996 (Exhibit 285).
    \464\ Id.
---------------------------------------------------------------------------
    Moreover, the mystery surrounding this contribution is 
compounded by a check signed by Kent La on an account with his 
wife, Nancy.\465\ The check, dated October 28, 1996 in the 
amount of $20,000, is payable to Loh Sun International, but was 
not deposited until December 23, 1996. On the memo line La 
wrote, ``Donation to DNC--7/29/96.'' It is unclear why La would 
reimburse his own company for a political contribution. One 
explanation is that he was attempting to ``cure,'' after the 
fact, a conduit contribution funded by Ted Sioeng with foreign 
funds. While La has been deposed by Committee staff, the 
transcript has not been made public. The DOJ has asked the 
Committee not to release any part of the deposition transcript 
as doing so ``would jeopardize [the Department's] pending 
criminal investigation relating to Mr. La.'' \466\
---------------------------------------------------------------------------
    \465\ Grand National Bank Check No. 143 from Kent and Nancy La to 
Loh Sun International in the amount of $20,000, Oct. 28, 1996 (Exhibit 
286).
    \466\ Letter from L. Anthony Sutin, Acting Assistant Attorney 
General, to Chairman Dan Burton, Aug. 28, 1998.
---------------------------------------------------------------------------

                       C. The Tanuwidjaja Family

     Subandi Tanuwidjaja $80,000 ($20,000 Illegal/$60,000 Suspect)

    Within 10 days in September 1996, the Tanuwidjaja family, 
to which the Sioeng family is related through marriage and 
business interests, made three contributions to the DNC 
totaling $100,000 as follows:
    On September 9, 1996, Ted Sioeng's son-in-law, Subandi 
Tanuwidjaja, a U.S. permanent resident, signed a $60,000 
personal check to the DNC \467\ against a U.S. bank balance of 
$66,050.\468\ Three days before, the account received a 
$100,000 personal check from the U.S. bank account of his 
father, Susanto Tanuwidjaja, an Indonesian national.\469\ 
Susanto's check was funded by a $100,000 wire transfer on 
August 21, 1996 from an Indonesian bank account in the name of 
Subandi Tanuwidjaja.\470\ The fact that the foreign money was 
wired into Susanto's U.S. bank account and not his son's 
suggests that the money may have been his, and raises questions 
about the legality of the contribution. It thus appears that 
this $60,000 contribution may have been funded by foreign money 
and by a foreign national and should be returned by the DNC.
---------------------------------------------------------------------------
    \467\ DNC Check Tracking Form for Western State Bank Check No. 134 
from Subandi Tanuwidjaja to the DNC in the amount of $60,000, Sept. 9, 
1996 (Exhibit 287).
    \468\ Western State Bank Account Statement of Subandi Tanuwidjaja, 
Sept. 13, 1996 (Exhibit 288).
    \469\ Western State Bank Check No. 1026 from Susanto Tanuwidjaja to 
Subandi Tanuwidjaja in the amount of $100,000, Sept. 6, 1996, and 
Western State Bank Deposit Ticket of Subandi Tanuwidjaja in the amount 
of $100,000, Sept. 9, 1996 (Exhibit 289).
    \470\ Western State Bank Wire Transfer Report of Susanto 
Tanuwidjaja and Subandi Tanuwidjaja in the amount of $99,985, Aug. 21, 
1996 (transfer from Subandi Tanuwidjaja to Susanto Tanuwidjaja) 
(Exhibit 290).
---------------------------------------------------------------------------
    On September 19, 1996, Subandi Tanuwidjaja signed a $20,000 
personal check to the DNC\471\ against a bank balance of 
$25,640.\472\ The day before, the account received a $20,000 
wire transfer from Dragon Union, Ltd. in Hong Kong.\473\ 
Subandi Tanuwidjaja is Dragon Union's sole corporate 
director.\474\ It thus appears that this $20,000 contribution 
was funded by foreign money and should be returned by the DNC.
---------------------------------------------------------------------------
    \471\ DNC Check Tracking Form for Check No. 136 from Subandi 
Tanuwidjaja to the DNC in the amount of $20,000, Sept. 19, 1996 
(Exhibit 291).
    \472\ Western State Bank Account Statement of Subandi Tanuwidjaja, 
Oct. 15, 1996 (Exhibit 292).
    \473\ Western State Bank Wire Transfer Report of Subandi 
Tanuwidjaja and Dragon Union in the amount of $20,000, Sept. 18, 1996 
(transfer from Dragon Union to Subandi Tanuwidjaja) (Exhibit 293).
    \474\ Dragon Union Limited Companies Ordinance on Change of 
Director Regarding Subandi Tanuwidjaja, Jan. 27, 1997 (Exhibit 294).
---------------------------------------------------------------------------

                 Suryanti Tanuwidjaja $20,000 (Illegal)

    On September 16, 1996, Ted Sioeng's daughter-in-law, 
Suryanti Tanuwidjaja, a U.S. permanent resident, signed a 
$20,000 personal check to the DNC \475\ against a bank balance 
of $61,726.\476\ Two days later, the account received a $20,000 
wire transfer from Dragon Union, Ltd. in Hong Kong.\477\ As 
noted, Suryanti's brother, Subandi, is Dragon Union's sole 
corporate director.
---------------------------------------------------------------------------
    \475\ DNC Check Tracking Form for Bank of America Check No. 1611 
from Suryanti Tanuwidjaja to the DNC in the amount of $20,000, Sept. 
16, 1996 (Exhibit 295).
    \476\ Bank of America Account Statement of Suryanti Tanuwidjaja, 
Sept. 27, 1996 (Exhibit 296).
    \477\ Bank of America Wire Transfer Report of Suryanti Tanuwidjaja 
and Dragon Union in the amount of $20,000, Sept. 18, 1996 (transfer 
from Dragon Union to Suryanti Tanuwidjaja) (Exhibit 297).
---------------------------------------------------------------------------
    Hence, although sufficient domestic funds existed at the 
time the DNC contribution check was written, the close 
proximity and same amount of the foreign wire transfer suggests 
that this $20,000 contribution was reimbursed by ineligible 
foreign money, and should be returned by the DNC. In this case, 
as with Subandi's $20,000 contribution, it appears that the 
Dragon Union transfers were intended to fund or reimburse the 
DNC contributions in the same amounts.

    Maria Hsia Related Contributions During the 1996 Election Cycle

         Chee Kien Koh a.k.a. the Rev. Hai Kai $5,000 (Illegal)

    On September 16, 1996, Chee Kien Koh a.k.a. the Rev. Hai 
Kai deposited into his checking account $3,000 cash and a 
$2,000 check from the International Buddhist Progress Society 
(``IBPS''),\478\ the organization that arranged the Hsi Lai 
Temple fund-raiser featuring Vice President Al Gore and 
facilitated a number of conduit contributions to the DNC in 
conjunction with that event and others.\479\ The next day, on 
September 17, 1996, Koh issued a check in the amount of $5,000 
to the DNC in conjunction with the DNC's September 18, 1996, 
Asian Dinner fund-raiser featuring Vice President Al Gore.\480\ 
Yi Chu, the Hsi Lai Temple's treasurer, testified to Senate 
investigators that Chee Kien Koh was reimbursed for his $5,000 
contribution to the DNC with a check from the IBPS in the 
amount of $3,000 and $2,000 cash, precisely what the bank 
records indicate.\481\
---------------------------------------------------------------------------
    \478\ Bank of America Deposit Ticket of Chee Kien Koh in the amount 
of $5,500, Sept. 16, 1996, Bank of America Cash Ticket of Chee Kien Koh 
in the amount of $3,000, Sept. 16, 1996, and General Bank Check No. 
4118 from IBPS to Cash in the amount of $2,000, Sept. 16, 1996 (Exhibit 
298); Bank of America Account Statement of Chee Kien Koh, Oct. 16, 1996 
(Exhibit 299).
    \479\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 2, 
1749-2497 (1998).
    \480\ Bank of America Check No. 0094 from Chee Kien Koh to the DNC 
in the amount of $5,000 (Exhibit 300). The check cleared Chee Kien 
Koh's Bank of America account on Sept. 26, 1996. Exhibit 299 Bank of 
America Account Statement of Chee Kien Koh, Oct. 16, 1996.
    \481\ Investigation of Illegal or Improper Activities in Connection 
with the 1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, Deposition of Yi Chu, 79-82, Aug. 7, 1997; 
Investigation of Illegal or Improper Activities in Connection with the 
1996 Federal Election Campaign Before the Senate Committee on 
Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d sess., vol. 2, 
1773, fn. 136 (1998).
---------------------------------------------------------------------------
    Interestingly, the DNC did not attribute Koh's contribution 
to Koh; they attributed it to Maria Hsia,\482\ a former DNC 
fund-raiser who pled the Fifth Amendment to both the Committee 
and the Senate and is currently under grand jury indictment for 
violating Federal election laws in conjunction with the Hsi Lai 
Temple fund-raiser.\483\ Koh's contribution was most likely 
attributed to Hsia due to her orchestration of conduit 
contributions through individuals with ties to the Temple. The 
FEC most likely credited the contribution to Hsia based on 
information provided by the DNC.\484\ In addition, the 
contribution information provided to the Committee by the DNC 
lists John Huang as the DNC contact for the contribution.\485\ 
Despite the contribution's apparent link to Hsia and Huang and 
the Senate's discussion of it in its Final Report, the DNC did 
not conduct a review of it. The DNC has disgorged to the U.S. 
Treasury a number of other contributions with links to Hsia and 
the Hsi Lai Temple but has retained Koh's $5,000.\486\
---------------------------------------------------------------------------
    \482\ DNC Check Tracking Form for Bank of America Check No. 0094 
from Chee Kien Koh to the DNC in the amount of $5,000, Sept. 17, 1996 
(Exhibit 301); http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \483\ See Federal Grand Jury Indictment of Maria Hsia, U.S. 
District Court for the District of Columbia, Feb. 18, 1998.
    \484\ See generally http://wyl.ewg.org, Environmental Working Group 
Website, Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \485\ Exhibit 301 DNC Check Tracking Form for Bank of America Check 
No. 0094 from Chee Kien Koh to the DNC in the amount of $5,000, Sept. 
17, 1996.
    \486\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998; See Exhibit 4 
Letter from Joseph E. Sandler, Esq., to Lawrence Noble, Esq., June 27, 
1997 (citing FEC Advisory Opinion 1995-19 and FEC Advisory Opinion 
1991-39); Exhibit 5 Letter from Joseph E. Sandler, Esq., to Lawrence 
Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from Judah Best, Esq., to 
James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 DNC List of 
Contributions Returned or Disgorged Produced to the Committee on Nov. 
20, 1997, at 1-9.
---------------------------------------------------------------------------
    Based on the proven history of using conduits to contribute 
to the DNC by Hsia and the IBPS and the suspicious activity 
evidenced by Chee Kien Koh's bank records, Koh's $5,000 was an 
illegal conduit contribution in violation of 2 U.S.C. 
Sec. 441f. Therefore, pursuant to Federal regulations and DNC 
practice, the DNC should disgorge Koh's $5,000 contribution to 
the U.S. Treasury.\487\
---------------------------------------------------------------------------
    \487\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

                     Hsiao Jie Su $2,500 (Illegal)

    On February 16, 1996, the International Buddhist Progress 
Society issued a check to Hsiao Jie Su in the amount of 
$2,500.\488\ The next day, on February 17, 1996, Su issued a 
check in the amount of $2,500 to the DNC in conjunction with 
the DNC's Asian Dinner fund-raiser held at the Hay Adams Hotel 
in Washington, DC.\489\ Su deposited the IBPS's check into her 
checking account at the International Bank of California in Los 
Angeles on February 20, 1996.\490\ The contribution check 
cleared Su's account on February 26, 1996.\491\
---------------------------------------------------------------------------
    \488\ International Bank of California Check No. 3301 from the IBPS 
to Hsiao Jie Su in the amount of $2,500, Feb. 16, 1996, and 
International Bank of California Deposit Ticket of Hsiao Jie Su in the 
amount of $2,500, Feb. 20, 1996 (Exhibit 302).
    \489\ International Bank of California Check No. 304 from Hsiao Jie 
Su to the DNC in the amount of $2,500, Feb. 17, 1996 (Exhibit 303); DNC 
Check Tracking Form for International Bank of California Check No. 304 
from Hsiao Jie Su to the DNC in the amount of $2,500, Feb. 17, 1996 
(Exhibit 304).
    \490\ Exhibit 302 International Bank of California Check No. 3301 
from the IBPS to Hsiao Jie Su in the amount of $2,500, Feb. 16, 1996, 
and International Bank of California Deposit Ticket of Hsiao Jie Su in 
the amount of $2,500, Feb. 20, 1996; International Bank of California 
Account Statement of Hsiao Jie Su, Mar. 15, 1996 (Exhibit 305).
    \491\ Id.; Exhibit 303 International Bank of California Check No. 
304 from Hsiao Jie Su to the DNC in the amount of $2,500, Feb. 17, 
1996.
---------------------------------------------------------------------------
    Consistent with other contributions made by individuals 
linked to the IBPS, DNC contribution information lists Maria 
Hsia as the solicitor and John Huang as the DNC contact.\492\ 
It was Su's apparent link to Hsia and Huang that led to a 
review of her contribution.\493\ Su completed and signed an 
Ernst & Young questionnaire on January 18, 1997, in which she 
confirmed that the money contributed to the DNC was her 
own.\494\ Su also advised Ernst & Young auditors of her 
unwillingness to answer followup questions via telephone.\495\
---------------------------------------------------------------------------
    \492\ Exhibit 304 DNC Check Tracking Form for International Bank of 
California Check No. 304 from Hsiao Jie Su to the DNC in the amount of 
$2,500, Feb. 17, 1996.
    \493\ See generally DNC Response to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 7.
    \494\ Ernst & Young Contribution Review Materials for Hsiao Jie Su, 
DNC 1807597, DNC 1807599, DNC 1807601-DNC 1807602, DNC 1807604-DNC 
1807606, DNC 1807619-DNC 1807620, DNC 1807754, and DNC 1807757-DNC 
1807758, at 1-3 (Exhibit 306).
    \495\ Id. at 3.
---------------------------------------------------------------------------
    Su's Ernst & Young file was labeled ``DER'' for dead end 
research \496\ and passed to IGI for a determination of Su's 
Social Security number and date of birth, which IGI 
provided.\497\ Through IGI, the DNC was able to determine that 
her Social Security number had been valid for almost 20 years 
at the time of the contribution but was unable to confirm her 
address.\498\ This information evidently provided the DNC with 
the minimum information needed to conclude that the 
contribution was legal and appropriate; the DNC retained the 
contribution.
---------------------------------------------------------------------------
    \496\ Id. at 1.
    \497\ IGI Contribution Review Materials for Hsiao Jie Su, HS 
002392-HS 002413, at 4 (Exhibit 307).
    \498\ Id.; see Id. at 1-22.
---------------------------------------------------------------------------
    Based on the proven history of using conduits to contribute 
to the DNC by Hsia and the IBPS and the suspicious activity 
evidenced by Hsiao Jie Su's bank records, the evidence 
indicates that Su's $2,500 was an illegal conduit contribution 
in violation of 2 U.S.C. Sec. 441f. Therefore, pursuant to 
Federal regulations and DNC practice, the DNC should disgorge 
Su's $2,500 contribution to the U.S. Treasury.\499\
---------------------------------------------------------------------------
    \499\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

 Other Suspect or Illegal Contributions During the 1992, 1994 and 1996 
                            Election Cycles

                     Sy Zuan Pan $20,000 (Illegal)

    On September 18, 1996, Sy Zuan ``Roger'' Pan issued a check 
in the amount of $20,000 to the DNC in conjunction with the 
DNC's Asian Dinner fund-raiser featuring Vice President Gore, 
held that day, in San Francisco.\500\ Ernst & Young conducted a 
review of Pan's September 1996 $20,000 contribution.\501\ The 
DNC mailed a review questionnaire to Pan on a date uncertain 
but apparently received no immediate response; \502\ the copy 
of Pan's questionnaire provided to the Committee is 
predominantly blank.\503\ Attempts to reach Pan at the number 
provided to the DNC were also unsuccessful. The Ernst & Young 
auditor noted that: ``[Pan is] currently in China. [N]ot 
knowing [sic] his number. Also he's moving a lot in China.'' 
\504\ Ernst & Young designated the Pan file ``Term[inated].'' 
\505\ After Ernst & Young's unsuccessful attempt to verify the 
legality of Pan's contribution, IGI made an attempt.\506\ On 
January 16, 1997, an IGI employee contacted one of Pan's 
employees regarding the contribution.\507\ According to notes 
from the IGI interview, ``[the woman] was unable to answer 
whether [Pan] is a U.S. citizen, but said that he or she would 
call us back next week to answer our questions.'' \508\ There 
is no indication that Pan ever returned IGI's call and the IGI 
notes indicate that it was unable to gather any additional 
information on Pan.\509\
---------------------------------------------------------------------------
    \500\ DNC Check Tracking Form for Wells Fargo Bank Check No. 1091 
from Sy Zuan Pan to the DNC in the amount of $20,000, Sept. 18, 1996, 
D0000443 (Exhibit 308); Ernst & Young Contribution Review Materials for 
Sy Zuan Pan, DNC 1802793-DNC 1802794, DNC 1802797, DNC 1802799, DNC 
1802801-DNC 1802802, and DNC 1802812-DNC 1802814, at 7 (Exhibit 309).
    \501\ Id.
    \502\ Id. at 1-9.
    \503\ Id. at 4-6.
    \504\ Id. at 8.
    \505\ Id. at 1.
    \506\ IGI Contribution Review Materials for Sy Zuan Pan, HS 006439-
HS 006441 (Exhibit 310).
    \507\ Id. at 2.
    \508\ Id.
    \509\ Id. at 1-3.
---------------------------------------------------------------------------
    In the wake of IGI's investigation of Pan's contribution, 
Pan's attorney, Arnold Chin of San Francisco, in a January 29, 
1997, letter to an Ernst & Young auditor requested that the 
contribution be returned, stating that:

        I represent Mr. Sy Zuan Guo [sic] with regards to his 
        donation/contribution of the sum of $20,000 to the 
        Democratic National Committee for the 1996 Presidential 
        Election. I am in receipt of your questionnaire 
        concerning the donation/contribution made from my 
        client.

        If the donation is subject to inquiry then on behalf of 
        my client, I am requesting that the donation/
        contribution be returned through my office. My client 
        will not complete any questionnaire.\510\
---------------------------------------------------------------------------
    \510\ Letter from Arnold Chin, Esq., to Eric Guo, Jan. 26, 1997 
(emphasis added) (Exhibit 311).

    The DNC has returned over 50 contributions at the request 
of contributors, but the DNC retained Pan's contribution.\511\
---------------------------------------------------------------------------
    \511\ Exhibit 7 DNC List of Contributions Returned or Disgorged 
Produced to the Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------
    Pan has cooperated with the Committee through his attorney 
Chin. On July 23, 1998, a Committee counsel interviewed Chin 
regarding his client's contribution to the DNC.\512\ Chin 
indicated that at the time of the contribution and currently, 
Pan is not ``technically a resident for the purposes of 
migration [sic].'' \513\ Chin confirmed that Pan's contribution 
was illegal under Federal election law.\514\ That same day, 
Chin wrote the Committee to confirm that Pan ``requested the 
return of the money from the DNC after he found out that he 
could not make such a donation . . . The DNC never knew that he 
was not eligible to donate because of his immigration status in 
the United States.'' \515\ The Federal election law provision 
to which Chin refers in his interview and his letter is 2 
U.S.C. Sec. 441e(a) which makes it unlawful for a foreign 
national to make a political contribution.\516\
---------------------------------------------------------------------------
    \512\ Committee Interview of Arnold Chin, July 23, 1998.
    \513\ Id.
    \514\ Id.
    \515\ Letter from Arnold Chin, Esq., to Tim Griffin, Esq., July 23, 
1998 (Exhibit 312).
    \516\ See generally Committee Interview of Arnold Chin, July 23, 
1998.
---------------------------------------------------------------------------
    Even though Pan did not complete the Ernst & Young 
questionnaire as requested and Pan's attorney requested the 
return of Pan's $20,000 contribution, the DNC retained it. 
Based on the foregoing, Pan's contribution was given in 
violation of 2 U.S.C. Sec. 441e(a)--the prohibition against 
contributions by foreign nationals. Therefore, the DNC should 
return Pan's contribution to him or disgorge it to the U.S. 
Treasury.\517\
---------------------------------------------------------------------------
    \517\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

               K&L International, Inc. $150,000 (Illegal)

    On May 6, 1996, Il Sung Construction Co., Ltd. (``Il 
Sung''), a Korean corporation based in Soeul, Korea, 
transferred $200,000 via electronic wire into the checking 
account of Chong Kim & Associates, Inc.,\518\ a California 
corporation based in Los Angeles.\519\ On May 11, 1996, Chong 
Kim, the President of Chong Kim & Associates, issued a check in 
the amount of $150,000 to the DNC on the Wilshire State Bank 
checking account of K&L International, Inc. (``K&L''),\520\ 
another California corporation controlled by Chong Kim.\521\ At 
the time the $150,000 check was written, K&L's checking account 
balance was $3,341.24.\522\ In order to insure that K&L's 
account would have a sufficient balance to cover the check, on 
May 17, 1996, Chong Kim purchased a $150,000 cashier's check 
from Sumitomo Bank of California (``Sumitomo Bank'') in Los 
Angeles \523\ and deposited it into K&L's checking 
account.\524\ But it was too late: the check to the DNC had 
bounced on May 15, 1996, due to insufficient funds.\525\ 
Although Kim could not recall whether he forwarded another 
check to the DNC in the amount of $150,000 to replace the 
bounced check or whether the initial check cleared his account 
on the second attempt,\526\ bank records indicate that the 
original check issued on May 15, 1996, was rerouted through 
Wilshire Bank and cleared on June 3, 1996.\527\
---------------------------------------------------------------------------
    \518\ Sumitomo Bank Account Statement of Chong Kim & Associates, 
May 31, 1996 (Exhibit 313); Sumitomo Bank Wire Transfer Report of Chong 
Kim & Associates, May 31, 1996 (Exhibit 314); Committee Interview of 
Chong Kim, July 20, 1998.
    \519\ Office of California Secretary of State, Corporate Records.
    \520\ Wilshire State Bank Check No. 1087 from K&L to the DNC in the 
amount of $150,000, May 11, 1996 (Exhibit 315); DNC Check Tracking Form 
for Wilshire State Bank Check No. 1087 from K&L to the DNC in the 
amount of $150,000, May 11, 1996 (Exhibit 316).
    \521\ Office of California Secretary of State, Corporate Records.
    \522\ Wilshire State Bank Account Statement for K&L, May 31, 1996 
(Exhibit 317).
    \523\ Exhibit 313 Sumitomo Bank Account Statement of Chong Kim & 
Associates, May 31, 1996; Sumitomo Bank Cashier's Check Register of K&L 
in the amount of $150,000, May 17, 1996 (Exhibit 318); Sumitomo Bank 
Cashier's Check, May 17, 1996 (Exhibit 319); Sumitomo Bank Cashier's 
Check (Copy No. 2), May 17, 1996, and Wilshire State Bank Deposit 
Ticket of K&L in the amount of $150,000, May 17, 1996 (Exhibit 320).
    \524\ Exhibit 317 Wilshire State Bank Account Statement for K&L, 
May 31, 1996; Exhibit 320 Sumitomo Bank Cashier's Check (Copy No. 2), 
May 17, 1996, and Wilshire State Bank Deposit Ticket of K&L in the 
amount of $150,000, May 17, 1996; Exhibit 319 Sumitomo Bank Cashier's 
Check, May 17, 1996.
    \525\ Exhibit 315 Wilshire State Bank Check No. 1087 from K&L to 
the DNC in the amount of $150,000, May 11, 1996; Exhibit 317 Wilshire 
State Bank Account Statement for K&L, May 31, 1996.
    \526\ Committee Interview of Chong Kim, Aug. 28, 1998.
    \527\ Wilshire State Bank Account Statement for K&L, June 28, 1996 
(Exhibit 321); Exhibit 315 Wilshire State Bank Check No. 1087 from K&L 
to the DNC in the amount of $150,000, May 11, 1996; see generally 
http://wyl.ewg.org, Environmental Working Group Website, Compiled from 
FEC Data, Last Updated Sept. 10, 1998.
---------------------------------------------------------------------------
    Interestingly, although K&L's initial check was signed by 
Kim,\528\ K&L's contribution was not attributed to him; it was 
attributed to Los Angeles businessman Robert Lee, a friend and 
business associate of Kim.\529\ The contribution information 
provided to the Committee by the DNC lists then-DNC Finance 
Director Richard Sullivan and David Carroll as the DNC contacts 
for the contribution and Arkansas attorney Larry Wallace as the 
solicitor.\530\
---------------------------------------------------------------------------
    \528\ Exhibit 315 Wilshire State Bank Check No. 1087 from K&L to 
the DNC in the amount of $150,000, May 11, 1996; Committee Interview of 
Chong Kim, July 7, 1998; Exhibit 316 DNC Check Tracking Form for 
Wilshire State Bank Check No. 1087 from K&L to the DNC in the amount of 
$150,000, May 11, 1996.
    \529\ Committee Interview of Chong Kim, July 7, 1998; Exhibit 316 
DNC Check Tracking Form for Wilshire State Bank Check No. 1087 from K&L 
to the DNC in the amount of $150,000, May 11, 1996.
    \530\ Id.
---------------------------------------------------------------------------
    According to Wallace, Lee, whom he had known for several 
years, initially approached him seeking business opportunities 
for Korean based Il Sung.\531\ Lee also expressed an interest 
in making a contribution to the DNC.\532\ Wallace introduced 
Lee to then-DNC Finance Director Richard Sullivan and David 
Carroll at the DNC and asked them to assist Lee with his 
contribution.\533\ Wallace told Committee counsel that he 
advised Sullivan and Carroll to insure that Lee understood the 
contribution must be made with his money.\534\ The only time 
Wallace ever met Kim is when Lee and Kim visited him at his 
hotel room in Washington, DC, at which time Lee expressed the 
desire to contribute.\535\ According to Wallace, he tried to 
make it very clear to them that they had to contribute U.S. 
money and that it could not simply be funds routed through a 
U.S. bank account.\536\
---------------------------------------------------------------------------
    \531\ Committee Interview of Larry Wallace, Aug. 7, 1998.
    \532\ Id.
    \533\ Id.
    \534\ Id.
    \535\ Id.
    \536\ Id.
---------------------------------------------------------------------------
    Chong Kim advised Committee investigators that he has never 
owned any part of Il Sung.\537\ At the time of the 
contribution, K&L had yet to complete its first business 
project.\538\ According to Kim, his contribution to the DNC was 
part of an effort to develop overseas business opportunities in 
conjunction with Il Sung.\539\ The remaining $50,000 of the 
$200,000 received by Chong Kim from Il Sung was paid to Larry 
Wallace and Robert Lee, $25,000 each.\540\ Kim advised 
Committee counsel that Wallace and Lee were paid to assist in 
the development of overseas business opportunities.\541\ 
Wallace confirmed that he assisted Lee with some overseas 
business projects but was unaware that any of the money given 
to the DNC or paid to him was provided by Chong Kim or Il 
Sung.\542\ Wallace said he was under the mistaken impression 
that Lee was the source of the funds and that Lee was the 
contact for K&L.\543\ This would possibly explain the 
attribution of K&L's contribution to Lee on the DNC check 
tracking form.\544\
---------------------------------------------------------------------------
    \537\ Committee Interview of Chong Kim, July 20, 1998.
    \538\ IGI Contribution Review Materials of K&L, HS 003786, HS 
011373, and HS 003787-HS 003815, at 2 (Exhibit 322); Ira Chinoy and 
Lena H. Sun, ``Unwary DNC Accepted Donations at Face Value,'' the 
Washington Post, Nov. 22, 1996, at A1.
    \539\ Committee Interview of Chong Kim, July 7, 1998.
    \540\ Committee Interview of Chong Kim, July 7, 1998; Committee 
Interview of Larry Wallace, Aug. 7, 1998; Sumitomo Bank Payment Order 
of Chong Kim & Associates in the amount of $25,000, May 6, 1996 
(Exhibit 323); Exhibit 313 Sumitomo Bank Account Statement of Chong Kim 
& Associates, May 31, 1996.
    \541\ Committee Interview of Chong Kim, July 7, 1998.
    \542\ Committee Interview of Larry Wallace, Aug. 7, 1998.
    \543\ Id.
    \544\ See Exhibit 316 DNC Check Tracking Form for Wilshire State 
Bank Check No. 1087 from K&L to the DNC in the amount of $150,000, May 
11, 1996.
---------------------------------------------------------------------------
    Ernst & Young conducted a review of K&L's May 1996 $150,000 
contribution and was unable to confirm the address and 
telephone number provided by K&L.\545\ Apparently, no review 
questionnaire was completed.\546\ After Ernst & Young's 
unsuccessful attempt to verify the legality of K&L's 
contribution, IGI made an attempt.\547\ On January 9, 1997, an 
IGI employee interviewed Lee regarding K&L's contribution.\548\ 
Lee asserted that although K&L ``has not done any commercial 
development in the United States . . . , the funds he 
contributed came from `earnings in the U.S.' '' \549\
---------------------------------------------------------------------------
    \545\ Ernst & Young Contribution Review Materials of K&L, DNC 
1806062, and DNC 1806066-DNC 1806072, at 2 (Exhibit 324).
    \546\ Id. at 1-8.
    \547\ Exhibit 322 IGI Contribution Review Materials of K&L, HS 
003786, HS 011373, and HS 003787-HS 003815.
    \548\ Id. at 2.
    \549\ Id.
---------------------------------------------------------------------------
    Despite the questions raised by the Ernst & Young review of 
K&L's contribution, the DNC retained it. Moreover, the 
Committee has no evidence that the DNC discussed the 
contribution with then-Finance Director Richard Sullivan, David 
Carroll or Larry Wallace in conjunction with the DNC's 
contribution review, even though Wallace had warned Sullivan 
and Carroll to proceed with caution. In any event, K&L's 
$150,000 contribution violated both 2 U.S.C. Sec. 441e(a) and 2 
U.S.C. Sec. 441f, and thus, the DNC should disgorge K&L's 
illegal $150,000 contribution to the U.S. Treasury.\550\
---------------------------------------------------------------------------
    \550\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

              American Great Ground Group $7,000 (Suspect)

    On July 20, 1996, American Great Ground Group, Inc. 
(``AGGG''), a California corporation, issued a check to the DNC 
in the amount of $7,000 \551\ in conjunction with the July 22, 
1996, DNC Asian Dinner fund-raiser at the Century Plaza Hotel 
in Los Angeles.\552\ John Huang was the DNC contact for the 
contribution.\553\
---------------------------------------------------------------------------
    \551\ Bank of America Check No. 1524 from AGGG to the DNC in the 
amount of $7,000, July 20, 1996 (Exhibit 325); DNC Check Tracking Form 
for Bank of America Check No. 1524 from AGGG to the DNC in the amount 
of $7,000, July 20, 1996 (Exhibit 326).
    \552\ Id.
    \553\ Id.
---------------------------------------------------------------------------
    Ernst & Young conducted a review of AGGG's July 1996 $7,000 
contribution and was unable to confirm the address provided by 
AGGG.\554\ The DNC mailed a review questionnaire to James 
Shang, the contact for AGGG, in December 1996, but apparently 
received no response; the copy of AGGG's questionnaire provided 
to the Committee is completely blank.\555\ Attempts to reach 
Shang at the number provided to the DNC were also 
unsuccessful.\556\ Ernst & Young's review notes indicate that 
it was unable to gather any significant information on AGGG and 
designated the file ``Term[inated].'' \557\ After Ernst & 
Young's unsuccessful attempt to verify the legality of AGGG's 
contribution, IGI made an attempt.\558\ Shang did not return a 
Committee investigator's telephone calls.
---------------------------------------------------------------------------
    \554\ IGI Contribution Review Materials for AGGG/James Shang, HS 
007737-HS 007760, at 3-4 (Exhibit 327).
    \555\ Id. at 2.
    \556\ Id. at 11-18.
    \557\ Id. at 2.
    \558\ See Id. at 1-24.
---------------------------------------------------------------------------
    The Committee has reviewed AGGG bank records: apparently, 
AGGG's predominant source of revenue at the time of the 
contribution was a series of wire transfers, all of which 
originated with the Bank of Communications in Shenyang, 
China,\559\ a bank owned and operated by the Chinese 
government.\560\ Although inconclusive, AGGG's bank records 
appear to indicate that the Bank of Communications was not only 
the issuing bank but also the ultimate source of the 
funds.\561\
---------------------------------------------------------------------------
    \559\ Bank of America Account Statement of AGGG, June 28, 1996 
(Exhibit 328); Bank of America Wire Transfer Report of AGGG in the 
amount of $35,785, June 26, 1996 (Exhibit 329); Bank of America Account 
Statement of AGGG, June 31, 1996 (Exhibit 330); Bank of America Account 
Statement of AGGG, Aug. 30, 1996 (Exhibit 331); Bank of America Wire 
Transfer Report of AGGG in the amount of $47,985, Aug. 23, 1996 
(Exhibit 332).
    \560\ Cheung Lai-Kuen, ``Outlook on China Groups Lowered,'' South 
China Morning Post, Mar. 22, 1997, at 2.
    \561\ Exhibit 329 Bank of America Wire Transfer Report of AGGG in 
the amount of $35,785, June 26, 1996; Exhibit 332 Bank of America Wire 
Transfer Report of AGGG in the amount of $47,985, Aug. 23, 1996.
---------------------------------------------------------------------------
    As indicated previously, foreign nationals are prohibited 
from making a political contribution directly or through any 
other person, or making an expenditure, in connection with an 
election to any political office.\562\ The term ``person'' 
includes a corporation.\563\ The term ``foreign national'' 
includes the foreign principal of a domestic corporation.\564\ 
In FEC Advisory Opinion 1989-20, the FEC ``prohibited 
contributions by a real estate development company that was 
predominately funded by a foreign national parent, and whose 
projects were not yet generating income.'' \565\ The ultimate 
source of the wire transfers in this case are not conclusively 
known. However, if the wire transfers, and thus the 
contribution, originated with a foreign principal of AGGG's, 
AGGG's contribution was an illegal contribution by a foreign 
national in violation of 2 U.S.C. Sec. 441e(a).
---------------------------------------------------------------------------
    \562\ 2 U.S.C. Sec. 441e(a); 11 CFR Sec. 110.4(a) (1) and (2); FEC 
Advisory Opinion No. 1992-16, June 26, 1992.
    \563\ 2 U.S.C. Sec. 431(11).
    \564\ FEC Advisory Opinion 1992-16 (citing 22 U.S.C. Sec. 611(b); 2 
U.S.C. Sec. 441e(b)(1); 11 CFR Sec. 110.4(a)(4)(i)).
    \565\ FEC Advisory Opinion 1992-16 (citing FEC Advisory Opinion 
1989-20).
---------------------------------------------------------------------------
    As on other occasions, despite the paucity of information 
gathered pursuant to the Ernst & Young and IGI reviews, the DNC 
decided to retain AGGG's $7,000 contribution. However, based on 
an analysis of AGGG's bank records, its $7,000 contribution 
appears to constitute a violation of 2 U.S.C. Sec. 441e(a) and, 
in any event, should be disgorged to the U.S. Treasury based on 
the DNC's own criteria of insufficient information.\566\
---------------------------------------------------------------------------
    \566\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

                   Yong Xing Huang $10,000 (Suspect)

    On May 6, 1996, Y.X. Huang, a relative of John Huang,\567\ 
deposited $5,000 cash into his checking account at Asia Bank, 
N.A. (``Asia Bank''), in Elmhurst, New York.\568\ At the time 
of the deposit, Y.X. Huang's checking account balance was 
$8,146.74.\569\ Three days later, on May 9, 1996, Y.X. Huang 
deposited an additional $5,000 cash.\570\ On May 13, 1996, Y.X. 
Huang issued a check in the amount of $10,000 to the DNC in 
conjunction with the DNC's Asian Pacific American Leadership 
Council May 13, 1996, fund-raiser held the same day at the 
Sheraton-Carlton Hotel in Washington, DC.\571\ (Of the $579,000 
raised at this event, the DNC returned or disgorged at least 
$475,000, 82 percent of the total raised.) \572\ According to 
documents produced to the Committee by the DNC, John Huang was 
both the solicitor of and the DNC contact for Y.X. Huang's 
contribution.\573\
---------------------------------------------------------------------------
    \567\ Committee Interview of Y.X. Huang, Aug. 14, 1998.
    \568\ Asia Bank Cash In Ticket of Y.X. Huang in the amount of 
$5,000, May 6, 1996, and Asia Bank Deposit Ticket of Y.X. Huang in the 
amount of $5,000, May 6, 1996 (Exhibit 333); Asia Bank Account 
Statement of Y.X. Huang, May 20, 1996 (Exhibit 334).
    \569\ Id.
    \570\ Asia Bank Cash In Ticket of Y.X. Huang in the amount of 
$5,000, May 9, 1996, and Asia Bank Deposit Ticket of Y.X. Huang in the 
amount of $5,000, May 9, 1996 (Exhibit 335); Exhibit 334 Asia Bank 
Account Statement of Y.X. Huang, May 20, 1996.
    \571\ Id.; Asia Bank Check No. 102 from Y.X. Huang to the DNC in 
the amount of $10,000, May 13, 1996 (Exhibit 336); DNC Check Tracking 
Form for Asia Bank Check No. 102 from Y.X. Huang to the DNC in the 
amount of $10,000, May 13, 1996 D 0000335 (Exhibit 337).
    \572\ See generally Investigation of Illegal or Improper Activities 
in Connection with the 1996 Federal Election Campaign Before the Senate 
Committee on Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d 
sess., vol. 4, 4816 (1998); Exhibit 7 DNC List of Contributions 
Returned or Disgorged Produced to the Committee on Nov. 20, 1997, at 1-
9.
    \573\ Exhibit 337 DNC Check Tracking Form for Asia Bank Check No. 
102 from Y.X. Huang to the DNC in the amount of $10,000, May 13, 1996 D 
0000335.
---------------------------------------------------------------------------
    Ernst & Young conducted a review of Y.X. Huang's May 1996 
$10,000 contribution.\574\ Although Ernst & Young discussed 
Y.X. Huang's contribution with his daughter,\575\ they did not 
receive any information directly from Y.X. Huang regarding his 
contributions.\576\ The Ernst & Young auditor noted that ``[w]e 
need to speak to father [sic] directly,'' \577\ but apparently 
neither Ernst & Young nor the DNC ever did.\578\ Two review 
forms relating to Y.X. Huang's contribution were provided to 
the Committee: one of the review forms is blank and labeled 
``Terminated.''\579\ The other review form is complete and 
labeled ``Unsuccessful.'' \580\
---------------------------------------------------------------------------
    \574\ IGI Contribution Review Materials for Y.X. Huang, HS 007153-
HS 007190, at 6 (Exhibit 338).
    \575\ Id. at 22.
    \576\ Id. at 1-38.
    \577\ Id. at 28.
    \578\ Id. at 1-22.
    \579\ Id. at 6.
    \580\ Id. at 22
---------------------------------------------------------------------------
    After the Ernst & Young review, IGI gathered a limited 
amount of additional information regarding Y.X. Huang.\581\ 
However, through IGI, the DNC was able to determine that his 
Social Security number had been valid for approximately 10 
years at the time of the contribution \582\ and that his home 
had an assessed value of $361,000.\583\ This information 
evidently provided the DNC with the minimum information needed 
to conclude that the contribution was legal and appropriate; 
the DNC retained the contribution.
---------------------------------------------------------------------------
    \581\ Id.
    \582\ Id. at 2.
    \583\ Id. at 2.
---------------------------------------------------------------------------
    The Committee was successful in contacting Y.X. Huang.\584\ 
On August 14, 1998, Y.X. Huang contacted a Committee attorney 
telephonically through his daughter Sharon Huang, who served as 
a translator;\585\ Y.X. Huang speaks only limited English.\586\ 
Y.X. Huang indicated that his relative John Huang solicited his 
contribution in the amount of $10,000.\587\ Y.X. Huang advised 
that he has not seen John Huang in several months.\588\ When 
asked about the source of the $10,000 cash deposited into his 
account, Y.X. Huang indicated that a ``traditional Chinese 
organization loaned him the money.'' \589\ He denied that the 
money was John Huang's.\590\ Y.X. Huang was unwilling or unable 
to provide additional details regarding the loan.\591\
---------------------------------------------------------------------------
    \584\ Committee Interview of Y.X. Huang, Aug. 14, 1998.
    \585\ Id.
    \586\ Id.
    \587\ Id.
    \588\ Id.
    \589\ Id.
    \590\ Id.
    \591\ Id.
---------------------------------------------------------------------------
    Particularly suspicious is the fact that the $10,000 cash 
was deposited in two separate portions of $5,000 each.\592\ 
Y.X. Huang had no explanation for breaking the deposit into two 
equal halves.\593\ As indicated previously, under Federal law, 
a CTR must be filed in conjunction with any cash transaction 
involving $10,000 or more.\594\ It is a Federal crime to avoid 
the generation of a CTR purposefully.\595\
---------------------------------------------------------------------------
    \592\ Exhibit 334 Asia Bank Account Statement of Y.X. Huang, May 
20, 1996.
    \593\ Committee Interview of Y.X. Huang, Aug. 14, 1998.
    \594\ See generally 31 U.S.C. Sec. Sec. 5313 and 5322; 31 C.F.R. 
Sec. 103.22.
    \595\ 31 U.S.C. Sec. 5322.
---------------------------------------------------------------------------
    With regard to matters discussed with Committee 
investigators, Y.X. Huang's veracity is questionable: when 
asked about a $50,000 cashier's check that he received from a 
Cecilia Soohoo \596\ and deposited into his Asia Bank 
account,\597\ he did not recall receiving the $50,000 check and 
denied knowing Soohoo.\598\ Committee counsel informed Y.X. 
Huang that the Committee is in possession of his bank 
records,\599\ nonetheless, during detailed questioning 
regarding the $50,000, Y.X. Huang repeated his previous 
answers.\600\
---------------------------------------------------------------------------
    \596\ John Huang is reportedly related to a Linda Soohoo.
    \597\ Citizens Bank Cashier's Check No. 806626213 from Cecelia H.Y. 
Soohoo to Yong Xing Huang in the amount of $50,000, May 13, 1996, and 
Asia Bank Deposit Ticket of Y.X. Huang in the amount of $50,000, May 
23, 1996 (Exhibit 339); Asia Bank Account Statement of Y.X. Huang, May 
21, 1996 (Exhibit 340); Asia Bank Withdrawal Ticket of Y.X. Huang in 
the amount of $50,030, May 24, 1996 (Exhibit 341).
    \598\ Committee Interview of Y.X. Huang, Aug. 14, 1998.
    \599\ Id.
    \600\ Id.
---------------------------------------------------------------------------
    Later that same day, on August 14, 1998, Y.X. Huang re-
contacted Committee counsel telephonically through his daughter 
Sharon Huang.\601\ At that time, Y.X. Huang indicated that he 
then recalled receiving the $50,000.\602\ According to Y.X. 
Huang, he received the $50,000 in the form of a wire transfer 
from his relative Sin Yun Chen of Hong Kong who needed to store 
the money in his account because she wanted to purchase a home 
in the United States.\603\ Bank records indicate that the 
$50,000--after being deposited into Y.X. Huang's account on May 
23, 1996 \604\--was sent via wire transfer to the People's 
Construction Bank of China in Zhe Jiang, China on May 24, 
1996.\605\ Moreover, Committee counsel informed Y.X. Huang that 
the $50,000 was not a wire transfer; it was a cashier's check 
from Cecilia Soohoo.\606\ He again denied knowing Soohoo.\607\ 
Y.X. Huang was unable to provide further details regarding the 
transaction.\608\
---------------------------------------------------------------------------
    \601\ Id.
    \602\ Id.
    \603\ Id.
    \604\ Exhibit 339 Citizens Bank Cashier's Check No. 806626213 from 
Cecelia H.Y. Soohoo to Yong Xing Huang in the amount of $50,000, May 
13, 1996, and Asia Bank Deposit Ticket of Y.X. Huang in the amount of 
$50,000, May 23, 1996; Exhibit 340 Asia Bank Account Statement of Y.X. 
Huang, May 21, 1996.
    \605\ Exhibit 341 Asia Bank Withdrawal Ticket of Y.X. Huang in the 
amount of $50,030, May 24, 1996; Asia Bank Wire Transfer Report of Y.X. 
Huang in the amount of $50,000, May 24, 1996 (Exhibit 342).
    \606\ Committee Interview of Y.X. Huang, Aug. 14, 1998.
    \607\ Id.
    \608\ Id.
---------------------------------------------------------------------------
    Despite the fact that the DNC's review of Y.X. Huang's 
contribution was labeled ``Terminated'' and labeled 
``Unsuccessful,'' the DNC apparently decided that it had 
sufficient information to declare the contribution appropriate 
and retain it. That fact notwithstanding, based on Huang's 
proven history of using conduits to contribute to the DNC and 
the suspicious activity evidenced by Y.X. Huang's bank records, 
the evidence indicates that his $10,000 was most likely another 
illegal conduit contribution generated by John Huang in 
violation of 2 U.S.C. Sec. 441f. In any event, the Y.X. Huang's 
$10,000 contribution is highly suspect and should be disgorged 
to the U.S. Treasury based on the DNC's own criterion of 
insufficient information.\609\
---------------------------------------------------------------------------
    \609\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

                Platinum Realty, Inc. $22,500 (Suspect)

    Platinum Realty, Inc. (``Platinum'') contributed $12,500 to 
the DNC on February 19, 1996, in conjunction with the DNC's 
Asian Dinner fund-raiser held that same day at the Hay Adams 
Hotel \610\ and contributed an additional $10,000 to the DNC on 
July 18, 1996, in conjunction with the DNC's July 22, 1996, 
Asian Dinner fund-raiser at the Century Plaza Hotel, Los 
Angeles, California.\611\ Both contribution checks were issued 
from Platinum's checking account at the American International 
Bank in Los Angeles and signed by Platinum's president Huey Min 
Yu.\612\
---------------------------------------------------------------------------
    \610\ DNC Check Tracking Form for American International Bank Check 
No. 1409 from Platinum Realty to the DNC in the amount of $12,500, Feb. 
19, 1996 DNC 1803275 (Exhibit 343).
    \611\ DNC Check Tracking Form for American International Bank Check 
No. 1644 from Platinum Realty to the DNC in the amount of $10,000, July 
18, 1996 DNC 1803276 (Exhibit 344).
    \612\ Id.; Exhibit 343 DNC Check Tracking Form for American 
International Bank Check No. 1409 from Platinum Realty to the DNC in 
the amount of $12,500, Feb. 19, 1996 DNC 1803275.
---------------------------------------------------------------------------
    John Huang was the DNC contact for and solicitor of 
Platinum's contributions.\613\ In addition, telephone records 
and other documents produced to the Committee provide 
additional links between Yu and Huang.\614\ The telephone 
records show calls between Yu and Huang around the time of Yu's 
July contribution.\615\
---------------------------------------------------------------------------
    \613\ Id.; Ernst & Young Contribution Review Materials for Huey Min 
Yu, DNC 1803240, DNC 1803242-DNC 1803244, DNC 1803247-DNC 1803248, DNC 
1803252, DNC 1803258, and DNC 1803270-DNC 1803276 (Exhibit 345).
    \614\ Phone Records of John Huang Compiled by Committee 
Investigators (Exhibit 346); Invoice of Berry & Associates, Aug. 1, 
1996 (Exhibit 347); Facsimile from Huey Min Yu to Paul C. Berry, May 
14, 1996 (Exhibit 348).
    \615\ Exhibit 346 Phone Records of John Huang Compiled by Committee 
Investigators.
---------------------------------------------------------------------------
    On several occasions during December 1996 and January 1997, 
the DNC and Ernst & Young personnel contacted Yu and one of his 
employees regarding his contributions to the DNC.\616\ On 
January 7, 1997, Yu provided an Ernst & Young auditor with the 
information requested by the Ernst & Young questionnaire.\617\ 
The auditor inquired of Yu:
---------------------------------------------------------------------------
    \616\ Exhibit 345 Ernst & Young Contribution Review Materials for 
Huey Min Yu, DNC 1803240, DNC 1803242-DNC 1803244, DNC 1803247-DNC 
1803248, DNC 1803252, DNC 1803258, and DNC 1803270-DNC 1803276, at 2-3, 
and 8.
    \617\ Id. at 4-8.

        Would you be willing to send me a letter confirming 
        that fact, and also confirming that none of the money 
        came from outside of the United States or from a source 
        other than [company's] U.S. funds? \618\
---------------------------------------------------------------------------
    \618\ Id. at 7.

Yu responded yes.\619\ Yu apparently never confirmed the source 
of the funds used for the contribution. The auditor's notes 
indicate that Yu ``was aggravated by the questions, 
particularly citizenship & income. Mentioned having someone 
from the DNC call him.'' \620\ The Ernst & Young auditor 
labeled Yu's review file ``Survey Unsuccessful.'' \621\ The 
Committee twice unsuccessfully attempted to contact Yu.
---------------------------------------------------------------------------
    \619\ Id.
    \620\ Id. at 2.
    \621\ Id. at 1. The Committee has received no evidence of IGI's 
participation in this review. Id.
---------------------------------------------------------------------------
    In a letter to an Ernst & Young auditor written the same 
day of the Ernst & Young interview, Huey Min Yu requested the 
return of his contribution, stating in pertinent part that:

        I regret to hear that DNC [sic] has considered my 
        contributions unacceptable due to lack of information . 
        . . Should the receiving entity to [sic] my 
        contribution captioned above considered [sic] the 
        information given by me at the time of contribution as 
        ``incomplete'' and therefore is an unacceptable 
        transaction, then please consider this letter as my 
        formal request that the subject contributions be 
        returned as soon as possible.\622\
---------------------------------------------------------------------------
    \622\ Facsimile from Huey Min Yu to Alyson Payne, Jan. 7, 1997 
(Exhibit 349).

As a result of his objection to the DNC review, Yu provided no 
information which would have enabled the DNC to make an 
informed determination regarding the legality or 
appropriateness of Platinum Realty's contribution. But despite 
the paucity of information gathered pursuant to the Ernst & 
Young review and its own characterization of the review as 
``unsuccessful,'' the DNC retained Yu's $22,500 in 
contributions. The DNC has returned over 50 contributions at 
the request of the contributor.\623\ Due to insufficient 
information and Yu's own request for the return of his 
contributions, the DNC should return Yu's $22,500 to him or 
disgorge his contributions to the U.S. Treasury.\624\
---------------------------------------------------------------------------
    \623\ Exhibit 7 DNC List of Contributions Returned or Disgorged 
Produced to the Committee on Nov. 20, 1997, at 1-9.
    \624\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

                      Ji Ping Yu $5,000 (Suspect)

    On August 17, 1996, Ji Ping Yu issued a check in the amount 
of $5,000 to the DNC's Victory '96 fund.\625\ Two days later, 
on August 19, 1996, Ji Ping Yu deposited $5,500 in cash in two 
separate transactions, $2,500 and then $3,000.\626\ Yu's 
checking account balance was $2,745.86 at the time of the 
initial deposit.\627\ Although difficult to decipher due to 
poor copy quality, the deposits appear to have been made almost 
simultaneously.\628\ The check cleared Yu's Citibank checking 
account on August 23, 1996.\629\
---------------------------------------------------------------------------
    \625\ Citibank Check No. 833 from Tze Hwa Yu and Ji Ping Yu to 
Victory 96 in the amount of $5,000, Aug. 17, 1996 (Exhibit 350); 
Citibank Account Statement of Tze Hwa Yu and Ji Ping Yu, Aug. 26, 1996 
(Exhibit 351).
    \626\ Id.; Citibank Deposit Ticket of Ji Ping Yu in the amount of 
$2,500, Aug. 19, 1996 (Exhibit 352); Citibank Deposit Ticket of Ji Ping 
Yu in the amount of $3,000, Aug. 19, 1996 (Exhibit 353).
    \627\ Id.
    \628\ The sequential transaction numbers stamped on the rear of the 
deposit tickets are evidence that the two deposits were made in 
sequence and simultaneously. Exhibit 352 Citibank Deposit Ticket of Ji 
Ping Yu in the amount of $2,500, Aug. 19, 1996; Exhibit 353 Citibank 
Deposit Ticket of Ji Ping Yu in the amount of $3,000, Aug. 19, 1996. 
While the deposit tickets are dated Aug. 18, 1996 in handwriting, the 
account statement indicates that the deposits were made on Aug. 19, 
1996. Exhibit 351 Citibank Account Statement of Tze Hwa Yu and Ji Ping 
Yu, Aug. 26, 1996.
    \629\ Id.
---------------------------------------------------------------------------
    According to DNC contribution information provided to the 
Committee, the contribution was solicited by Yah Lin 
``Charlie'' Trie in conjunction with the President's Birthday 
Party fund-raiser held in New York City on August 19, 
1996.\630\ The DNC contact/fund-raiser for the contribution was 
Richard Sullivan.\631\ The DNC apparently reviewed Yu's 
contribution, but the Committee has limited--three pages with 
information obtained by the contributor at the time of 
contribution--information regarding the review.\632\
---------------------------------------------------------------------------
    \630\ IGI Contribution Review Materials for Ji Ping Yu, HS 002576-
HS 002578, at 3 (Exhibit 354).
    \631\ Id. at 2.
    \632\ Id. at 1-3.
---------------------------------------------------------------------------
    It is essential to note that Trie used a number of conduit 
contributors to funnel thousands of dollars into the DNC during 
August 1996, most, if not all, of which was in conjunction with 
the DNC's Birthday Party fund-raiser for the President.\633\ 
Based on Trie's proven history of using conduits to contribute 
to the DNC and the suspicious activity evidenced by Ji Ping 
Yu's bank records, the evidence indicates that Yu's $5,000 may 
have been an illegal conduit contribution in violation of 2 
U.S.C. Sec. 441f. In any event, the DNC--and the Committee for 
that matter--have been unable to obtain sufficient information 
to make an informed decision as to the legality or 
appropriateness of this contribution. Therefore, pursuant to 
DNC criteria and DNC practice, the DNC should return Yu's 
$5,000 contribution to him or disgorge it to the U.S. 
Treasury.\634\
---------------------------------------------------------------------------
    \633\ See Federal Grand Jury Indictment of Yah Lin ``Charlie'' 
Trie, U.S. District Court for the District of Columbia, Jan. 28, 1998.
    \634\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

                    Kuang Tao Zhou $50,000 (Suspect)

    On April 18, 1996, Mei Chi Kuo Chow of Los Angeles, 
California, issued a check in the amount of $30,000 to Kuang 
Tao Zhou,\635\ a college student who resides in Philadelphia, 
Pennsylvania.\636\ The entire $30,000 can be traced to a 
$60,000 February 27, 1996, wire transfer from Tzu Shih Chow's 
account at Chinatrust Commercial Bank to Mei Chi Kuo Chow's 
account at Union Bank, Santa Monica, California.\637\ Zhou 
deposited the $30,000 check into his account at Jefferson Bank 
of Philadelphia that same day.\638\ His checking account 
balance was $3,646.70 at the time of the deposit.\639\ The 
following day, on April 19, 1996, Zhou issued a check in the 
amount of $30,000 to the DNC in conjunction with the April 26, 
1996, Philadelphia POTUS GalaRendell Dinner.\640\ DNC 
contribution information produced to the Committee attributes 
the solicitation of Zhou's contribution to Mayor Ed Rendell of 
Philadelphia.\641\ In addition to the foregoing, Zhou 
contributed an additional $26,500 to the DNC, $2,000 to the 
DSCC and $4,000 to congressional and senatorial 
candidates.\642\
---------------------------------------------------------------------------
    \635\ Union Bank of California Account Statement of Mei Chi Kuo 
Chow, Apr. 24, 1996 (Exhibit 355); Union Bank of California Check No. 
2772 from Mei Chi Kuo Chow to Kuang Tao Zhou in the amount of $30,000, 
Apr. 18, 1996, and Jefferson Bank Deposit Ticket of Kuang Tao Zhou in 
the amount of $37,000, Apr. 18, 1996 (Exhibit 356).
    \636\ IGI Contribution Review Materials for Kuang Tao Zhou, HS 
001600-HS 001620, at 2 (Exhibit 357); ``Rendell's Top Donor Just Wants 
Spot in Law School,'' Harrisburg Patriot, Dec. 18, 1996, at B6.
    \637\ Union Bank of California Wire Transfer Report of Mei Chi Kuo 
Chow in the amount of $59,985, Feb. 28, 1996 (Exhibit 358); Union Bank 
of California Account Statement of Mei Chi Kuo Chow, Mar. 26, 1996 
(Exhibit 359).
    \638\ Exhibit 356 Union Bank of California Check No. 2772 from Mei 
Chi Kuo Chow to Kuang Tao Zhou in the amount of $30,000, Apr. 18, 1996, 
and Jefferson Bank Deposit Ticket of Kuang Tao Zhou in the amount of 
$37,000, Apr. 18, 1996; Jefferson Bank Account Statement of Kuang Tao 
Zhou, May 13, 1996 (Exhibit 360).
    \639\ Exhibit 360 Jefferson Bank Account Statement of Kuang Tao 
Zhou, May 13, 1996.
    \640\ Id.; Jefferson Bank Check No. 480 from Kuang Tao Zhou to the 
DNC Non-Federal in the amount of $30,000, Apr. 19, 1996 (Exhibit 361); 
Exhibit 357 IGI Contribution Review Materials for Kuang Tao Zhou, HS 
001600-HS 001620, at 2.
    \641\ Id.
    \642\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998. Apr. 24, 1996, 
$10,000 to the DNC; Apr. 24, 1996, $10,000 to the DNC; Aug. 12, 1996, 
$1,500 to the DNC Birthday Victory Fund; June 6, 1997, $2,000 to 
Representative Richard Gephardt (D-MO-3); Oct. 10, 1997, $1,000 to 
Senator Edward M. Kennedy (D-MA); Oct. 22, 1997, $5,000 to the DNC; 
Oct. 28, 1997, $2,000 to the DSCC; Mar. 31, 1998, $2,000 to Geraldine 
Ferraro (D-NY); Apr. 9, 1998, $500 to Robert A. Borski (D-PA-3).
---------------------------------------------------------------------------
    Also on April 19, 1996, Zhou received a $19,985 wire into 
his Jefferson Bank account from Tzu Shih Chow in Taiwan.\643\ 
FEC data and press reports indicate that Zhou contributed an 
additional $20,000 to the DNC in April 1996 in two separate 
$10,000 contributions which Zhou has described as a ``credit 
card'' contribution.\644\
---------------------------------------------------------------------------
    \643\ Jefferson Bank Account Credit Ticket of Kuang Tao Zhou in the 
amount of $19,977, Apr. 19, 1996 (Exhibit 362).
    \644\ http:wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998; ``Rendell's Top 
Donor Just Wants Spot in Law School,'' Harrisburg Patriot, Dec. 18, 
1996. The Committee has gathered credit card records that confirm a 
$10,000 contribution to the DNC on Apr. 23, 1996. Citibank Credit Card 
Account Statement for Kuang Tao Zhou, Apr. 30, 1996 (Exhibit 363). The 
Committee has not confirmed the second $10,000 contribution made on 
Apr. 24, 1996, as indicated by the FEC data and in the press.
---------------------------------------------------------------------------
    Ernst & Young conducted a review of Zhou's April 1996 
$30,000 contribution and was unable to confirm the address and 
telephone number provided by Zhou.\645\ The DNC mailed a review 
questionnaire to Zhou on January 6, 1997,\646\ but apparently 
received no response; the copy of Zhou's questionnaire provided 
to the Committee is completely blank.\647\ After Ernst & 
Young's unsuccessful attempt to verify the legality of Zhou's 
contribution, IGI made an attempt.\648\ IGI's review notes 
indicate that it was unable to gather any additional 
information on Zhou.\649\
---------------------------------------------------------------------------
    \645\ Exhibit 357 IGI Contribution Review Materials for Kuang Tao 
Zhou, HS 001600-HS 001620, at 3 and 5-7.
    \646\ Id. at 3.
    \647\ Id. at 9-21.
    \648\ Id. at 1-21.
    \649\ Id. at 6-8.
---------------------------------------------------------------------------
    On July 8, 1998, Committee investigators unsuccessfully 
attempted to telephone and locate Mei Chi Kuo and Tzu Shih Chow 
in Los Angeles, California. Also, Committee investigators 
repeatedly made unsuccessful attempts to telephone Zhou in 
Philadelphia at numbers provided by him to the DNC.
    As in other instances of suspect contributions, despite the 
paucity of information gathered pursuant to the Ernst & Young 
and IGI reviews, the DNC decided to retain Zhou's $30,000 
contribution. The DNC apparently did not conduct a review 
regarding Zhou's additional $20,000 in contributions also made 
in April 1996. While Zhou is a U.S. Citizen, according to Ernst 
& Young notes \650\ and the son of a wealthy Taiwanese 
magnate,\651\ bank records indicate that his three 
contributions to the DNC totaling $50,000 appear to have been 
illegal conduit contributions in violation of 2 U.S.C. 
Sec. 441f. In any event, the DNC has insufficient information 
to determine the legality or appropriateness of Zhou's 
contributions. Therefore, pursuant to Federal regulations and 
DNC practice, the DNC should disgorge Zhou's $50,000 in 
contributions to the U.S. Treasury.\652\
---------------------------------------------------------------------------
    \650\ Id. at 4.
    \651\ ``Rendell's Top Donor Just Wants Spot in Law School,'' 
Harrisburg Patriot, Dec. 18, 1996.
    \652\ See FEC Advisory Opinion 1995-19; FEC Advisory Opinion 1991-
39; Exhibit 4 Letter from Joseph E. Sandler, Esq., to Lawrence Noble, 
Esq., June 27, 1997 (citing FEC Advisory Opinion 1995-19 and FEC 
Advisory Opinion 1991-39); Exhibit 5 Letter from Joseph E. Sandler, 
Esq., to Lawrence Noble, Esq., Mar. 25, 1998; Exhibit 6 Letter from 
Judah Best, Esq., to James C. Wilson, Esq., Apr. 15, 1998; Exhibit 7 
DNC List of Contributions Returned or Disgorged Produced to the 
Committee on Nov. 20, 1997, at 1-9.
---------------------------------------------------------------------------

  Pauline Kanchanalak Related Contributions During the 1992, 1994 and 
                          1996 Election Cycles

Duangnet Kronenberg $261,500 and Pauline Kanchanalak $112,500 (Illegal)

    During the period September 1992 through June 1996, then-
DNC fund-raiser Pauline Kanchanalak and her sister-in-law, 
Duangnet ``Georgie'' Kronenberg, illegally funneled at least 
$679,000 to the DNC and other Democratic causes.\653\ In the 
wake of intense press scrutiny and a DNC internal investigation 
regarding Kanchanalak and her fund-raising activities, the DNC 
returned Kanchanalak's contributions totaling $253,500 \654\ on 
November 20, 1996.\655\ In contrast, the press paid far less 
attention to Kronenberg, whose contributions are detailed 
below: \656\
---------------------------------------------------------------------------
    \653\ Federal Grand Jury Indictment of Pauline Kanchanalak and 
Duangnet Kronenberg, U.S. District Court for the District of Columbia, 
July 13, 1998.
    \654\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.
    \655\ Marcy Gordon, ``DNC Returns $253,000 Attributed to Thai 
Donor; Businesswoman, a Legal U.S. Resident, Says Money Actually Came 
from Mother-in-Law,'' the Washington Post, Nov. 21, 1996; see also, 
http://wyl.ewg.org, Environmental Working Group Website, Compiled from 
FEC Data, Last Updated Sept. 10, 1998.
    \656\ Id.

----------------------------------------------------------------------------------------------------------------
                                                  Check                                                         
                     Name                         Date      FEC  Date             Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
Duangnet Kronenberg..........................    09/23/92    09/28/92  DNC............................    $4,000
Duangnet Kronenberg..........................    09/24/92    09/28/92  DNC............................     5,000
Duangnet Kronenberg..........................    05/26/94    05/27/94  DNC............................    20,000
Duangnet Kronenberg..........................    06/07/94    06/13/94  DNC............................    15,000
Duangnet Kronenberg..........................    02/26/96    02/29/96  DNC............................     5,000
Duangnet Kronenberg..........................    03/08/96    03/11/96  DNC............................     5,000
Duangnet Kronenberg..........................    03/14/96    03/15/96  DNC............................     5,000
Duangnet Kronenberg..........................    05/23/96    06/06/96  DNC............................     5,000
Duangnet Kronenberg..........................    06/18/96    06/19/96  DNC............................    50,000
----------------------------------------------------------------------------------------------------------------

Owing to what appears to have been relatively little press 
scrutiny of Kronenberg--a database search of national 
periodicals indicates that only 27 articles mentioning 
Kronenberg were published between the breaking of the campaign 
finance scandal on September 21, 1996, and December 31, 1996, 
in contrast to 149 articles mentioning Kanchanalak \657\--the 
DNC retained her contributions totaling $114,000 until recently 
when it disgorged $105,000 to the U.S. Treasury; \658\ it did 
not disgorge $9,000.\659\ On July 13, 1998, Kanchanalak and 
Kronenberg were indicted by a Federal grand jury and charged 
with ``conspiring to impair and impede the FEC and to cause the 
submission of false statements to the FEC.'' \660\ It was not 
until the indictment that the DNC pledged to return 
Kronenberg's contributions.\661\
---------------------------------------------------------------------------
    \657\ The search referenced was conducted on the ``allnewsplus'' 
library of the Westlaw database. The search used regarding Kronenberg 
was ``date (1996) and (Georgie Duangnet) +2 Kronenberg. The search used 
regarding Kanchanalak was ``date (1996) and Pauline +2 Kanchanalak.''
    \658\ See Exhibit 18 Letter from Joseph E. Sandler, Esq., to 
Lawrence M. Noble, Esq., July 24, 1998.
    \659\ According to a letter from the DNC to the FEC, the DNC did 
not disgorge the Sept. 23, 1992, $4,000 contribution to the DNC and the 
Sept. 24, 1992, $5,000 contribution to the DNC. See generally Exhibit 
18 Letter from Joseph E. Sandler, Esq., to Lawrence M. Noble, Esq., 
July 24, 1998.
    \660\ Federal Grand Jury Indictment of Pauline Kanchanalak and 
Duangnet Kronenberg, U.S. District Court for the District of Columbia, 
July 13, 1998.
    \661\ Amy Keller, ``Burton Eyes Unreturned DNC Cash,'' Roll Call, 
July 20, 1998.
---------------------------------------------------------------------------
    In addition to the DNC, 10 state Democratic parties 
received contributions from Kanchanalak and Kronenberg as 
detailed below: \662\
---------------------------------------------------------------------------
    \662\ http://wyl.ewg.org, Environmental Working Group Website, 
Compiled from FEC Data, Last Updated Sept. 10, 1998.

----------------------------------------------------------------------------------------------------------------
                                                  Check                                                         
                     Name                         Date      FEC  Date             Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
Pauline Kanchanalak..........................    10/20/92  ..........  California Democratic Party....    $5,000
Pauline Kanchanalak..........................    06/25/96  ..........  California Democratic Party....    24,500
Pauline Kanchanalak..........................    06/27/96  ..........  Florida Democratic Party.......    35,000
Pauline Kanchanalak..........................    06/29/96  ..........  Ohio Democratic Party..........    33,000
Pauline Kanchanalak..........................    07/05/96  ..........  Illinois Democratic Party......    25,000
Pauline Kanchanalak..........................    07/05/96  ..........  Pennsylvania Democratic Party..    25,000
Duangnet Kronenberg..........................    09/08/94  ..........  Massachusetts Democratic Party.     5,000
Duangnet Kronenberg..........................    10/06/94  ..........  Maryland Democratic Party......     4,000
Duangnet Kronenberg..........................    10/06/94  ..........  Oklahoma Democratic Party......     5,000
Duangnet Kronenberg..........................    10/06/94  ..........  Kentucky Democratic Party......     2,500
Duangnet Kronenberg..........................    10/06/94  ..........  West Virginia Democratic Party.     1,000
Duangnet Kronenberg..........................    06/13/96  ..........  California Democratic Party....    30,000
Duangnet Kronenberg..........................    06/15/96  ..........  Florida Democratic Party.......    25,000
Duangnet Kronenberg..........................    06/18/96  ..........  Illinois Democratic Party......    30,000
Duangnet Kronenberg..........................    06/21/96  ..........  Ohio Democratic Party..........    20,000
Duangnet Kronenberg..........................    06/25/96  ..........  Pennsylvania Democratic Party..    25,000
----------------------------------------------------------------------------------------------------------------

    Recently, the Committee wrote the 10 state Democratic 
parties who received contributions from Kanchanalak and 
Kronenberg to inquire as to the state parties' retention of 
these contributions and inform them of the indictment and the 
DNC's practice of returning illegal political contributions to 
the U.S. Treasury pursuant to Federal election law.\663\ The 
Committee has received information that Florida, Maryland, and 
Ohio have returned the contributions.\664\ Massachusetts has 
informed Committee counsel that it is reviewing the matter. The 
remainder have, to date, yet to respond to the Committee.\665\ 
These contributions are illegal and should be returned.
---------------------------------------------------------------------------
    \663\ Letters from Chairman Dan Burton to the state Democratic 
parties of Maryland, Oklahoma, Kentucky, West Virginia, California, 
Florida, Illinois, Ohio, and Pennsylvania, July 24, 1998, and 
Massachusetts, Aug. 3, 1998 (Exhibit 364). Kanchanalak's contributions 
to state Democratic parties include: Oct. 20, 1992, $5,000 to the 
California Democratic party; June 25, 1996, $24,500 to the California 
Democratic party; June 27, 1996, $35,000 to the Florida Democratic 
party; June 29, 1996, $33,000 to the Ohio Democratic party; July 5, 
1996, $25,000 to the Illinois Democratic party; July 5, 1996, $25,000 
to the Pennsylvania Democratic party.
    \664\ Letter from Maryland Democratic party to Chairman Dan Burton, 
July 29, 1998 (Exhibit 365); Letter from Florida Democratic party to 
Chairman Dan Burton, July 29, 1998 (Exhibit 366); Letter from Ohio 
Democratic party to Chairman Dan Burton, July 30, 1998 (Exhibit 367).
    \665\ The Committee has not received a response from the state 
Democratic parties of Massachusetts, Oklahoma, Kentucky, West Virginia, 
California, Illinois, and Pennsylvania.
---------------------------------------------------------------------------
    The DNC conducted a review of Kronenberg's contributions in 
December 1996.\666\ Kronenberg cooperated with Ernst & Young 
auditors and indicated that the money contributed to the DNC 
was her own.\667\ In the fall of 1997 much more information 
regarding Kronenberg's contribution came to light as a result 
of the House and Senate campaign finance investigations. On 
September 16, 1997, the Senate Governmental Affairs Committee 
held a hearing focusing directly on certain contributions of 
Kanchanalak and Kronenberg.\668\ The Senate committee publicly 
disclosed the foreign source of these contributions.\669\ 
However, until recently, the DNC and state Democratic parties 
evidently were ignorant of the publicly available evidence that 
Kronenberg's contributions were highly suspect and possibly 
illegal.
---------------------------------------------------------------------------
    \666\ Ernst & Young Contribution Review Materials for Duangnet 
Kronenberg, DNC 1802603, DNC 1802606, DNC 1802609-DNC 1802610, DNC 
1802612, DNC 1802615, DNC 1802617, and DNC 1802619-DNC 1802623, at 1-12 
(Exhibit 368).
    \667\ Id. at 5.
    \668\ See generally Investigation of Illegal or Improper Activities 
in Connection with the 1996 Federal Election Campaign Before the Senate 
Committee on Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d 
sess., vol. 1, 206-223, 1192, and 475 (1998).
    \669\ See generally Id. at 208 and 475; Investigation of Illegal or 
Improper Activities in Connection with the 1996 Federal Election 
Campaign Before the Senate Committee on Governmental Affairs, 105th 
Cong., 1st sess., part VII, S. Hrg. 105-300, 384 (1998).
---------------------------------------------------------------------------
    And, if that were not sufficient, the Final Report of that 
same Senate committee dedicated over 15 pages to detailing the 
fund-raising activities of Kanchanalak and Kronenberg.\670\ The 
report directly questioned the legality of the contributions 
\671\ and contains sufficient information for the DNC to 
conclude that Kronenberg's contributions were possibly illegal 
and, at a minimum, inappropriate under the DNC's own criteria 
of appropriateness. DNC General Counsel Sandler even admitted 
to the Committee that he read the Senate report ``about the 
time'' it was made public,\672\ but the DNC still did not 
return Kronenberg's contributions.
---------------------------------------------------------------------------
    \670\ See generally Investigation of Illegal or Improper Activities 
in Connection with the 1996 Federal Election Campaign Before the Senate 
Committee on Governmental Affairs, S. Rept. No. 167, 105th Cong., 2d 
sess., vol. 1, 206-223 and 1192 (1998).
    \671\ Id. at 208; see also Investigation of Illegal or Improper 
Activities in Connection with the 1996 Federal Election Campaign Before 
the Senate Committee on Governmental Affairs, 105th Cong., 1st sess., 
part VII, S. Hrg. 105-300, 384 (1998).
    \672\ Committee Deposition of Joseph E. Sandler, Esq., May 14, 
1998, 113.
---------------------------------------------------------------------------
    The DNC ignored the publicly available evidence regarding 
Kronenberg's contributions until she was indicted by a Federal 
grand jury.\673\ In the wake of the indictment, DNC spokesman 
Rick Hess reacted with surprise:
---------------------------------------------------------------------------
    \673\ DNC Response to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 38-39.

        Until the indictment was handed down last week, there 
        was no indication that donations from Ms. Kronenberg 
        were from anybody but herself.\674\
---------------------------------------------------------------------------
    \674\ Amy Keller, ``Burton Eyes Unreturned DNC Cash,'' Roll Call, 
July 20, 1998 (emphasis added).

    Additionally, DNC General Counsel Sandler in a July 24, 
---------------------------------------------------------------------------
1998, letter advised the FEC that:

        Prior to the date of the indictment, the DNC had no 
        information indicating that these specific 
        contributions were in any way unlawful or 
        improper.\675\
---------------------------------------------------------------------------
    \675\ Exhibit 18 Letter from Joseph E. Sandler, Esq., to Lawrence 
M. Noble, Esq., July 24, 1998 (emphasis added).

    Prior to the date of the indictment, the public record 
indicated otherwise. The DNC's litany of misleading statements 
that were issued when the campaign scandal broke in 1996 
continue even today.
    It is interesting to note that although the DNC ignored the 
Senate Final Report with regard to Kronenberg's contributions, 
it has cited that same Final Report to the Committee when it 
has supported their decision to retain certain 
contributions.\676\ Furthermore, Ms. Kronenberg has refused to 
cooperate with both House and Senate investigators and has 
invoked her Fifth Amendment privilege against self-
incrimination.
---------------------------------------------------------------------------
    \676\ DNC Response to the Committee's June 23, 1998, 
Interrogatories, Aug. 6, 1998, at 12.
---------------------------------------------------------------------------
    In sum, the DNC returned Kanchanalak's contributions in 
late 1996 in the wake of the breaking campaign finance scandal 
under the lights of intense press scrutiny. As a result of its 
internal inquiry regarding Kanchanalak, the DNC was aware of 
Kronenberg's contributions and her relationship with 
Kanchanalak. But the DNC retained Kronenberg's contributions. 
In September 1997, the Senate held campaign finance hearings 
which specifically questioned the legality of Kronenberg's 
contributions. But the DNC retained Kronenberg's contributions. 
The Senate published its Final Report in early 1998 again 
directly questioning the legality of Kronenberg's contributions 
and, soon thereafter, DNC General Counsel Sandler read it. But 
the DNC retained Kronenberg's contributions. In July 1998, 
Kronenberg was indicted by a Federal grand jury for campaign 
finance violations. Finally, the DNC returned Kronenberg's 
contributions. Even then the DNC maintained that they never had 
any indication Kronenberg's contributions were ``unlawful,'' 
``improper,'' or ``from anybody but herself.'' The DNC's 
actions with regard to Kronenberg's contributions are 
indicative of the disingenuous approach the DNC has taken 
throughout the campaign finance scandal.

                               Conclusion

    After an extensive and thorough investigation of the DNC's 
contribution review process and contributions received by it 
from 1992-1996, it is clear that the DNC's public words often 
were and continue to be at odds with its intentions and 
actions. Time and time again, the DNC received information 
regarding the illegality or inappropriateness of contributions, 
but failed to take the appropriate action of returning or 
disgorging them. Moreover, often when the DNC received no 
significant information regarding contributions, it retained 
the funds. Prompting the DNC to return illegal or otherwise 
questionable contributions has at times closely resembled the 
painful and difficult process of pulling teeth.
    The Committee's conclusions would likely be altogether 
different were the contributions at issue not linked to a 
variety of other suspicious individuals--most of which have 
refused to cooperate with Federal authorities--and 
circumstances under investigation by the Department of Justice 
as well as the Committee. Though the Committee has been 
severely hampered in its investigation by non-cooperative 
witnesses, it still has been identified over $1.7 million in 
illegal or suspect contributions that remains in Democratic 
coffers, over $1 million of which is held by the DNC alone. 
Hundreds of thousands of dollars in additional questionable 
contributions--many of which are almost certainly illegal--are 
still under investigation by the Committee. Many questions 
regarding the orchestration of illegal campaign contributions 
remained unanswered. The American People deserve the truth. For 
that reason, the Committee's investigation continues.

                                APPENDIX

 ILLEGAL AND SUSPECT CONTRIBUTIONS RETAINED OR BELATEDLY DISGORGED BY 
   THE DEMOCRATIC NATIONAL COMMITTEE AND STATE DEMOCRATIC PARTIES \1\

   I. Illegal Contributions (Sorted by Name, Check Date and FEC Date)

----------------------------------------------------------------------------------------------------------------
                                                  Check     FEC  Date                                           
                     Name                       Date \2\       \3\                Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
Lei Chu......................................    02/20/96    02/23/96  Democratic National Committee..   $12,500
Jessica Elnitiarta...........................    02/19/96    02/23/96  Democratic National Committee..   100,000
J&M International............................    02/23/96    02/27/96  Democratic National Committee..    25,000
K&L International............................    05/11/96    05/14/96  Democratic National Committee..   150,000
Pauline Kanchanalak..........................    10/20/92  ..........  California Democratic Party....     5,000
Pauline Kanchanalak..........................    06/25/96  ..........  California Democratic Party....    24,500
Pauline Kanchanalak..........................    06/27/96  ..........  Florida Democratic Party.......    35,000
Pauline Kanchanalak..........................    06/29/96  ..........  Ohio Democratic Party..........    33,000
Pauline Kanchanalak..........................    07/05/96  ..........  Illinois Democratic Party......    25,000
Pauline Kanchanalak..........................    07/05/96  ..........  Pennsylvania Democratic Party..    25,000
Chee Kien Koh................................    09/17/96    09/25/96  Democratic National Committee..     5,000
Duangnet Kronenberg..........................    09/24/92    09/28/92  Democratic National Committee..     5,000
Duangnet Kronenberg..........................    09/23/92    09/28/92  Democratic National Committee..     4,000
Duangnet Kronenberg..........................    05/26/94    05/27/94  Democratic National Committee..    20,000
Duangnet Kronenberg..........................    06/07/94    06/13/94  Democratic National Committee..    15,000
Duangnet Kronenberg..........................    09/08/94  ..........  Massachusetts Democratic Party.     5,000
Duangnet Kronenberg..........................    10/06/94  ..........  Kentucky Democratic Party......     2,500
Duangnet Kronenberg..........................    10/06/94  ..........  Maryland Democratic Party......     4,000
Duangnet Kronenberg..........................    10/06/94  ..........  Oklahoma Democratic Party......     5,000
Duangnet Kronenberg..........................    10/06/94  ..........  West Virginia Democratic Party.     1,000
Duangnet Kronenberg..........................    02/26/96    02/29/96  Democratic National Committee..     5,000
Duangnet Kronenberg..........................    03/08/96    03/11/96  Democratic National Committee..     5,000
Duangnet Kronenberg..........................    03/14/96    03/15/96  Democratic National Committee..     5,000
Duangnet Kronenberg..........................    05/23/96    06/06/96  Democratic National Committee..     5,000
Duangnet Kronenberg..........................    06/13/96  ..........  California Democratic Party....    30,000
Duangnet Kronenberg..........................    06/15/96  ..........  Florida Democratic Party.......    25,000
Duangnet Kronenberg..........................    06/18/96  ..........  Illinois Democratic Party......    30,000
Duangnet Kronenberg..........................    06/18/96    06/19/96  Democratic National Committee..    50,000
Duangnet Kronenberg..........................    06/21/96  ..........  Ohio Democratic Party..........    20,000
Duangnet Kronenberg..........................    06/25/96  ..........  Pennsylvania Democratic Party..    25,000
Bie Chuan Ong................................    10/09/92    10/21/92  California Democratic Party....     5,000
Bie Chuan Ong................................    10/19/92    10/21/92  Arkansas Democratic Party......     5,000
Bie Chuan Ong................................  ..........    10/23/92  Michigan Democratic Party......     5,000
Bie Chuan Ong................................  ..........    10/23/92  Democratic Senatorial Campaign      5,000
                                                                        Committee.                              
Lucy Jao Ong.................................    10/10/92    10/21/92  Arkansas Democratic Party......     5,000
Lucy Jao Ong.................................  ..........    10/21/92  California Democratic Party....     5,000
Lucy Jao Ong.................................  ..........    10/22/92  Democratic Senatorial Campaign      5,000
                                                                        Committee.                              
Lucy Jao Ong.................................  ..........    10/23/92  Michigan Democratic Party......     5,000
Sy Zuan Pan..................................    09/18/96    09/27/96  Democratic National Committee..    20,000
Panda Estates Investment Inc.................    07/12/96    07/23/96  Democratic National Committee..  \4\ 60,0
                                                                                                              00
Hsiao Jie Su.................................    02/17/96    02/23/96  Democratic National Committee..     2,500
Subandi Tanuwidjaja..........................    09/19/96    10/02/96  Democratic National Committee..    20,000
Suryanti Tanuwidjaja.........................    09/16/96    09/27/96  Democratic National Committee..   20,000 
----------------------------------------------------------------------------------------------------------------
\1\ The contributions indicated in italics were belatedly disgorged. All other contributions have been retained 
  by the recipient.                                                                                             
\2\ The ``Check Date'' is taken directly from the contribution check where available.                           
\3\ If the Committee is not in possession of the check or is unable to discern the date on the check, Federal   
  Election Commission [FEC] data as provided at http://wyl.ewg.org and/or www.tray.com is used. In those        
  instances, the ``FEC Date'' given reflects the date the contribution was registered with the FEC not          
  necessarily the precise date of contribution as reflected on the contribution check. The date on the          
  contribution check usually pre-dates the FEC date by anywhere from one day to a month.                        
\4\ This illegal $60,000 is a portion of a $100,000 contribution. Committee investigators consider the remaining
  $40,000 suspect.                                                                                              

                  II. Summary of Illegal Contributions

----------------------------------------------------------------------------------------------------------------
                                                                               Belatedly                        
                                                               Retained  vs.   Disgorged                  Total 
----------------------------------------------------------------------------------------------------------------
Arkansas Democratic Party Illegal...........................    $10,000                                  $10,000
California Democratic Party Illegal.........................     69,500                                   69,500
Democratic National Committee Illegal.......................    415,000          $114,000                529,000
Democratic Senatorial Campaign Committee Illegal............     10,000                                   10,000
Florida Democratic Party Illegal............................  .........            60,000                 60,000
Illinois Democratic Party Illegal...........................     55,000                                   55,000
Kentucky Democratic Party Illegal...........................      2,500                                    2,500
Maryland Democratic Party Illegal...........................  .........             4,000                  4,000
Massachusetts Democratic Party Illegal......................      5,000                                    5,000
Michigan Democratic Party Illegal...........................     10,000                                   10,000
Ohio Democratic Party Illegal...............................  .........            53,000                 53,000
Oklahoma Democratic Party Illegal...........................      5,000                                    5,000
Pennsylvania Democratic Party Illegal.......................     50,000                                   50,000
West Virginia Democratic Party Illegal......................      1,000                                    1,000
                                                             -----------     -------------             ---------
    Total Illegal Contributions.............................    633,000    +      231,000        =       864,000
----------------------------------------------------------------------------------------------------------------

  III. Suspect Contributions (Sorted by Name, Check Date and FEC Date)

----------------------------------------------------------------------------------------------------------------
                                                  Check                                                         
                     Name                         Date      FEC  Date             Recipient              Amount 
----------------------------------------------------------------------------------------------------------------
American Great Ground Group..................    07/20/96    07/31/96  Democratic National Committee..    $7,000
AIDC \5\.....................................    12/25/93  ..........  Democratic National Committee..    25,000
Donna Chiang.................................    09/18/92    09/28/92  Democratic National Committee..    10,000
Donna Chiang.................................    09/22/92    10/07/92  Democratic National Committee..    10,000
Joseph Chiang................................    09/18/92    09/28/92  Democratic National Committee..    10,000
Joseph Chiang................................    09/22/92    10/07/92  Democratic National Committee..    10,000
Brenda Da Silveira...........................    10/19/92    10/27/92  Democratic Senatorial Campaign      5,000
                                                                        Committee.                              
Ricor Da Silveira............................    10/19/92    10/27/92  Democratic Senatorial Campaign      5,000
                                                                        Committee.                              
Ricor Da Silveira............................    10/21/92    10/27/92  Michigan Democratic Party......     5,000
Ricor Da Silveira............................    10/22/96    10/27/92  Arkansas Democratic Party......     5,000
Hip Hing Holdings............................    05/28/93  ..........  Democratic National Committee..     2,500
Hip Hing Holdings............................    09/23/93    09/30/96  Democratic National Committee..    15,000
Hip Hing Holdings............................    09/29/93  ..........  California Democratic Party....     5,000
Jane Huang...................................    08/12/92    08/19/92  Democratic National Committee..     5,000
Jane Huang...................................    08/10/92    09/04/92  California Democratic Party....     5,000
Jane Huang...................................    09/01/92    09/09/92  Democratic National Committee..     1,000
Jane Huang...................................    09/15/92    09/22/92  Democratic National Committee..     5,000
Jane Huang...................................    09/15/92    09/22/92  Democratic National Committee..     5,000
Jane Huang...................................    09/16/92    09/28/92  California Democratic Party....     1,000
Jane Huang...................................    04/30/93    05/07/93  Democratic Senatorial Campaign      2,500
                                                                        Committee.                              
Jane Huang...................................  ..........    06/15/93  Democratic Senatorial Campaign      1,000
                                                                        Committee.                              
Jane Huang...................................    10/05/93    10/21/93  Democratic Senatorial Campaign      6,750
                                                                        Committee.                              
Jane Huang...................................    12/01/93    12/14/93  Democratic National Committee..    15,000
Jane Huang...................................  ..........    03/16/94  Democratic National Committee..    10,000
Jane Huang...................................  ..........    04/26/94  California Democratic Party....    10,000
Jane Huang...................................    04/20/94    04/29/94  Democratic National Committee..     5,000
Jane Huang...................................  ..........    05/16/94  Democratic Congressional Dinner     3,000
                                                                        Committee.                              
Jane Huang...................................  ..........    08/11/94  Democratic National Committee..     5,000
Jane Huang...................................    12/18/94    12/22/94  Democratic National Committee..     5,000
Jane Huang...................................  ..........    11/14/95  Democratic Senatorial Campaign      1,000
                                                                        Committee.                              
Jane Huang...................................  ..........    11/17/95  Democratic Congressional            5,000
                                                                        Campaign Committee.                     
John Huang...................................  ..........    02/04/92  California Democratic Party....       500
John Huang...................................  ..........    06/01/92  Democratic National Committee..       800
John Huang...................................  ..........    07/28/92  Democratic National Committee..     5,000
John Huang...................................    08/31/92    09/04/92  California Democratic Party....     1,500
John Huang...................................    09/08/92    09/23/92  Democratic Senatorial Campaign      1,500
                                                                        Committee.                              
John Huang...................................    09/16/92    09/28/92  California Democratic Party....     1,000
John Huang...................................    10/27/92  ..........  Democratic National Committee..     2,500
John Huang...................................    10/31/92    11/10/92  Democratic Senatorial Campaign      1,000
                                                                        Committee.                              
John Huang...................................    04/30/93    05/07/93  Democratic Senatorial Campaign      2,500
                                                                        Committee.                              
John Huang...................................  ..........    06/15/93  Democratic Senatorial Campaign      1,000
                                                                        Committee.                              
John Huang...................................  ..........    06/25/93  Democratic National Committee..    10,000
John Huang...................................    10/05/93    10/21/93  Democratic Senatorial Campaign      6,750
                                                                        Committee.                              
John Huang...................................    12/01/93    12/14/93  Democratic National Committee..    10,000
John Huang...................................  ..........    03/16/94  Democratic National Committee..    10,000
Yong Xing Huang..............................    05/13/96    05/17/96  Democratic National Committee..    10,000
Loh Sun International........................    07/29/96    08/02/96  Democratic National Committee..    50,000
Felix Ma.....................................    08/30/92    10/23/92  Democratic Senatorial Campaign      5,000
                                                                        Committee.                              
Felix Ma.....................................    09/10/92    10/23/92  Michigan Democratic Party......     5,000
Felix Ma.....................................    09/30/92    10/23/92  Ohio Democratic Party..........     5,000
Mary Ma......................................    09/15/92    10/27/92  Michigan Democratic Party......     5,000
Mary Ma......................................    09/25/92    10/22/92  Democratic Senatorial Campaign      5,000
                                                                        Committee.                              
Mary Ma......................................    09/30/92  ..........  Democratic Senatorial Campaign      5,000
                                                                        Committee.                              
Mary Ma......................................  ..........    10/23/92  Missouri Democratic Party......     5,000
Mary Ma......................................  ..........    10/28/92  Ohio Democratic Party..........     5,000
Panda Estates Investment Inc.................    07/12/96    07/23/96  Democratic National Committee..  \6\ 40,0
                                                                                                              00
Panda Estates Investment Inc.................    07/29/96    08/01/96  Democratic National Committee..    50,000
Platinum Realty..............................    02/19/96    02/22/96  Democratic National Committee..    12,500
Platinum Realty..............................    07/18/96    08/01/96  Democratic National Committee..    10,000
Aileen Riady.................................    08/13/92    09/04/92  California Democratic Party....     5,000
Aileen Riady.................................    08/13/92    08/17/92  Democratic National Committee..    15,000
Aileen Riady.................................    10/08/92    10/27/92  Arkansas Democratic Party......     5,000
Aileen Riady.................................    10/12/92  ..........  Georgia Democratic Party.......    50,000
Aileen Riady.................................    10/15/92    10/29/92  North Carolina Democratic Party    50,000
James T. Riady...............................    08/13/92    09/04/92  California Democratic Party....     5,000
James T. Riady...............................    08/13/92    08/17/92  Democratic National Committee..    15,000
James T. Riady...............................    09/30/92  ..........  Michigan Democratic Party......    75,000
James T. Riady...............................    10/05/92  ..........  Ohio Democratic Party..........    75,000
James T. Riady...............................    10/08/92    10/27/92  Arkansas Democratic Party......     5,000
James T. Riady...............................    10/08/92  ..........  Arkansas Democratic Party......    75,000
James T. Riady...............................    10/12/92  ..........  Louisiana Democratic Party.....    75,000
San Jose Holdings............................    09/27/93    09/30/93  Democratic National Committee..    15,000
Joseph Sund..................................    09/24/92    09/28/92  Democratic National Committee..    10,000
Joseph Sund..................................    09/30/92    10/23/92  Michigan Democratic Party......     5,000
Joseph Sund..................................  ..........    10/21/92  Arkansas Democratic Party......     5,000
Joseph Sund..................................    09/28/93    09/30/93  Democratic National Committee..    10,000
Joseph Sund..................................    09/30/93    10/30/93  Democratic National Committee..     5,000
Joseph Sund..................................    09/30/93    10/30/93  Democratic National Committee..     5,000
Subandi Tanuwidjaja..........................    09/09/96  ..........  Democratic National Committee..    60,000
Toy Center Holdings..........................  ..........    07/15/93  Democratic National Committee..     2,500
Toy Center Holdings..........................    09/23/93    09/30/93  Democratic National Committee..    15,000
Christina Yeh................................  ..........    09/29/92  Democratic National Committee..     5,000
Christina Yeh................................  ..........    09/29/92  Democratic National Committee..     5,000
Christina Yeh................................  ..........    10/07/92  Democratic National Committee..     5,000
Christina Yeh................................  ..........    10/07/92  Democratic National Committee..     5,000
Christina Yeh................................  ..........    10/25/93  Democratic National Committee..    10,000
David Yeh....................................    08/03/92    09/29/92  Democratic National Committee..     5,000
David Yeh....................................    08/08/92    09/29/92  Democratic National Committee..     5,000
David Yeh....................................    08/18/92    10/07/92  Democratic National Committee..     5,000
David Yeh....................................    08/18/92    10/07/92  Democratic National Committee..     5,000
David Yeh....................................    09/27/93    10/25/93  Democratic National Committee..    10,000
Ji Ping Yu...................................    08/17/96  ..........  Democratic National Committee..     5,000
Kuang Tao Zhou...............................  ..........    04/24/96  Democratic National Committee..    10,000
Kuang Tao Zhou...............................  ..........    04/24/96  Democratic National Committee..    10,000
Kuang Tao Zhou...............................    04/19/96    04/25/96  Democratic National Committee..   30,000 
----------------------------------------------------------------------------------------------------------------
\5\ The Arkansas International Development Corp.                                                                
\6\ This suspect $40,000 is a portion of a $100,000 contribution. Committee investigators consider the remaining
  $60,000 illegal.                                                                                              

                  IV. Summary of Suspect Contributions

----------------------------------------------------------------------------------------------------------------
                                                                              Belatedly                         
                                                            Retaiained  vs.   Disgorged                  Total  
----------------------------------------------------------------------------------------------------------------
Arkansas Democratic Party Suspect.........................     $95,000       ..........                  $95,000
California Democratic Party Suspect.......................      34,000       ..........                   34,000
Democratic Congressional Campaign Committee Suspect.......       5,000       ..........                    5,000
Democratic Congressional Dinner Committee Suspect.........       3,000       ..........                    3,000
Democratic National Committee Suspect.....................     623,800       ..........                  623,800
Democratic Senatorial Campaign Committee Suspect..........      49,000       ..........                   49,000
Georgia Democratic Party Suspect..........................      50,000       ..........                   50,000
Louisiana Democratic Party Suspect........................      75,000       ..........                   75,000
Michigan Democratic Party Suspect.........................      95,000       ..........                   95,000
Missouri Democratic Party Suspect.........................       5,000       ..........                    5,000
North Carolina Democratic Party Suspect...................      50,000       ..........                   50,000
Ohio Democratic Party Suspect.............................      85,000       ..........                   85,000
                                                           ------------     ------------             -----------
    Total Suspect Contributions...........................   1,169,800    +        0.00        =       1,169,800
----------------------------------------------------------------------------------------------------------------

           V. Summary of Contributions (Illegal vs. Suspect)

----------------------------------------------------------------------------------------------------------------
                                                              Illegal   vs.    Suspect                   Total  
----------------------------------------------------------------------------------------------------------------
Arkansas Democratic Party..................................    $10,000           95,000                 $105,000
California Democratic Party................................     69,500           34,000                  103,500
Democratic Congressional Campaign Committee................  .........            5,000                    5,000
Democratic Congressional Dinner Committee..................  .........            3,000                    3,000
Democratic National Committee..............................    529,000          623,800                1,152,800
Democratic Senatorial Campaign Committee...................     10,000           49,000                   59,000
Florida Democratic Party...................................     60,000       ..........                   60,000
Georgia Democratic Party...................................  .........           50,000                   50,000
Illinois Democratic Party..................................     55,000       ..........                   55,000
Kentucky Democratic Party..................................      2,500       ..........                    2,500
Louisiana Democratic Party.................................  .........           75,000                   75,000
Maryland Democratic Party..................................      4,000       ..........                    4,000
Massachusetts Democratic Party.............................      5,000       ..........                    5,000
Michigan Democratic Party..................................     10,000           95,000                  105,000
Missouri Democratic Party..................................  .........            5,000                    5,000
North Carolina Democratic Party............................  .........           50,000                   50,000
Ohio Democratic Party......................................     53,000           85,000                  138,000
Oklahoma Democratic Party..................................      5,000       ..........                    5,000
Pennsylvania Democratic Party..............................     50,000       ..........                   50,000
West Virginia Democratic Party.............................      1,000       ..........                    1,000
                                                            -----------     ------------             -----------
    Total Contributions....................................    864,000    +   1,169,800        =       2,033,800
----------------------------------------------------------------------------------------------------------------

    VI. Summary of Contributions (Retained vs. Belatedly Disgorged)

----------------------------------------------------------------------------------------------------------------
                                                                              Belatedly                         
                                                             Retained   vs.   Disgorged                  Total  
----------------------------------------------------------------------------------------------------------------
Arkansas Democratic Party.................................    $105,000                                   105,000
California Democratic Party...............................     103,500                                   103,500
Democratic Congressional Campaign Committee...............       5,000                                     5,000
Democratic Congressional Dinner Committee.................       3,000                                     3,000
Democratic National Committee.............................   1,038,800          114,000                1,152,800
Democratic Senatorial Campaign Committee..................      59,000                                    59,000
Florida Democratic Party..................................                       60,000                  $60,000
Georgia Democratic Party..................................      50,000                                    50,000
Illinois Democratic Party.................................      55,000                                    55,000
Kentucky Democratic Party.................................       2,500                                     2,500
Louisiana Democratic Party................................      75,000                                    75,000
Maryland Democratic Party.................................                        4,000                    4,000
Massachusetts Democratic Party............................       5,000                                     5,000
Michigan Democratic Party.................................     105,000                                   105,000
Missouri Democratic Party.................................       5,000                                     5,000
North Carolina Democratic Party...........................      50,000                                    50,000
Ohio Democratic Party.....................................      85,000           53,000                  138,000
Oklahoma Democratic Party.................................       5,000                                     5,000
Pennsylvania Democratic Party.............................      50,000                                    50,000
West Virginia Democratic Party............................       1,000                                     1,000
                                                           ------------     ------------             -----------
    Total Contributions...................................   1,802,800    +    $231,000        =       2,033,800
----------------------------------------------------------------------------------------------------------------

                     VII. Summary of Contributions

--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                                                                      Belatedly                         
                                                            Illegal   vs.    Suspect                 Retained   vs.   Disgorged                  Total  
--------------------------------------------------------------------------------------------------------------------------------------------------------
Arkansas Democratic Party................................    $10,000           95,000                  105,000                                   105,000
California Democratic Party..............................     69,500           34,000                  103,500                                   103,500
Democratic Congressional Campaign Committee..............                       5,000                    5,000                                     5,000
Democratic Congressional Dinner Committee................                       3,000                    3,000                                     3,000
Democratic National Committee............................    529,000          623,800                1,038,800          114,000                1,152,800
Democratic Senatorial Campaign Committee.................     10,000           49,000                   59,000                                    59,000
Florida Democratic Party.................................     60,000                                                     60,000                   60,000
Georgia Democratic Party.................................                      50,000                   50,000                                    50,000
Illinois Democratic Party................................     55,000                                    55,000                                    55,000
Kentucky Democratic Party................................      2,500                                     2,500                                     2,500
Louisiana Democratic Party...............................                      75,000                   75,000                                    75,000
Maryland Democratic Party................................      4,000                                                      4,000                    4,000
Massachusetts Democratic Party...........................      5,000                                     5,000                                     5,000
Michigan Democratic Party................................     10,000           95,000                  105,000                                   105,000
Missouri Democratic Party................................                       5,000                    5,000                                     5,000
North Carolina Democratic Party..........................                      50,000                   50,000                                    50,000
Ohio Democratic Party....................................     53,000           85,000                   85,000           53,000                  138,000
Oklahoma Democratic Party................................      5,000                                     5,000                                     5,000
Pennsylvania Democratic Party............................     50,000                                    50,000                                    50,000
West Virginia Democratic Party...........................      1,000                                     1,000                                     1,000
                                                          -----------     ------------             ------------     ------------             -----------
    Total Contributions..................................    864,000    +   1,169,800       or       1,802,800    +     231,000        =       2,033,800
--------------------------------------------------------------------------------------------------------------------------------------------------------

    [Supporting documentation follows:]