Third Bank Records Memorandum - Redacted
Third Bank Records Memorandum - Redacted
MEMORANDUM
RE: Third Bank Records Memorandum from the Oversight Committee’s Investigation
into the Biden Family’s Influence Peddling and Business Schemes
Committee staff is releasing a Third Bank Records Memorandum to apprise Majority Members
of the ongoing investigation of the Biden family’s influence peddling schemes. On March 16,
2023, staff issued the first memorandum (First Bank Records Memorandum), highlighting the
Biden family’s use of the Robinson Walker, LLC account to receive money from a certain
Chinese entity. On May 10, 2023, staff issued a second memorandum (Second Bank Records
Memorandum), which focused on the Bidens’ business dealings in Romania and additional
information regarding their partnership with Chinese entities closely tied to the Chinese
Communist Party (CCP).1
This Third Bank Records Memorandum serves to inform Members of the Biden family’s
relationships with certain foreign entities and individuals in Russia, Ukraine, and Kazakhstan.
The Committee has subpoenaed six different banks and received thousands of records in
response. The Committee’s subpoenas were tailored to specific individuals and companies that
engaged in business activities with Biden family members and their business associates. The
Committee has not yet subpoenaed bank records of members of the Biden family.
Committee staff will continue to release memoranda as new information is uncovered.
1
Memorandum (Mar. 16, 2023), H. Comm. on Oversight & Accountability. From Maj. Comm. staff to Comm.
Members. Re: New Evidence Resulting from the Oversight Committee’s Investigation into the Biden Family’s
Influence Peddling and Business Schemes; Memorandum (May. 10, 2023), H. Comm. on Oversight &
Accountability. From Maj. Comm. staff to Comm. Members. Re: Second Bank Records Memorandum from the
Oversight Committee’s Investigation into the Biden Family’s Influence Peddling and Business Schemes.
1
Summary
Committee Staff is Releasing Payments from Russia, Ukraine, and Kazakhstan that
Occurred During Joe Biden’s Vice Presidency: The Committee has now identified over
$20 million in payments from foreign sources to the Biden family and their business
associates.
Hunter Biden and Devon Archer Used Rosemont Seneca Entities to Bring in Millions
from Oligarchs in Europe and Asia: Using accounts nominally tied to Devon Archer (but
using the familiar “Rosemont Seneca” branding), Hunter Biden received incremental
payments originating from foreign sources, attempting to hide the source and size of the
payments.
In February 2014, a Russian Oligarch Sent $3.5 Million to a Shell Company Associated
with Hunter Biden and Devon Archer: Russian billionaire Yelena Baturina transferred $3.5
million to Rosemont Seneca Thornton, a shell company. Approximately $1 million was
transferred to Devon Archer, and the remainder was used to initially fund a new company
account, Rosemont Seneca Bohai, which Devon Archer and Hunter Biden used to receive
other foreign wires.
In Spring 2014, a Ukrainian Oligarch Placed Archer and Biden on the Burisma Board of
Directors and Agreed to Pay them $1 Million Each per Year: Burisma Holdings’ (Burisma)
corporate secretary, Vadym Pozharsky, worked on behalf of the Ukrainian oligarch and
owner of Burisma, Mykola Zlochevsky. Hunter Biden was initially hired by Burisma to
work as counsel for the company, and Pozharsky and Zlochevsky met with Hunter Biden at a
conference in Lake Como in Italy where they decided Hunter Biden would work on the board
of directors with Devon Archer. Then-Vice President Joe Biden visited Ukraine soon after
their first payments. Payments from Burisma for both Devon Archer and Hunter Biden were
wired to Rosemont Seneca Bohai. Payments were transmitted in incremental amounts to
Hunter Biden’s different bank accounts.
In April 2014, a Kazakhstani Oligarch Wired the Exact Price of Biden’s Sportscar to a
Bank Account Used by Archer and Biden: In February 2014, Hunter Biden met with Kenes
Rakishev at a Washington, D.C. hotel. Rakishev worked closely with the prime minister of
Kazakhstan, Karim Massimov. In April, Rakishev, a Kazakhstani oligarch, wired $142,300
to Rosemont Seneca Bohai. The next day, a payment was made from Rosemont Seneca
Bohai for a sportscar for Hunter Biden in the amount of $142,300. Archer and Biden then
arranged for Burisma executives to visit Kazakhstan in June 2014 to evaluate a three-way
deal among Burisma, a Chinese state-owned company, and the government of Kazakhstan.
Hunter Biden received millions of dollars in payments from Yelena Baturina, Burisma,
and Kenes Rakishev. Vice President Biden had dinner with them in the spring of 2014
and 2015 in Washington, D.C.
2
A. The Biden Family Received Millions from Russia, Kazakhstan, and Ukraine
President Biden Lied About His Family’s Business Deals. The Committee has revealed
millions of dollars have come into the Biden family’s bank accounts from foreign sources,
including China, Romania, Kazakhstan, Russia, and Ukraine. Independent whistleblowers’
sworn testimony from the criminal investigation into Hunter Biden has corroborated the
Committee’s financial investigation. Testimony from Hunter Biden’s former business
partner, Devon Archer, also supports the Committee’s findings. No one in the Biden
Administration or in the Minority has explained what services, if any, the Bidens and their
associates provided in exchange for the over $20 million in foreign payments.
Joe Biden was “The Brand” sold around the world to enrich the Biden family and he was
used to “signal” their access, influence, and power. The Committee’s investigation has
shown that money was transferred to the Bidens from foreign nationals or entities based in
Russia, Kazakhstan, and Ukraine when Joe Biden was Vice President. Then-Vice President
Biden met—in person, for significant periods of time—with those individuals or their
representatives. Then-Vice President Biden joined approximately 20 phone calls on
speakerphone with Hunter Biden’s foreign business associates and attended dinners with
foreign oligarchs who paid huge sums of money to Hunter Biden.2 Joe Biden, “the brand,”
was the only product the Bidens sold.
President Biden’s Family is the Vehicle to Receive Bribery Payments. President Biden’s
defenders purport a weak defense by asserting the Committee must show payments directly
to the President to show corruption. This is a hollow claim no other American would be
afforded if their family members accepted foreign payments or bribes. Indeed, the law
recognizes payments to family members to corruptly influence others can constitute a bribe.3
The Biden White House’s Attempt to Move the Goalposts Shows They Have No Answers.
The White House’s latest claim that the “President was not in business with his son” is a
marked departure from previous attempts to counter the Committee’s investigation.
President Biden and White House spokespersons previously stated that the President had no
knowledge of his son’s business and did not discuss business with his son. The Office of
White House Counsel refuses to answer questions about this departure from previous
statements.4
2
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 51; see also Transcript of Devon
Archer, H. Comm. on Oversight and Accountability, at 45-47.
3
Under the Foreign Corrupt Practices Act, “Companies also may violate the FCPA if they give payments or gifts to
third parties, such as an official’s family members, as an indirect way of corruptly influencing a foreign official.”
FCPA – A Resource Guide to the U.S. Foreign Corrupt Practices Act (Second Edition), U.S. Dep’t of Justice
(Criminal Division) & U.S. Securities and Exchange Commission (Enforcement Division), p. 16 (emphasis added).
4
Letter from Hon. Elise Stefanik, Chairwoman, H. Republican Conference, Hon. James Comer, Chairman, H.
Comm. on Oversight & Accountability, Hon. Jim Jordan, Chairman, H. Comm. on the Judiciary, & Hon. Jason
Smith, Chairman, H. Comm. on Ways & Means, to Mr. Stuart Delery, White House Counsel (July 20, 2023); see
also Josh Christenson, WH snubs GOP demand to explain Joe’s shifting story on Hunter, N.Y. Post (July 28, 2023).
3
The Committee intends to craft legislation that would strengthen reporting requirements
related to certain foreign transactions involving senior elected officials’ family members and
that would implement robust financial disclosure requirements that shed light on ownership
of opaque corporate entities. Moreover, in order to prevent financial transactions from being
structured in a way to evade oversight, the Committee is examining whether certain reporting
requirements, including any new reporting requirements for senior elected officials’ family
members, should extend for a period of time after a President or Vice President leaves office.
The Committee also seeks to strengthen the Bank Secrecy Act and anti-money laundering
laws by analyzing whether financial institutions have the available tools and support from
federal agencies to thwart illegal money laundering and foreign corruption activity. The
Committee is evaluating whether Suspicious Activity Reports generated by personal and
corporate bank accounts associated with a Vice President’s or President’s immediate family
members should undergo a more rigorous banking compliance process, receive an expedited
review by law enforcement without undue influence by political appointees, and be disclosed
to Congress, under certain circumstances, given potential political corruption and risks to our
national security.
The Committee aims to draft legislation that delivers more transparency to the American
people, deters foreign interests from attempting to obtain influence over and access to the
highest levels of the federal government by entering into business deals with presidential and
vice-presidential family members, discourage such family members from capitalizing on
their relatives’ public service, and ensure the nation is safe from foreign adversaries.
4
The Third Bank Records Memorandum discusses three of these entities: Rosemont Seneca
Partners, LLC; Rosemont Seneca Thornton, LLC; and Rosemont Seneca Bohai, LLC.
One of the entities identified in the Second Bank Records Memorandum was Rosemont
Seneca Partners, LLC (Rosemont Seneca Partners). Hunter Biden, Devon Archer, and others
formed Rosemont Seneca Partners on June 25, 2009.7 Hunter Biden and Devon Archer were
equity holders in this entity.
Hunter Biden served as chairman of Rosemont Seneca Partners; Devon Archer served as the
chief executive officer; Eric Schwerin served as the president.
5
Memorandum (May. 10, 2023), H. Comm. on Oversight & Accountability. From Maj. Comm. staff to Comm.
Members. Re: Second Bank Records Memorandum from the Oversight Committee’s Investigation into the Biden
Family’s Influence Peddling and Business Schemes, at 6-7.
6
Id.
7
Internet Archive WayBackMachine, Leadership Team,
web.archive.org/web/20120827191603/http://www.rosemontseneca.com/team.html (last accessed Aug. 8, 2023).
5
Rosemont Seneca Partners was central to the Bidens’ later business ventures: many of the
entities Hunter Biden formed after 2009 would be housed under or would transact with
Rosemont Seneca Partners.
Another entity used by Hunter Biden and Devon Archer was Rosemont Seneca Thornton,
LLC (Rosemont Seneca Thornton).
Rosemont Seneca Thornton was registered in Delaware on May 28, 2013.8 The entity served
as a means to silo work with another Biden family associate, James “Jimmy” Bulger,
chairman of the Thornton Group.9 Rosemont Seneca Thornton was created in anticipation of
engaging in a Chinese private investment fund (BHR Partners) controlled by Chinese state-
owned enterprises, namely Bank of China.10 Additional information regarding BHR Partners
will be released in a future bank records memorandum.
On December 6, 2013, a bank account for Rosemont Seneca Thornton was opened and listed
Devon Archer and Rosemont Seneca Partners as beneficiaries of the account.
Hunter Biden was a beneficiary of funds deposited in the Rosemont Seneca Thornton bank
account through his stake in Rosemont Seneca Partners. This relationship is shown below:
8
OpenCorporates.com, ROSEMONT SENECA THORNTON, LLC.,
https://opencorporates.com/companies/us_de/5341255 (last accessed Aug. 4, 2023).
9
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 59.
10
Id.
6
Hunter Biden, Devon Archer, and others at Café Milano in Washington, D.C. Joe
Biden stayed for dinner.17
Following Russia’s invasion into Ukraine, the Biden Administration placed several Russian
oligarchs on the public sanctions list. Notably, Yelena Baturina is not on that list.18
On February 5, 2014, Hunter Biden met Kazakhstani oligarch Kenes Rakishev at the Hay
Adams Hotel in Washington, D.C.19 In email correspondences with Devon Archer
surrounding the meeting, Rakishev requested Secretary of State John Kerry visit Kazakhstan.
Archer replied, “if we have some business started as planned I will ensure its planned
soonest.”20
Rakishev is a Kazakhstani oligarch and millionaire and was a director at Kazakhstan’s state-
owned oil company KazMunayGas.21
Rakishev maintained ties to Karim Massimov,22 who became prime minister on April 2,
2014. On April 24, 2023, Massimov was sentenced to 18 years in prison for treason, abuse
of power, and attempting a coup.23
On April 22, 2014, Rakishev used his Singaporean entity, Novatus Holdings,24 to wire the
Rosemont Seneca Bohai bank account $142,300.
The next day, the exact same amount was wired out to a car dealership in New Jersey for an
expensive sportscar for Hunter Biden. Archer did not know why Rakishev bought the
sportscar for Hunter Biden.25 The wire transaction is below:
17
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 46.
18
John Hyatt, The Russian Oligarch Billionaires Who Haven’t Been Sanctioned, Forbes (April 7, 2022).
19
Email from Kenes Rakishev to Hunter Biden and Devon Archer dated February 5, 2014.
20
Email from Kenes Rakishev to Hunter Biden and Devon Archer dated February 5, 2014.
21
Aidana Demesinova, Kenes Rakishev became a freelance adviser to the Minister of Foreign Affairs, (translated
using Google Translate) (Aug. 6, 2019), https://kazpravda kz/n/kenes-rakishev-stal-vneshtatnym-sovetnikom-
ministra-inostrannyh-del/.
22
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 63.
23
Sentence passed in the case of Massimov K. and others, Court of Astana City (translated using Google Translate)
(Apr. 24, 2023), https://astana.sud.kz/rus/news/vynesen-prigovor-po-delu-masimova-k-i-drugih.
24
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 61-62.
25
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 64.
11
Figure 8 (From left to right) Kenes Rakishev, Hunter Biden, Vice President Biden, and Karim Massimov.
In early 2014, Devon Archer assumed a position on the Burisma board of directors.29
Burisma is an energy company founded in 2002 by Mykola Zlochevsky, a Ukrainian
oligarch, politician, and businessman.30
Hunter Biden joined Burisma as counsel in early 2014 and assumed a position on the board
of directors by April/May 2014.31 Devon Archer has testified to the Committee that Hunter
Biden became a member of the board of directors after a meeting in Lake Como with
Pozharsky and Zlochevsky.32
For their positions on the board of Burisma, Hunter Biden and Devon Archer reached a deal
with Burisma where each were paid $1 million per year, equating to each receiving
29
See Transcript of Devon Archer, at 13.
30
Reuters, Factbox: Burisma, the obscure Ukrainian gas company at the heart of U.S. political row (Sep. 24, 2019).
31
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 19.
32
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 17.
13
approximately $83,333 per month.33 Pozharsky played a central role with the Burisma board
of directors and communicating between Biden/Archer and Zlochevsky.
Payments from Burisma for Hunter Biden and Devon Archer were sent to the Rosemont
Seneca Bohai account—the same account that received the Rakishev wire and the account
where the Baturina wire was ultimately transferred. This arrangement changed in late 2015
because of Archer’s legal troubles, and Hunter Biden began receiving money from Burisma
into his corporate account, Owasco P.C., an account not shared with Devon Archer.34
For 2014 and 2015, Hunter Biden and Devon Archer received approximately $3.32 million.
All payments from Burisma to that account are produced below:
33
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 18.
34
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 24.
14
DATE SENDER RECIPIENT MONEY IN
4/15/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
4/15/2014 Burisma Holdings Limited Rosemont Seneca Bohai $29,424.82
5/15/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
5/15/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
6/17/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
6/17/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
6/18/2014 Burisma Holdings Limited Rosemont Seneca Bohai $60,954.54
7/15/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
7/15/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
8/18/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
8/18/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
9/16/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
9/16/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
10/7/2014 Burisma Holdings Limited Rosemont Seneca Bohai $28,913.89
10/7/2014 Burisma Holdings Limited Rosemont Seneca Bohai $2,543.38
10/15/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
10/15/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
11/18/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
11/18/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
12/16/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
12/16/2014 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
1/6/2015 Burisma Holdings Limited Rosemont Seneca Bohai $47,249.07
1/14/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
1/14/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
2/17/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
2/17/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
3/16/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
3/16/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
4/15/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
4/15/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
5/18/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
5/18/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
6/9/2015 Burisma Holdings Limited Rosemont Seneca Bohai $3,668.47
6/18/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
6/18/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
7/16/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
7/16/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
7/28/2015 Burisma Holdings Limited Rosemont Seneca Bohai $60,554.53
8/19/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
8/19/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
15
9/17/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
9/17/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
10/16/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
10/16/2015 Burisma Holdings Limited Rosemont Seneca Bohai $83,333.33
10/16/2015 Burisma Holdings Limited Rosemont Seneca Bohai $4,737.58
Total $3,321,379.49
Based on IRS whistleblower testimony, Hunter Biden and Devon Archer earned $6.5 million
from Burisma. This finding is consistent with the Committee’s investigation.35
As testified by an IRS whistleblower, the Rosemont Seneca Bohai account was used for
personal expenses of Hunter Biden, as well as to engage in further investment with Devon
Archer.36 Again, Devon Archer corroborated he and Hunter Biden were 50-50 owners in
Rosemont Seneca Bohai.37
Additionally, money wired by Burisma to the Rosemont Seneca Bohai account was often
transferred to Hunter Biden directly and his corporate entity, Owasco P.C. in small
increments. This is similar to Rob Walker’s later incremental distribution of money received
from Romanian entities from 2015 to 2017 and Chinese entities in 2017.38
Devon Archer could not explain why Hunter Biden received money in the Rosemont Seneca
Bohai account when Hunter Biden had other business accounts.39
An example of this income from Burisma, with subsequent payments out to Hunter Biden or
Owasco P.C. is produced below:
35
See Transcript of Special Agent, Internal Revenue Service, H. Comm. on Ways and Means, at 99.
36
See Transcript of Special Agent, Internal Revenue Service, H. Comm. on Ways and Means, at 63; see also
Transcript of Special Agent, at 102 (“So he underreported his total income by $267,000, if you are using the most
conservative approach, and that is a tax loss of $106,000. So that includes deductions for personal wages and
salaries paid, personal travel expenses paid, personal children expenses that he paid, and personal other expenses
that he paid.”).
37
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 65.
38
Memorandum (Mar. 16, 2023), H. Comm. on Oversight & Accountability. From Maj. Comm. staff to Comm.
Members. Re: New Evidence Resulting from the Oversight Committee’s Investigation into the Biden Family’s
Influence Peddling and Business Schemes, at 2.
39
See Transcript of Devon Archer, H. Comm. on Oversight and Accountability, at 67.
16
o Kenes Rakishev and his associate, former Prime Minister Karim Massimov, were
Kazakhstani oligarchs, and the latter has been convicted in Kazakhstan over
serious crimes.41 The Committee has identified $142,300 that benefitted the
Biden family and associates from this Kazakhstani source.
o Rosemont Seneca Thornton and Rosemont Seneca Bohai were both used to
receive funds that went to Hunter Biden.
o Rosemont Seneca Thornton first received the $3.5 million wire originating from
the Russian oligarch, Yelena Baturina.
o Rosemont Seneca Bohai ultimately received $2.75 million of the original wire
from Baturina, the wire from Kenes Rakishev, and Burisma payments until late
2015, when Burisma began sending funds for Hunter Biden to an account not
shared with Devon Archer.
41
Former Kazakh security boss jailed for 18 yrs over role in attempted coup, Reuters (April 24, 2023).
42
David L. Stern and Robyn Dixon, Ukraine says it intercepted $6 million bribe to stop probe of Burisma founder,
Wash. Post (June 14, 2020).
43
Laura Strickler and Rich Schapiro, Hunter Biden’s legal work in Romania raises new questions about his
overseas dealings, NBC News (Oct. 24, 2019).
44
Shu Zhang, Chen Aizhu, China’s CEFC founder Ye named in corruption case – state media, Reuters (Oct. 12,
2018).
18
3. Joe Biden participated in dinners with these individuals directly at Café Milano in
Washington, D.C. with Hunter Biden and Devon Archer in the spring of 2014 and 2015.
The Committee has issued letters to individuals for documents and/or transcribed interviews
from witnesses who were involved in particular financial transactions or had knowledge of
other documents related to this investigation. The Committee will continue to engage in the
accommodations process with those who have not cooperated with our investigation.
The Committee plans to gather additional bank records in the near future and continue
following the money trail. The Committee is committed to rooting out fraud, waste, and
abuse that exist at the highest level of the federal government.
19