Impeachment Inquiry Scoping Memo Final

MEMORANDUM
TO: Members of the Committee on Oversight and Accountability, Committee on

Judiciary, and Committee on Ways and Means
FROM: Chairman James Comer, Chairman Jim Jordan, and Chairman Jason Smith
DATE: September 27, 2023
RE: Impeachment Inquiry
I. Introduction
For the past several months, the House Committees on Oversight and Accountability
(Oversight Committee), Ways and Means (Ways and Means Committee), and the Judiciary
(Judiciary Committee) (collectively, Committees) have been investigating (1) foreign money
received by the Biden family, (2) President Joe Biden’s involvement in his family’s foreign
business entanglements, and (3) steps taken by the Biden Administration to slow, hamper, or
otherwise impede the criminal investigation of the President’s son, Robert Hunter Biden, which
involves funds received by the Biden family from foreign sources. As a result of these
investigations, the Committees have uncovered significant new information that raises serious
concerns as to whether the President has abused his federal office to enrich his family and
conceal his and/or his family’s misconduct. This information includes:
The Biden family and their business associates received over $24 million from foreign sources
over the course of approximately five years.
• From 2014 to 2019, Biden family members and their affiliate companies received over
$15 million from foreign companies and foreign nationals in Ukraine, Russia,
Kazakhstan, Romania, and China. Biden business associates received an additional $9
million.
• This money was transmitted to Biden family members from foreign sources through an
exceedingly complex chain of transactions that made it difficult to track the flow of these
funds.
President Biden was personally involved in his family’s foreign business dealings, and those
business arrangements intersected with his official duties.
• The President had knowledge of many of his family’s business dealings, and indeed
participated in them by having phone calls and attending private dinners—including
while he was Vice President—with his family’s business associates and foreign business
associates who would pay his family millions of dollars for no identifiable product or
service.
1
• These foreign business associates of the President’s family had interests in countries
where then-Vice President Biden—and as President—played, and continues to play, an
active role in formulating and implementing the foreign policy of the United States.
The President has not been truthful about his family’s foreign business entanglements.
• Weeks before the 2020 Presidential election, then-candidate Joe Biden said on national
television that his family did not receive any money from China. That was a lie. Joe
Biden not only knew about his family’s work with Chinese nationals, business associates
have confirmed that Joe Biden met with his family’s Chinese associates—including while
he was Vice President.
• President Biden’s assertions that he never discussed business with his family are false.
The Committees have also uncovered substantial information, including through

whistleblowers, indicating that the Biden Administration has obstructed the criminal
investigation into Hunter Biden. This information includes evidence that Department of Justice
personnel blocked avenues of inquiry that could have led to evidence incriminating President
Biden and impeded efforts to prosecute Hunter Biden for tax crimes relating to foreign business
arrangements that could have implicated President Biden.
As a result of the information assembled by the Committees, on September 12, 2023,

Speaker Kevin McCarthy directed the Committees to open a formal impeachment inquiry into
President Joe Biden. While work on legislative reforms to address the deficiencies in current law
revealed by the Committees’ investigations will continue, the Committees will now additionally
focus on determining whether to recommend articles of impeachment against President Biden as
detailed below.
This Memorandum further explains the purpose of the inquiry, summarizes the evidence
justifying the inquiry, and outlines the scope of this impeachment investigation.
II. Purpose of Impeachment Inquiry
We begin with a brief overview of the impeachment power before turning to the purpose
of this specific impeachment inquiry.
The Constitution vests the House of Representatives with the “sole Power of
Impeachment”1 and provides that the “President, Vice President and all civil Officers of the
United States, shall be removed from Office on Impeachment for, and Conviction of, Treason,
Bribery, or other high Crimes and Misdemeanors.”2 While removal is automatic once an officer
is impeached and convicted, Congress may, in its discretion, go further and disqualify the officer
from ever “hold[ing] … any Office of honor, Trust or Profit under the United States.”3
1
U.S. Const. art. I, § 2, cl. 5.
2
Id. art. II, § 4.
3
See id. art. I, § 3, cl. 7.
2
As Alexander Hamilton explained in Federalist No. 65, impeachment involves “those
offenses which proceed from the misconduct of public men, or, in other words, from the abuse or
violation of some public trust.”4 In our nation’s history, such offenses have included bribery,
abuse of power, obstruction of justice, obstruction of Congress, perjury, and using one’s office
for personal gain.5 Hamilton described impeachment as a “bridle in the hands of the legislative
body upon the executive servants of the government.”6 As an exclusive Congressional authority,
impeachment serves as a critical check on the other branches of the federal government.7 It also
protects our constitutional republic from officers who engage in malfeasance.8 After all, once an
officer is impeached and convicted, he is automatically removed from office and can be
disqualified from ever holding office again.
Given that impeachment is designed, among other things, to protect the American people
from corrupt public officials, it makes sense that the Constitution does not limit impeachable
offenses to those an officer committed while serving in his current office. In fact, the
Constitution says nothing at all about the timing of impeachable acts. An officer may be
impeached for conduct in a former office as well as his current office. Indeed, the House has
adopted articles of impeachment based on conduct occurring prior to an officer assuming his
current position.9 As a result, President Biden may be impeached for any impeachable offenses
he committed as Vice President in addition to any such offenses he has committed as President.
The purpose of this inquiry—and at this stage, it is just that, an inquiry—is to determine
whether sufficient grounds exist for the Committees to draft articles of impeachment against
President Biden for consideration by the full House. This impeachment inquiry will enable the
Committees to gather information necessary to assess whether President Biden has engaged in
impeachable conduct.10 The decision to begin this inquiry does not mean that the Committees
4
See, e.g., The Federalist No. 65 (Hamilton).
5
See, e.g., H. Rep. No. 100-810, at 1 (1988) (first article explaining a conspiracy where a district court judge took
money from criminal defendants and, in return, imposed sentences that did not require incarceration); H.R. Res. 755,
116th Cong. (2019) (abuse of power and obstruction of Congress); H. Rep. No. 105-830, at 32-105 (1998)
(describing articles based on perjury, obstruction of justice, and abuse of power); H. Doc. No. 62-1140, at 1701
(1912) (“He [the impeached officer] has prostituted his high office for personal profit. He has attempted by various
transactions to commercialize his potentiality as a judge.”).
6
The Federalist No. 65 (Hamilton).
7
See, e.g., The Federalist No. 66 (Hamilton) (“[T]he powers relating to impeachments are … an essential check in
the hands of [Congress] upon the encroachments of the executive.”); see also U.S. Const. art. II, § 2, cl. 1 (“The
President … shall have Power to grant Reprieves and Pardons for Offenses against the United States, except in
Cases of Impeachment.” (emphasis added)).
8
See, e.g., 1 Joseph Story, Commentaries on the Constitution of the United States § 803, at 568 (4th ed. 1873)
(“[Impeachment] is not so much designed to punish an offender as to secure the state against gross official
misdemeanors. It touches neither his person nor his property, but simply divests him of his political capacity.”).
9
In 1912, the House impeached Judge Robert Archbald, who was a federal district court judge and then a federal
circuit court judge. When the House adopted thirteen articles of impeachment against him, Archbald was a federal
circuit court judge, but six articles were based solely on his conduct as a district court judge, and another was based
on his conduct both as a district court judge and as a circuit court judge. More recently, in 2010, the House
impeached Judge G. Thomas Porteous, Jr., who was a state court judge before being appointed to the federal bench.
One of the articles of impeachment that the House adopted against him was based solely on events that occurred
while Porteous was still a state court judge, and a separate article was based on his conduct both while a state court
judge and while a federal judge.
10
See, e.g., In re Request for Access to Grand Jury Materials Grand Jury No. 81-1, Miami, 833 F.2d 1438, 1445
(11th Cir. 1987) (“[The House] holds investigative powers that are ancillary to its impeachment power.”).
3
have reached a conclusion on this question. As the U.S. Court of Appeals for the District of
Columbia Circuit has stated, “To level the grave accusation that a President may have committed
‘Treason, Bribery, or other high Crimes and Misdemeanors,’ U.S. Const. art. II, § 4, the House
must be appropriately informed.”11 And an impeachment inquiry is the traditional means by
which the House assembles and evaluates that information.12 There is no artificial deadline for
concluding this inquiry. The Committees will follow the facts and will take the necessary time to
determine whether articles of impeachment should be drafted and referred to the full House for
consideration.
While the full House must vote to adopt any articles of impeachment, the full House need
not vote to launch this impeachment inquiry. The Constitution, which, again, gives the House
the sole power of impeachment, includes no requirement that the full House vote to start an
impeachment inquiry. Neither do the Rules of the House of Representatives. In fact, the House
has launched several impeachment inquiries without a full House vote,13 and four years ago a
federal district court expressly rejected the argument that a House resolution is required to begin
an impeachment inquiry.14
III. Basis of Impeachment Inquiry and Information Obtained to Date
The Committees have accumulated significant evidence suggesting that President Biden
knew of, participated in, and profited from his family’s international business activities. The
evidence further suggests the President may have used certain members of his family—
particularly his son, Hunter Biden—to accumulate millions of dollars from foreign individuals
and entities for the benefit of his family and himself. In particular, the Committees have
assembled information indicating that President Biden may have: (1) performed official acts or
changed United States policy as a direct result of the foreign money received by his family; (2)
provided access to his federal office in exchange for his family’s receipt of foreign money;
and/or (3) knowingly participated in a scheme where foreign business interests were led to
believe that they would gain access to him (in his official capacity) if they were to pay
substantial amounts of money to his family. If any of these things did occur, that would
11
Comm. on Judiciary of U.S. House of Representatives v. McGahn, 968 F.3d 755, 765 (D.C. Cir. 2020) (en banc).
12
See, e.g., H. Rep. No. 116-346, at 28 (2019) (“Here, consistent with historical practice, the House divided its
impeachment inquiry into two phases, first collecting evidence and then bringing that evidence before the Judiciary
Committee for its consideration of articles of impeachment.”), https://www.congress.gov/116/crpt/hrpt346/CRPT-
116hrpt346.pdf; H. Rep. No. 111-427, at 7 (2010) (“[T]he impeachment inquiry was referred by the Committee on
the Judiciary to a Task Force on Judicial Impeachment …, comprised of 12 Committee Members, to conduct the
investigation.”), https://www.congress.gov/111/crpt/hrpt427/CRPT-111hrpt427.pdf; H.R. Rep. No. 101-8, at 292
(1989) (explaining that the relevant committee reviewed materials that had been compiled in other proceedings and
“began its own investigation” “in connection with the impeachment inquiry”).
13
For example, in the 1980s, the full House did not vote to authorize the impeachment inquiries involving Judge
Harry Claiborne, Judge Alcee Hastings, or Judge Walter Nixon. And in 2019, the Speaker of the House announced
the beginning of a formal impeachment inquiry into President Trump more than a month before the full House voted
to authorize it.
14
See In re Application of Comm. on Judiciary, 414 F. Supp. 3d 129, 168 (D.D.C. 2019) (“Even in cases of
presidential impeachment, a House resolution has never, in fact, been required to begin an impeachment inquiry.”),
aff’d, 951 F.3d 589 (D.C. Cir. 2020), vacated and remanded sub nom. on other grounds DOJ v. House Comm. on the
Judiciary, 142 S. Ct. 46 (2021).
4
constitute a grave abuse of the high office to which the American people have entrusted President
Biden.
The evidence also suggests President Biden has attempted to conceal his association with
and participation in various foreign business deals his family members arranged to capitalize on
his positions of public trust. And during the few instances in which the President has been given
an opportunity to explain his role in his family’s foreign business deals, the President has either
lied or made assertions that are highly implausible in light of the record before the Committees.
The evidence about the Biden family’s business practices the Committees have
accumulated, and Joe Biden’s participation in those activities, is significant and includes bank
records, discussions with former business associates, interviews with investigators from the
Hunter Biden criminal investigation, and government records from the Department of the
Treasury (Treasury Department), National Archives and Records Administration (National
Archives), the Federal Bureau of Investigation (FBI), and Internal Revenue Service (IRS). The
Committees have also reviewed records abandoned by the President’s son, including messages
among Biden family members. These messages appear to confirm President Biden has fostered a
system in which he uses his family members as agents that offer access to his positions of public
trust, influence on American policy, and protection from investigations or prosecution.
Moreover, this system appears to not only financially benefit the President’s family but also
himself. As recently as 2019, Hunter Biden texted a member of his own family “I Hope you all
can do what I did and pay for everything for this entire family Fro [sic] 30 years . . . [U]nlike Pop
I won’t make you give me half your salary.”15
Devon Archer, a longtime Biden business associate, during an interview with the
Oversight Committee, described the Biden “brand” as well as how Hunter Biden placed Joe
Biden on phone calls, including on speaker phone, approximately “20 times” with business
associates.16 Rob Walker, another longtime Biden associate, described Joe Biden taking
meetings with certain business partners. Archer also explained how then-Vice President Biden
sat at dinners with oligarchs who paid his son millions of dollars and met for coffee in Beijing
with his son’s Chinese business partner. Tony Bobulinski, another Biden associate, has
confirmed that Joe Biden was the “big guy” referenced in an email explaining how he and others
would divide equity in a joint venture with a corrupt Chinese company. This reference to the
“big guy” has been corroborated by reference to Joe Biden as the “big guy” in an FBI document
generated prior to the publicization of the email Bobulinski referenced. That same FBI
document details a bribery scheme in which the President allegedly participated with his son.
As part of its legislative and oversight work, the Oversight Committee has sought to
prevent potential future corruption by a President’s or Vice President’s family through
consideration of legislation aimed at imposing disclosure requirements regarding the financial
interests of the family members of Presidents and Vice Presidents. The Oversight Committee has
explained its legislative purposes in a series of investigative letters, hearings, and memoranda
that also detail through bank records the transfers of funds to the Biden family and its business
associates from Ukrainian, Russian, Kazakhstani, Romanian, and Chinese sources.
15
Text message from Hunter Biden to Naomi Biden, Jan. 3, 2019 (7:39 P.M.).
16
Transcribed interview of Devon Archer, H. Comm. on Oversight & Accountability (July 31, 2023), at 29 and 51.
5
The information and evidence the Committees have gathered establishes a good faith
basis to conclude that the President has been dishonest with the American people. There is
significant evidence that the President had involvement in his family’s foreign business
entanglements and his Administration has taken steps to impede the criminal investigation into
his family relating to those entanglements. For these reasons a formal impeachment inquiry into
his role in these matters is appropriate and necessary. Below is a summary of the evidence
accumulated by the Committees to date.
A. Summary of the Oversight Committee’s Financial Investigation
The Oversight Committee has reviewed Suspicious Activity Reports (SARs) from the
Treasury Department related to certain companies and business associates affiliated with the
Bidens.17 These SARs included detailed banking information that was flagged by financial
institutions involving Biden family members and their business associates.
Based in part on information from these SARs, the Oversight Committee has issued
subpoenas to six different banks for records related to companies and individuals who conducted
business with certain Biden family members and their related companies. A pattern of incredible
financial complexity emerged from Biden associates’ bank records and other evidence that
spanned from approximately 2014 to 2019. The Biden family used the corporate bank accounts
of third-party associates to receive wires from foreign companies and foreign nationals. The
Biden business associates would then disperse money to various Biden family members in
incremental payments over time. While much of this money went to Hunter Biden’s professional
corporation, Owasco P.C., and his other bank accounts, other Biden family members and their
companies also received significant payments.18
During the five-year period from 2014 to 2019, Biden family members and their
associates received over $24 million from foreign companies and foreign nationals, with more
than $15 million received by the Biden family and $9 million by business associates.19 The
Committees have not identified legitimate services that would warrant the lucrative payments
from these foreign sources.
17
Letter from Hon. James Comer, Chairman, H. Comm. on Oversight & Accountability, to Hon. Janet Yellen,
Secretary, U.S. Dep’t of Treasury (Jan. 11, 2023).
18
The Oversight Committee has identified specific companies that require further investigation based on the
financial documents that revealed a pattern of influence peddling and serious ethics issues. Some of these entities
are discussed in detail below and include Owasco P.C; Owasco, LLC; Rosemont Seneca Partners, LLC; Rosemont
Seneca Advisors, LLC; Skaneateles, LLC; Hudson West III, LLC; Hudson West V, LLC; Robinson Walker, LLC;
Rosemont Seneca Bohai, LLC; Rosemont Seneca Thornton, LLC; Lion Hall Group, LLC; and JBBSR, INC.
19
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;
Memorandum (Aug. 9, 2023), H. Comm. on Oversight & Accountability. From Maj. Comm. staff to Comm.
Members. Re: Third Bank Records Memorandum from the Oversight Committee’s Investigation into the Biden
Family’s Influence Peddling and Business Schemes.
6
B. Biden Influence Peddling with Ukrainian, Russian, and Kazakhstani Companies and
Nationals
(i) Influence Peddling in Ukraine and Payments from Burisma
With regard to Ukraine, the Oversight Committee has developed a significant body of
evidence consisting of financial records and testimony to suggest then-Vice President Biden’s
family used his position as Vice President to accumulate millions of dollars from Burisma, a
company then implicated in a years-long corruption investigation conducted by Ukrainian
authorities. The evidence also indicates that then-Vice President Biden took official action that
had the effect of benefiting Burisma. The evidence the Oversight Committee has developed
through testimony and bank records is bolstered by an FBI FD-1023 form that alleges the
President directly participated in a bribery scheme.
(ii) Financial Records and Testimony Regarding Burisma Payments
Hunter Biden joined Burisma as counsel in early 2014 and assumed a position on the
board of directors by April/May 2014.20 Devon Archer testified that Hunter Biden became a
member of the board of directors after a meeting in Lake Como, Italy, with Vadym Pozharsky,
Burisma’s corporate secretary, and Mykola “Nikolay” Zlochevsky, Burisma’s president.21
Pozharsky often communicated with Biden/Archer on behalf of Zlochevsky.22
For their positions on the board of Burisma, Hunter Biden and Devon Archer were each
paid $1 million per year, equating to each receiving approximately $83,333 per month.23 For
2014 and 2015, Hunter Biden and Devon Archer received approximately $3.32 million. Based
on IRS whistleblower testimony provided to the Ways and Means Committee, Hunter Biden and
Devon Archer earned $6.5 million from Burisma.24 This finding is consistent with the Oversight
Committee’s financial investigation thus far. Money wired by Burisma to the Rosemont Seneca
Bohai account was often later transferred to Hunter Biden directly and his professional
corporation, Owasco, P.C., in small increments.25 Hunter Biden did not have any relevant
qualifications for serving on the board of a Ukrainian energy company (other than his connection
to his father).
In February 2015, Viktor Shokin became the prosecutor general of Ukraine, inheriting an
ongoing investigation of Burisma’s President.26 Devon Archer testified about how Burisma
faced “government pressure from [the] Ukrainian Government investigations into Mykola, et
cetera.”27 On December 4, 2015, the Burisma board of directors met in Dubai.28 After that
20
Transcribed interview of Devon Archer, H. Comm. on Oversight & Accountability (July 31, 2023), at 19.
21
22
See, e.g., Email from Vadym Pozharsky to Hunter Biden dated May 7, 2014 (“Dear Hunter…[G]ood luck to you
in China, will convey your message to Nikolay.”).
23
24
See Transcript of Special Agent, Internal Revenue Service, H. Comm. on Ways and Means, at 99.
25
Memorandum (August 9, 2023), H. Comm. on Oversight & Accountability. From Maj. Comm. staff to Comm.
Family’s Influence Peddling and Business Schemes, at 16.
26
Oleg Sukhov, Political survivor Shokin takes over general prosecutor office; KYIV POST (Feb. 10, 2015).
27
28
7
meeting, Hunter Biden was asked to alleviate “pressure” Burisma was facing from the Ukrainian
government’s investigation into Zlochevsky, and Hunter Biden “called D.C.”29 Five days later—
on December 9, 2015—Vice President Biden delivered a speech to the Verkhovna Rada (the
Ukrainian parliament), in which he claimed the “Office of the General Prosecutor desperately
needs reform.”30 Indeed, on the flight to Ukraine, Vice President Biden reportedly “called an
audible” and “changed the plan” regarding the Obama-Biden Administration’s policy concerning
the renewal of a $1 billion loan guarantee for Ukraine, making it contingent upon the firing of
Shokin, which could help alleviate some of the pressure that Burisma was getting from Ukraine’s
government.31
In March 2016, the Rada voted to remove Shokin despite “veteran observers of Ukrainian
politics [saying] that the prosecutor . . . had played an important role in balancing competing
political interests, helping maintain stability during a treacherous era in the divided country’s
history.”32 In a 2018 public appearance before the Council on Foreign Relations, Joe Biden
described these events—albeit with inaccuracy regarding certain details:
I’m desperately concerned about the backsliding on the part of Kiev in terms
of corruption. They made—I mean, I’ll give you one concrete example. I
was—not I, but it just happened to be that was the assignment I got. I got
all the good ones. And so I got Ukraine. And I remember going over,
convincing our team, our leaders to—convincing that we should be
providing for loan guarantees. And I went over, I guess, the 12th, 13th time
to Kiev. And I was supposed to announce that there was another billion-
dollar loan guarantee. And I had gotten a commitment from Poroshenko
and from Yatsenyuk that they would take action against the state prosecutor.
And they didn’t.
So they said they had—they were walking out to a press conference. I said,
nah, I’m not going to—or, we’re not going to give you the billion dollars.
They said, you have no authority. You’re not the president. The president
said—I said, call him. I said, I’m telling you, you’re not getting the billion
dollars. I said, you’re not getting the billion. I’m going to be leaving here
in, I think it was about six hours. I looked at them and said: I’m leaving in
six hours. If the prosecutor is not fired, you’re not getting the money.
Well, son of a bitch. He got fired. And they put in place someone who
was solid at the time.33
The “solid” new prosecutor general of Ukraine who replaced Viktor Shokin was Yuriy
Lutsenko, who was not a lawyer and whose “one shining qualification appeared to be his loyalty
29
Transcribed interview of Devon Archer, H. Comm. on Oversight & Accountability (July 31, 2023), at 34, 36.
30
Remarks by Vice President Joe Biden to The Ukrainian Rada, Dec. 9, 2015, The White House, available at
https://obamawhitehouse.archives.gov/the-press-office/2015/12/09/remarks-vice-president-joe-biden-ukrainian-rada.
31
Glenn Kessler, Inside VP Biden’s linking of a loan to a Ukraine prosecutor’s ouster, Wash. Post (Sep. 15, 2023).
32
Andrew E. Kramer, Ukraine Ousts Viktor Shokin, Top Prosecutor, and Political Stability Hangs in the Balance,
N.Y. Times (March 29, 2016).
33
Foreign Affairs Issue Launch with Former Vice President Joe Biden, Council on Foreign Relations (Jan. 23, 2018)
(emphasis added).
8
to [President Petro Poroshenko].”34 Within a year of the elevation of Lutsenko, Ukrainian
prosecutors closed the investigation of Zlochevsky.35
In addition to this sudden change in the Obama-Biden Administration’s strategy

regarding Ukraine, Vice President Biden provided further value to his family’s business
associates by protecting them from anti-corruption efforts. Devon Archer testified that “people
would be intimidated to mess with [Burisma]….legally” because of the Biden “brand.”36 During
the transcribed interview with Devon Archer, he described the Biden “brand” and its value to a
company such as Burisma:
Q: You keep saying “the brand,” but by “brand” you mean the
Biden family, correct?
A: Correct.
Q: And that brand is what, in your opinion, was the majority of

what the value that was delivered from Hunter Biden to
Burisma?
A: I didn’t say majority, but I wouldn’t speculate on

percentages. But I do think that was an element of it.
Mr. Biggs: When you say “Biden family” – sorry to cut in here. I just
want to get a clarification.
You aren’t talking about Dr. Jill or anybody else. You’re

talking about Joe Biden. Is that fair to say?
A: Yeah, that’s fair to say. Listen, I think it’s – I don’t think

about it as, you know, Joe directly, but it’s fair. That’s fair to
say. Obviously, that brought the most value to the brand.37
On April 16, 2015, Hunter Biden, Devon Archer, and Vice President Joe Biden attended a
private dinner at Café Milano in Washington, D.C. with Vadym Pozharsky (a Burisma executive)
and others.38
Additional information about the Ukrainian payments can be found in the Third Bank
Records Memorandum released by the Oversight Committee.
34
Oleg Sukhov, Powerful suspects escape justice on Lutsenko’s watch, Kyiv Post (April 13, 2018).
35
Oleg Sukhov, Powerful suspects escape justice on Lutsenko’s watch, Kyiv Post (April 13, 2018).
36
37
Transcribed interview of Devon Archer, H. Comm. on Oversight & Accountability (July 31, 2023), at 29-30.
38
9
(iii) FBI FD-1023 Form
A June 30, 2020 FBI FD-1023 form subpoenaed by the Oversight Committee alleges that
President Biden directly participated in a bribery scheme involving Burisma. The confidential
human source (CHS) who provided its contents has been developed and trusted by the FBI since
the Obama-Biden Administration and was paid significant money for the information he or she
provided.
The FD-1023 form provides a detailed description of two in-person meetings and
telephone calls between the CHS and Burisma executives and/or then-president of Burisma,
Mykola Zlochevsky over the course of several years. The first meeting described in the FD-1023
form allegedly occurred in late 2015 or 2016. During that meeting with Burisma employee
Vadym Pozharsky and others, Pozharsky stated that members of the Burisma board of directors
included former Polish President Aleksander Kwasniewski and Hunter Biden. Pozharsky
allegedly said Hunter Biden was hired to “protect us, through his dad, from all kinds of
problems[.]”39 He also allegedly indicated that Hunter Biden “was not smart” and Burisma
therefore wanted to get additional counsel to advise on whether Burisma should purchase a
United States oil and gas business.40
In 2016, the FD-1023 form details that the CHS traveled to Vienna, Austria, and met with
Zlochevsky.41 During that meeting, the CHS advised against an initial public offering for
Burisma in the United States due to an ongoing Ukrainian corruption investigation focused on
Burisma, led by then-Prosecutor General Viktor Shokin. Zlochevsky replied something to the
effect of, “Don’t worry Hunter will take care of all of those issues through his dad.”42 During
this conversation, Zlochevsky allegedly told the CHS he had paid $5 million to two Bidens and
that both Hunter Biden and Joe Biden had told Zlochevsky to hire Hunter Biden to the board of
directors.43 The CHS understood the conversation to mean Zlochevsky “already had paid the
Bidens, presumably to ‘deal with Shokin.’”44
In 2016 or 2017, the CHS again spoke by phone with Zlochevsky. Zlochevsky stated he
was not happy about the outcome of the 2016 U.S. presidential election because of his
association with the Bidens. Zlochevsky stated “he didn’t want to pay the Bidens and he was
‘pushed to pay’ them.”45 Zlochevsky stated he had “many text messages and ‘recordings’ that
show he was coerced to make such payments[.]”46
In 2019, the CHS again spoke with Zlochevsky over the phone.47 The CHS stated
Zlochevsky could face difficulty explaining suspicious wire transfers “that may evidence any
(illicit) payments to the Bidens.”48 Zlochevsky stated that he did not directly transfer funds to
39
FBI Form FD-1023 (dated June 30, 2020), at 1.
40
Id.
41
FBI Form FD-1023 (dated June 30, 2020), at 1-2.
42
43
Id.
44
Id.
45
Id.
46
Id.
47
48
Id. (Parenthetical in original).
10
the “Big Guy,” which the CHS understood to mean Joe Biden, but used a series of transactions
that would take investigators years to trace.49
(iv) Payment from Russia
On December 6, 2013, a bank account for a company called Rosemont Seneca Thornton
was opened and listed Devon Archer and Rosemont Seneca Partners as beneficiaries of the
account.50 Hunter Biden, through his stake in Rosemont Seneca Partners, was a beneficiary of
funds deposited in the Rosemont Seneca Thornton bank account. On February 13, 2014,
Rosemont Seneca Bohai, LLC (Rosemont Seneca Bohai) was opened in Delaware.51 Devon
Archer confirmed to the Committee that he and Hunter Biden were 50-50 owners of Rosemont
Seneca Bohai.52
The next day, on February 14, 2014, the Russian oligarch Yelena Baturina—the
wealthiest woman in Russia at the time,53 and then married to the former Mayor of Moscow—
wired the Rosemont Seneca Thornton bank account $3.5 million.54 On March 11, 2014,
Rosemont Seneca Thornton transferred $2,752,711 to a Rosemont Seneca Bohai account.55 In
early February 2014—around the time of Baturina’s transfer of $3.5 million into the Rosemont
Seneca Thornton bank account—Devon Archer, Hunter Biden, and Vice President Biden had
dinner with Yelena Baturina and others at Café Milano in Washington, D.C.56 There is no
evidence that Hunter Biden performed any legitimate service in exchange for the money that
Baturina sent to companies affiliated with him.
Following Russia’s invasion of Ukraine in 2022, the Biden Administration placed several
Russian oligarchs on the public sanctions list. Notably, Yelena Baturina was not on the list.57
Additional information about the Russian payment can be found in the Third Bank
49
Id.
50
51
OpenCorporates.com, Rosemont Seneca Bohai, LLC, https://opencorporates.com/companies/us_de/5481769 (last
accessed Aug. 8, 2023).
52
53
Владелица Wildberries стала богатейшей россиянкой по версии Forbes, Forbes.ru (Feb. 20, 2020),
https://www.forbes.ru/milliardery/393387-vladelica-wildberries-stala-bogateyshey-rossiyankoy-po-versii-forbes.
54
55
56
57
John Hyatt, The Russian Oligarch Billionaires Who Haven’t Been Sanctioned, Forbes (April 7, 2022).
11
(v) $142,300 Sportscar from Kazakhstan
On February 5, 2014, an email indicates Hunter Biden met Kazakhstani oligarch Kenes
Rakishev at the Hay Adams Hotel in Washington, D.C.58 Rakishev was a Kazakhstani oligarch
and director of Kazakhstan’s state-owned oil company KazMunayGas.59 Rakishev maintained
ties to Karim Massimov,60 who became the prime minister on April 2, 2014.61 In email
correspondence with Biden business associate Devon Archer surrounding the meeting, Rakishev
requested that Secretary of State John Kerry visit Kazakhstan.62 Devon Archer replied, “If we
have some business started as planned I will ensure its [sic] planned soonest.”63 The Oversight
Committee continues to investigate the details of Secretary Kerry’s eventual visit to Kazakhstan
in November 2015.64
On April 22, 2014, Rakishev used his Singaporean entity, Novatus Holdings, to wire the
Rosemont Seneca Bohai bank account $142,300.65 The next day, the exact same amount was
wired out to a car dealership in New Jersey for an expensive sportscar for Hunter Biden. After
receiving the payment for the sportscar, in May and June of 2014, Hunter Biden and Devon
Archer represented Burisma on a trip to Kazakhstan to evaluate a deal between Burisma and
KazMunayGas.66
In early 2014, Devon Archer, Hunter Biden, and Vice President Biden had dinner with
Kenes Rakishev and Karim Massimov and others at Café Milano in Washington, D.C.67
Massimov would also attend the April 16, 2015, dinner with Hunter Biden, Devon Archer, Vice
President Biden, and others.68
Additional information about the Kazakhstani payment can be found in the Third Bank
C. Biden Influence Peddling in Romania
On May 21, 2014, then Vice President Biden visited Romania and delivered a speech
addressed to the Romanian Prime Minister, judges, prosecutors, and leaders of the parliament.69
During his speech, Vice President Biden stated the following:
58
Email from Kenes Rakishev to Hunter Biden and Devon Archer dated February 5, 2014.
59
Ракишев Кенес Хамитович, https://kapital.kz/dossier/rakishev-kenes.
60
61
Raushan Nurshayeva, Masimov returns as Kazakh PM to face economic crisis, Reuters (Apr. 2, 2014),
https://www.reuters.com/article/us-kazakhstan-government/masimov-returns-as-kazakh-pm-to-face-economic-
crisis-idUSBREA311AI20140402.
62
Email from Kenes Rakishev to Hunter Biden and Devon Archer dated February 5, 2014.
63
Email from Devon Archer to Kenes Rakishev, copying Hunter Biden dated February 5, 2014.
64
See, e.g., Matt Spetalnick, Kerry courts Kazakh leader as U.S. eyes stronger Central Asia ties, Reuters (Nov. 2,
2015).
65
66
Email from Devon Archer to Hunter Biden and Vadym Pozharsky dated May 7, 2014.
67
68
69
Remarks by vice President Joe Biden to Romanian Civil Society Groups and Students (Cotroceni Palace,
Bucharest, Romania), The White House – Office of the Vice President (May 21, 2014), available at
12
Corruption is a cancer, a cancer that eats away at a citizen’s faith in
democracy, diminishes the instinct for innovation and creativity; already-
tight national budgets, crowding out important national investments. It
wastes the talent of entire generations. It scares away investments and jobs.
And most importantly it denies the people their dignity. It saps the
collective strength and resolve of a nation. Corruption is just another form
of tyranny.
And corruption can represent a clear and present danger not only to a
nation’s economy, but to its very national security.70
In 2014 and 2015, one of the most high-profile corruption prosecutions in Romania
revolved around Gabriel Popoviciu.71 On September 28, 2015, Vice President Biden welcomed
Romanian President Klaus Iohannis to the White House.72 During the meeting, Vice President
Biden discussed anti-corruption issues and promoting the rule of law to strengthen Romania’s
national security.73 Within approximately five weeks of this meeting, Bladon Enterprises
Limited (Bladon Enterprises) began making deposits into the bank account of Robinson Walker,
LLC.74 Robinson Walker, LLC was formed by longtime Biden business associate John “Rob”
Walker. Bladon Enterprises is reported to be Gabriel Popoviciu’s company used to conduct
business in Romania.75
From November 2015 to May 2017, Bladon Enterprises paid Robinson Walker, LLC
over $3 million.76 Biden family accounts then received approximately $1.038 million from the
Robinson Walker, LLC account after the Bladon Enterprises deposits.77 The recipients of the
money from the Bladon Enterprises deposits included EEIG (James Gilliar), Hunter Biden,
Hallie Biden, Owasco, P.C., and an unknown Biden bank account.78 These payments appear to
be separate from any legal fees Hunter Biden received through the law firm, Boies Schiller, as
https://obamawhitehouse.archives.gov/the-press-office/2014/05/21/remarks-vice-president-joe-Biden-romanian-
civil-society-groups-and-stude.
70
Id. (emphasis added).
71
Laura Strickler & Rich Schapiro, Hunter Biden’s legal work in Romania raises new questions about his overseas
dealings, NBC News (Oct. 24, 2019).
72
The White House, Office of the Vice President, Readout of the Vice President’s Meeting with Romanian President
Klaus Iohannis (Sept. 28, 2015).
73
The White House, Office of the Vice President, Readout of the Vice President’s Meeting with Romanian President
Klaus Iohannis (Sept. 28, 2015).
74
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
75
Romanian investor develops large residential complex in office area (Oct. 6, 2016), available at
https://www.romania-insider.com/romanian-investor-develops-large-residential-complex-office-area.
76
77
78
13
the payments were directly from Rob Walker’s company. The Oversight Committee has not
identified legitimate services that would warrant these lucrative payments to Biden family
members.
Additional information about Romanian payments can be found in the Second Bank
D. Joe Biden and His Family Have Had Financial Dealings with Concerning Chinese
Nationals, and Joe Biden Has Made False Statements About Those Entanglements
On October 22, 2020, President Biden (then a candidate) answered a question about
whether there was anything inappropriate or unethical about his son’s business dealings in
Ukraine or China. President Biden denied that his son or anybody else from his family had
received money from China and stated:
My son has not made money in terms of this thing about, what are you
talking about, China. I have not had—the only guy who made money from
China is this guy [Donald Trump]. He’s the only one. Nobody else has
made money from China.79
Evidence shows this was not true. In fact, the evidence demonstrates Joe Biden knew his
statement was false. Evidence indicates President Biden has participated in his family’s dealings
with Chinese entities. All of this raises questions about why President Biden concealed his
family’s involvement with certain Chinese nationals and companies and whether any of his
official acts have been influenced by these prior business interactions and/or concern that
evidence regarding his family’s business dealings with China could be released.
(i) CEFC China Energy and Related Chinese Companies
CEFC China Energy (CEFC) was a Chinese energy conglomerate that quickly rose from
obscurity to becoming one of China’s largest ostensibly private companies. CEFC was closely
affiliated with China’s Belt and Road Initiative, and its chairman, Ye Jianming, told Chinese
media that CEFC “aims to serve the state’s strategy.”80 By 2017, Chairman Ye had “transformed
[CEFC] from a little-known fuel trader to a fast-expanding oil and finance giant with assets in
Europe, the Middle East, Central Asia and Africa.”81 Chairman Ye and CEFC reportedly had
connections to the Chinese military.82 Though it was in theory a private company, CEFC “has
layers of Communist Party committees, which are usually staples of state-owned enterprises.”83
The Bidens’ introduction to CEFC began while Joe Biden was Vice President, in late
2015, when Vuk Jeremic—a Serbian politician and recipient of millions of dollars from CEFC
79
Justin McCormack, Biden at Last Presidential Debate: ‘My son Has not Made Money’ from China,’ Nat’l Review
(Dec. 10, 2020) (emphasis added).
80
Ji Tianqin & Han Wei, In Depth: Investigation Casts Shadow on Rosneft’s China Investor CEFC, Caixin Global
(March 1, 2018).
81
(March 1, 2018).
82
See, e.g., “The Belt, The Road And The Money,” Transcript, NPR (Apr. 20, 2018).
83
(March 1, 2018).
14
related entities84—invited Hunter Biden to attend a “private dinner” with Chairman Ye.85
Principals of CEFC who engaged in business with the Bidens were the subjects of corruption
arrests and prosecutions. According to the U.S. Department of Justice (DOJ or Department),
Chairman Ye used CEFC to bribe and corruptly influence foreign officials. One of Chairman
Ye’s agents in the United States and abroad—Patrick Ho—was convicted of international bribery
and money laundering offenses because of his work for CEFC in Africa.86 DOJ referenced part
of Chairman Ye’s role in that bribery scheme in a press release:
HO also advised his boss, Ye Jianming, the then-chairman of CEFC China, to

provide $500,000 in cash to [President of Uganda Yoweri] Museveni, ostensibly as
a campaign donation, even though Museveni, had already been reelected. HO
intended these payments to influence [Uganda Minister of Foreign Affairs Sam]
Kutesa and Museveni to use their official power to steer business advantages to
CEFC China.87
On March 1, 2017, State Energy HK Limited, a company affiliated with Chairman Ye,
sent a wire to Robinson Walker, LLC for $3 million.88 John “Rob” Walker was a longtime Biden
business associate who formed Robinson Walker, LLC in Delaware.89 The day after receiving
the $3 million wire from China, Robinson Walker, LLC sent a wire to EEIG, a company
associated with James Gilliar, in Abu Dhabi for $1.065 million.90 Over the next approximately
three months, Robinson Walker, LLC sent 16 incremental payments totaling $1,065,692 to
various Biden family members and their corporate accounts: Hunter Biden, Hunter Biden’s
professional corporation, Owasco, P.C., one of James Biden’s companies (JBBSR Inc.), Hallie
Biden, and an unknown Biden account.91 The Committee can identify no legitimate services
rendered by these individuals or legitimate reason for payments being made in this manner.
After the Oversight Committee revealed the payments from China, President Biden
continued making false statements. On March 18, 2023, in response to a reporter’s question
84
Family’s Influence Peddling and Business Schemes, at 19 and 29.
85
Email from Vuk Jeremic to Eric Schwerin, Dec. 1, 2015 (11:14 A.M.).
86
U.S. Dep’t of Justice, Patrick Ho, Former Head of Organization Backed by Chinese Energy Conglomerate,
Sentenced to 3 Years in Prison for International Bribery and Money Laundering Offenses, U.S. Attorney’s Offices
(Southern District of New York), Mar. 25, 2019.
87
Id.
88
89
See 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.
90
91
15
regarding the over $1 million paid to the Biden family from this Chinese company, President
Biden claimed, “That’s not true.”92
However, President Biden not only knew of his family’s business practices in China;
evidence indicates he participated in them. On December 8, 2020, the FBI and IRS conducted a
recorded interview of Rob Walker. A transcript of that interview confirmed that Joe Biden met
with individuals from CEFC:
FBI Agent: Okay. Did um .., did the V.P. ever show up at any CEFC
meeting or anything like that.., even once he was out of
office?
Walker: Yes.
FBI Agent: Okay.
Walker: It was out-of-office. Ah, we were in ah.., D.C. at the Four

Seasons…
IRS Agent: Hmph hmph.
Walker: …and ah.., we were having lunch and he.., he stopped in…
IRS Agent: Hmph hmph.
Walker: …then he’d ah, leave.
FBI Agent: Okay.
Walker: That was it.
FBI Agent: Just said hello to everybody and then…
Walker: Yes.
FBI Agent: …took off?
Walker: He literally sat down. I don’t even think he drank water. I

think Hunter said um.., I may be tryin’ to start a company,
ah, or tried to do something with these guys and could you..,
and think he was like “if I’m around” …. and he’d show up.
FBI Agent: Okay. So I mean you definitely got the feeling that, that was
orchestrated by Hunter to.., to have like a.., an appearance
by his Dad at that meeting just to kind of..,
92
Chris Pandolfo, Biden denies $1M in payments to family from Hunter associate, despite bank records: ‘Not true’,
Fox News (Mar. 18, 2023).
16
Walker: Hmph hmph.
FBI Agent: …bolster your chances at…
Walker: Hmph hmph.
FBI Agent: …makin’ a deal work out.
Walker: Sure.
FBI Agent: Okay. Um.., any other… So that was the…, ah.., Four
Seasons in D.C. after he was out of office?
Walker: Yeah.
FBI Agent: Um, where… Any times when he was in office or did you
hear Hunter say that he was settin’ up a meeting with his dad
with them while dad was still in office?
Walker: Yeah.93
The President’s statement that the Oversight Committee’s bank records were “not true” is
false and even more egregious, given evidence that he stood to profit directly from the
arrangement. Originally—in early 2017—the deal with CEFC included other associates of
Hunter Biden and James Biden, namely: Rob Walker, Tony Bobulinski, and James Gilliar.
Bobulinski has spoken publicly about meeting with Joe Biden in 2017 about the CEFC deal.94
On May 13, 2017, Gilliar wrote in an email to Bobulinski (copying Rob Walker and Hunter
Biden): “At the moment there s [sic] a provisional agreement that the equity will be distributed
as follows[:] 20 H[;] 20 RW[;] 20JG[;] 20 TB[;] 10 Jim[;] 10 held by H for the big guy?”95 A
week after Gilliar’s email, Gilliar wrote Bobulinski, “Don’t mention Joe being involved, it’s only
when u are face to face, I know u know that but they are paranoid[.]”96
The original equity structure for the joint venture with CEFC was changed to remove
Gilliar, Walker, and Bobulinski, with only Hunter Biden and James Biden remaining of the
original group.97 Joe Biden’s participation in the venture appears to have continued. In one
WhatsApp message dated July 30, 2017, Hunter Biden wrote to a CEFC business associate, “I
am sitting here with my father and we would like to understand why the commitment made has
not been fulfilled.”98 He continued:
93
Transcript of recorded interview with Rob Walker, Dec. 8, 2020, at 81-82.
94
See, e.g., Brian Flood, Tony Bobulinski tells Tucker Carlson Joe Biden was ‘chairman’ of Hunter Biden’s overseas
business dealings, Fox News (Oct. 4, 2022). https://www.foxnews.com/media/tony-bobulinski-tucker-carlson-joe-
biden-chairman-hunter-biden-overseas-business-dealings.
95
Email from James Gilliar to Tony Bobulinski, May 13, 2017 (6:48 A.M.), copying Rob Walker and Hunter Biden.
96
Message from James Gilliar to Tony Bobulinski, May 20, 2017.
97
Transcript of recorded interview with Rob Walker, Dec. 8, 2020, at 83.
98
WhatsApp message, dated July 30, 2017, between Hunter Biden and Associate, provided in testimony provided by
Mr. Gary Shapley to the H. Comm. on Ways & Means (May 26, 2023).
17
Tell the director that I would like to resolve this now before it gets out of
hand. And now means tonight…. [I]f I get a call or text from anyone
involved in this other than you, Zhang, or the Chairman I will make certain
that between the man sitting next to me and every person he knows and my
ability to forever hold a grudge that you will regret not following my
direction.99
After the CEFC associate responded, Hunter Biden said again: “I am sitting here waiting
for the call with my father. I sure hope whatever it is you are doing is very very very
important.”100 The next day, the CEFC associate sent a message stating, “CEFC is willing to
cooperate with the family.”101 Then, on August 3, 2017, Hunter Biden wrote “The Biden’s [sic]
are the best I know at doing exactly what the Chairman wants from this partnershipn [sic].”102
Bank records obtained by the Oversight Committee establish that on August 4, 2017—the
day after Hunter Biden’s WhatsApp message above—CEFC Infrastructure Investment (US)
(CEFC Infrastructure) wired $100,000 to Hunter Biden’s professional corporation, Owasco, P.C.
The Committee was able to trace this money to a Chinese company and Chinese national,
Gongwen “Kevin” Dong.103
On August 2, 2017, CEFC (through Hudson West V) and Hunter Biden (through Owasco,
P.C.) established another company, Hudson West III, LLC.104 Dong and Biden were each 50
percent owners of Hudson West III.105 Bank records show between August 2017 and October
2018, Hudson West III sent over $4 million to Hunter Biden-related companies and over $75,000
to a James Biden company, Lion Hall Group, LLC.106
The next month, on September 21, 2017, Hunter Biden wrote an email to the general
manager of the House of Sweden, a building in Washington, D.C., in which he requested “keys
[be] made available for new office mates: Joe Biden Jill Biden Jim Biden Gongwen Dong
(Chairman Ye CEFC emissary)[.]”107 Hunter Biden also requested “the office sign ton [sic]
99
Id.
100
Id.
101
WhatsApp message, dated July 31, 2017, between Hunter Biden and Associate, provided in testimony provided
by Mr. Gary Shapley to the H. Comm. on Ways & Means (May 26, 2023).
102
WhatsApp message, dated August 3, 2017, between Hunter Biden and Associate, provided in testimony provided
by Mr. Gary Shapley to the H. Comm. on Ways & Means (May 26, 2023).
103
104
Amended and Restated Limited Liability Company Agreement of Hudson West III, LLC between Hudson West
V, LLC and Owasco, P.C. (Aug. 2, 2017). Executed by Dong Gongwen, President, and R. Hunter Biden, Co-
Chairman (See Schedule I, showing Hudson West V, LLC as 50 percent equity holder and Owasco, P.C. as 50
percent equity holder), available at
https://www.grassley.senate.gov/imo/media/doc/2.%20Hudson%20West%20III%20LLC%20Agreement.pdf.
105
Id.
106
Letter from Hon. Charles E. Grassley, Ranking Member, S. Comm. on the Judiciary, and Hon. Ron Johnson,
Ranking Member, Perm. Subcomm. On Investigations to Hon. David Weiss, U.S. Att’y (D. Del.), U.S. Dep’t of
Justice (Oct. 26, 2022), available at
https://www.grassley.senate.gov/imo/media/doc/grassley_johnson_to_us_attorney_weiss_-
_hunter_biden_investigation.pdf.
107
E-mail from Hunter Biden to House of Sweden management (Sep. 21, 2017) (parenthetical in original).
18
reflect the following[:] The Biden Foundation Hudson West (CEFC US)[.]”108 Hunter Biden
then provided the personal phone number of Joe Biden, to whom Hunter Biden refers as his
“partner” along with Dong and Jim Biden.109 The management was told to call Joe Biden if they
chose.110 In 2018, Chairman Ye was detained by Chinese authorities, and it was initially reported
by Chinese media that his “detention in China was ordered directly by the Chinese president, Xi
Jinping.”111
All of the evidence reviewed above indicates that CEFC officials may have targeted
certain Biden family members for their connections to Joe Biden. The Biden family profited
from these lucrative financial arrangements, and this raises questions about whether this money,
and/or concerns that Chinese sources may release additional evidence about these business
relationships with the Biden family, have had any impact on official acts performed by President
Biden or United States foreign policy.
Additional information about CEFC payments can be found in the First Bank Records
Memorandum and the Second Bank Records Memorandum released by the Oversight
Committee.
(ii) BHR Partners and Jonathan Li
As outlined below, President Biden became familiar with another of Hunter Biden’s
business associates in China, Jonathan Li, while he was Vice President. Jonathan Li was
affiliated with a Chinese government-linked private-equity fund, Bohai Capital.112 On December
16, 2013, Bohai Harvest RST (Shanghai) Equity Investment Fund Management Co., Ltd. (BHR
Partners) was formed, a venture between Rosemont Seneca Thornton, a Biden-affiliated
business, and Chinese entities.113
On July 31, 2023, the Oversight Committee conducted a transcribed interview of Devon
Archer, who discussed Vice President Biden’s interactions with Jonathan Li.114 In December
2013, then-Vice President Biden and Hunter Biden traveled on Air Force Two to China.115
Devon Archer stated Vice President Biden had coffee with Jonathan Li in Beijing:
108
Id. (parenthetical in original).
109
Id.
110
Id.
111
Eric Ng & Xie Yu, China detains CEFC’s founder Ye Jianming, wiping out US $153 million in value of stocks, S.
China Morning Post, Mar. 1, 2018, available at
https://web.archive.org/web/20180301105430/https://www.scmp.com/business/companies/article/2135238/china-
detain-cefc-founder-ye-jianming-stocks (accessed Apr. 27, 2023).
112
Adam Entous, Will Hunter Biden Jeopardize His Father’s Campaign? Joe Biden’s son is under scrutiny for his
business dealings and tumultuous personal life, The New Yorker (July 1, 2019); Report (September 23, 2020), S.
Comm. on Homeland Security and Governmental Affairs and U.S. Senate Committee on Finance From Maj. Comm.
staff to Comm. Members. Re: Hunter Biden, Burisma, and Corruption: The Impact on U.S. Government Policy and
Related Concerns, at 3.
113
National Enterprise Credit Information Publicity System Records for Bohai Huamei (Shanghai) Equity
Investment Fund Management Co., Ltd.
114
Transcribed interview of Devon Archer, H. Comm. on Oversight & Accountability (July 31, 2023).
115
The Vice President’s 2013 Asia Trip – Japan, China and the Republic of Korea, The White House, available at
https://obamawhitehouse.archives.gov/issues/foreign-policy/asia-trip-2013.
19
Q: Jonathan Li –
A: Yes.
Q: – that call, was that an inbound call, an outbound call? To the extent
you remember.
A: Yeah, to the extent I remember, that – I don’t know, but I know there
was a “hello.” There was, like – you know, they ended up having
coffee, I think, so he might’ve known him.
Q: Jonathan –
A: Jonathan Li and President Biden had coffee. So it might’ve been,

like, after they had coffee, and he was saying hello, so there was,
like, some familiarity.
Q: Where was that, that they had coffee?
A: They had coffee in Beijing.116
Devon Archer also stated that Vice President Biden wrote a college admission letter for
Jonathan Li’s daughter.117 The Oversight Committee has also identified an email indicating Joe
Biden, after his vice presidency, wrote a recommendation letter for Jonathan Li’s son to attend
Brown University.118 Vice President Biden knew Jonathan Li, met with him, had at least one
phone call with him, and wrote college recommendation letters for his children.
Additional information about BHR Partners and Jonathan Li will be released in a future
Oversight Committee Bank Records Memorandum.
116
Id. at 124.
117
Id. at 125-126.
118
Email from Jonathan Li to Eric Schwerin copying Hunter Biden, James Bulger, and Devon Archer dated Feb. 20,
2017.
20
E. Obstruction of Investigation of President Biden’s Son, Including Biden Family
Business Dealings, by His Own Administration
(i) Testimony of IRS Whistleblowers
Two whistleblowers from the IRS came forward to the Ways and Means Committee to
provide protected disclosures about a sensitive, high-profile matter. That high-profile matter is
an investigation into whether Hunter Biden committed tax-related crimes and other federal
offenses. The investigation, which looked into Hunter Biden’s financial dealings, implicated
transactions that involved foreign entities like Burisma, among others, and Hunter Biden. In
addition to providing information relevant to the Oversight Committee’s investigation, the IRS
whistleblowers raised grave concerns that certain people within DOJ, and potentially within the
IRS, have sought to hinder, obstruct, and sabotage the investigation by David Weiss, U.S.
Attorney for the District of Delaware, of the President’s son, Hunter Biden, an investigation that
could implicate Joe Biden in his son’s foreign business dealings. The whistleblowers also
alleged that DOJ and IRS officials have retaliated against the whistleblowers for raising these
concerns to Congress. The actions by DOJ and the IRS raise concerns about whether the Biden
Administration has obstructed justice and Joe Biden’s knowledge of, influence over, and/or
involvement with such obstruction.
Supervisory Special Agent Gary Shapley provided this information in a transcribed

interview (Shapley Interview) to the Ways and Means Committee on May 26, 2023.119 On June
1, 2023, an additional IRS whistleblower—the primary IRS criminal investigator on the Hunter
Biden investigation, Mr. Joseph Ziegler—provided additional disclosures to the Ways and Means
Committee in a separate transcribed interview (Ziegler Interview).120 The whistleblowers made
allegations of a wide range of problems with DOJ’s handling of this case. Just one of those
issues includes allegations that whenever investigators sought to take an investigative step that
might relate to, involve, or implicate Joe Biden, they were curtailed or prevented from taking that
step. The whistleblowers provided numerous examples of the roadblocks they faced throughout
the investigation. For instance, Mr. Shapley testified that in a May 3, 2021, memo he wrote:
“Through interviews and review of evidence obtained, it appears there may be campaign finance
criminal violations. AUSA Wolf stated on the last prosecution team meeting that she did not want
any of the agents to look into the allegation.”121
Further, IRS investigators wanted to interview Hunter Biden’s adult children about
payments that Hunter Biden purportedly made to them or for their benefit (e.g., clothes, tuition,
etc.), which he had deducted from his taxes.122 However, on October 21, 2021, AUSA Wolf told
investigators that they would be in “hot water” if they interviewed Hunter Biden’s adult
children.123 One of the whistleblowers, Special Agent Joseph Ziegler, described this restriction
as “completely abnormal” because it is “part of [the] normal process” to interview people who
are receiving money from the case subject.124 Despite investigators discovering evidence that
119
See Transcribed interview of Gary Shapley, Internal Revenue Service (May 26, 2023).
120
See Transcribed interview of Joseph Ziegler, Internal Revenue Service (June 1, 2023).
121
Id. at 22.
122
Ziegler Interview at 32, 129; See Reese Gorman, Hunter Biden investigation: Agents warned against
interviewing his adult children, WASH. EXAM. (July 19, 2023).
123
Id. at 32.
124
Id. at 32.
21
Hunter Biden may have deducted from his taxes payments to family members for personal
expenses, IRS investigators were also prohibited from interviewing other Biden family members,
including Valerie Biden Owens (President Biden’s sister), James Biden (President Biden’s
brother), Sara Biden (President Biden’s sister-in-law), Hallie Biden (Beau Biden’s widow), and
Kathleen Buhle (Hunter Biden’s ex-wife).125
These whistleblowers provided extensive testimony, and Mr. Shapley provided several
documents, that corroborate his account of events. This testimony necessitated further
congressional investigation into the handling of the tax investigation of Hunter Biden by both the
IRS and DOJ. The Committee on Ways and Means has conducted interviews of two additional
IRS employees regarding the whistleblower allegations, and the three Committees have
partnered to send numerous investigative letters requesting documents from, and interviews of,
numerous Biden Administration officials.
Subsequent to the release of the two transcripts from the IRS whistleblowers, the
Oversight Committee held a hearing on July 19, 2023.126 In addition to raising serious concerns
about the Biden Administration’s handling of the investigation of President Biden’s son, the
whistleblowers’ testimony corroborated the Oversight Committee’s findings, including the Biden
family and their associates’ use of over twenty companies; their receipt of millions of dollars
from countries including Ukraine, Romania, and China; and Joe Biden’s participation in a
meeting with CEFC.127
(ii) The Biden Justice Department allowed the statute of limitations to expire on
certain alleged criminal conduct that could implicate President Biden.
The Judiciary Committee has also gathered evidence that the Biden Administration has
improperly influenced the course of the IRS and DOJ investigation into Hunter Biden by
allowing the statute of limitations to lapse on certain charges.
According to IRS whistleblower Supervisory Special Agent Gary Shapley, the

Department allowed the statute of limitations to lapse on the 2014 and 2015 tax crimes
committed by Hunter Biden. Shapley testified that, up until October 7, 2022, he believed that
prosecutors “were deciding whether to charge 2014 and 2015 tax violations” based on statements
made by Attorney General Merrick Garland and Weiss.128 During this time period, prosecutors
and Hunter Biden’s counsel entered into agreements to toll the statute of limitations for crimes
pertaining to the 2014 and 2015 tax years.129
On October 7, 2022, Weiss, in a meeting with senior managers, indicated that he was
ultimately “not the deciding official on whether charges are filed.”130 Shapley later learned that
the U.S. Attorney for the District of Columbia, Matthew Graves, an appointee of President
125
Id. at 53, 144.
126
Hearing with IRS Whistleblowers About the Biden Criminal Investigation, H. Comm. on Oversight and
Accountability (July 19, 2023).
127
Hearing Wrap Up: IRS Whistleblowers Expose How Bidens Were Treated Differently, H. Comm. on Oversight
and Accountability (July 19, 2023).
128
Shapley Interview at 25.
129
Id. at 54.
130
Id. at 28.
22
Biden, “would not allow [Weiss] to charge in his district.”131 As a result, Weiss went to Main
Justice to request special counsel authority in the District of Columbia, which Main Justice
denied.132 Weiss was instead told to “follow DOJ’s process.”133
In November 2022, despite defense counsel’s willingness to again toll the statute of
limitations again, the Department allowed the statute of limitations to lapse on the 2014 and 2015
charges.134 As a result, no charges were ever brought.135 The expiration of the tax charges for
2014 and 2015 is significant because during those years, Hunter Biden took on a lucrative role
serving on the board of Burisma.136 Also during that period, his father, then-Vice President Joe
Biden, sought to have the Ukrainian prosecutor investigating Burisma fired.137 That prosecutor,
Viktor Shokin, “was fired after then-Vice President Joe Biden threatened to pull $1 billion in US
aid.”138 Ultimately, the “exclusion of the 2014 and 2015 years sanitized the most substantive
criminal conduct and concealed material facts” relating to Hunter Biden’s foreign income, “a
scheme to evade income taxes through a partnership with a convicted felon[,]” and “potential
FARA issues”—all of which implicates his father, Joe Biden.139 Simply put, the Biden
Administration’s DOJ appears to have intentionally slow-walked the investigation that
potentially implicated President Biden by allowing the statute of limitations to expire.140
(iii) The Biden Justice Department afforded Hunter Biden special treatment and a
lenient plea deal for which the Department could offer no comparable
precedent.
When the Department was compelled to take some prosecutorial action against Hunter
Biden, it tried to push through an apparently unprecedented plea deal, which imploded in open
court. In May 2023, around the time that the IRS whistleblowers initially testified to Congress
about irregularities in the Department’s investigation and shortly after a meeting between Hunter
Biden’s former lawyer Chris Clark, Weiss, and Associate Deputy Attorney General Bradley
Weinsheimer,141 the Department began formally negotiating with Hunter Biden’s lawyers about
potential plea and pretrial diversion agreements.142 The negotiations culminated in a plea
agreement publicly announced on June 20, 2023.143
131
Id.
132
Id. at 25.
133
134
Id. at 100.
135
Id.
136
Steven Nelson, Ukrainian prosecutor whose ouster Biden pushed was ‘threat,’ says Devon Archer, N.Y. POST
(Aug. 4, 2023).
137
Id.
138
Id.
139
140
Id. at 26.
141
See Betsy Woodruff Swan, In talks with prosecutors, Hunter Biden’s lawyers vowed to put the president on the
stand, POLITICO (Aug. 19, 2023) (reporting that Clark, Weiss, and Weinsheimer met on April 26, 2023 to discuss the
charges, but noting that it is “not clear what happened in the meeting, which came at a sensitive moment for the
probe”).
142
Defendant’s Response to the U.S. Motion to Vacate the Court’s Briefing Order, U.S. v. Robert Hunter Biden, No.
23-mj-274-MN, No. 23-cr-61-MN (D. Del. Aug. 13, 2023). See also Jessica Lynch, Hunter Biden began negotiating
plea deal with DOJ right after IRS whistleblower first came forward, court docs show, DAILY CALLER (Aug. 14,
2023).
143
Swan, supra note 141.
23
However, according to public reporting, Clark began pressuring the Department to settle
Hunter Biden’s case as early as spring of 2022.144 Specifically, Clark threatened investigators
that they faced career “suicide” if they pursued the investigation,145 asked for meetings “with
people at the highest levels of the [] Department,”146 and threatened to call President Biden to
testify as a fact witness for the defense.147 Clark even went so far as to tell prosecutors that they
would be creating a “Constitutional crisis” by pitting the President against the Department he
runs.148
The deal reached by Weiss’s team and Hunter Biden’s lawyers would have had Hunter
Biden plead guilty to two misdemeanor tax charges, plus a diversion agreement to dismiss a
separate felony gun charge if Hunter Biden complied for two years with the conditions set forth
in the agreement.149 The one-of-its-kind agreement shifted a broad immunity provision from the
plea agreement to the pretrial diversion agreement, benefiting Hunter Biden with the aim of
preventing the District Court from being able to scrutinize and reject that immunity provision.150
It also gave the District Court the sole power to determine whether Hunter Biden breached the
pretrial diversion agreement—a prerequisite for the Department to file the diverted charges
against him in the future and a provision benefitting Hunter Biden.151
On July 26, 2023, Hunter Biden appeared before Judge Maryellen Noreika of the U.S.
District Court for the District of Delaware for a hearing on the plea deal.152 The plea deal fell
apart when prosecutors and defense attorneys could not provide answers to routine questions
about the agreement posed by Judge Noreika.153 Judge Noreika described the Department’s deal
as “not standard” and “different from what I normally see.”154 Judge Noreika raised concerns
about two provisions of the deal: (1) a provision of the pretrial diversion agreement for the gun
charge that would prohibit the Department from bringing charges within the scope of the
agreement unless and until Judge Noreika first determined that the diversion agreement had been
breached,155 and (2) a grant of immunity within the pretrial diversion agreement that would
immunize Hunter Biden for not only the gun-related conduct, but also his unrelated tax crimes.156
144
Id.
145
See Shapley Interview at 27 (stating that Clark told prosecutors that they would be committing “career suicide” if
they filed criminal charges against Hunter Biden); Ziegler Interview at 122.
146
147
Id.
148
Id.
149
Josh Gerstein et al., Hunter Biden reaches plea deal with feds to resolve tax issues, gun charge, POLITICO (June
20, 2023).
150
See Letter from Chairmen Jim Jordan, Jason Smith, and James Comer, to Merrick B. Garland, Att’y Gen., U.S.
Dep’t of Just. (July 31, 2023). See also Transcript of Record at 46-47, 107, U.S. v. Robert Hunter Biden, No. 23-mj-
274-MN, No. 23-cr-61-MN (D. Del. July 26, 2023).
151
Transcript of Record at 95, U.S. v. Robert Hunter Biden, No. 23-mj-274-MN, No. 23-cr-61-MN (D. Del. July, 26,
2023).
152
See Michael S. Schmidt et al., Inside the Collapse of Hunter Biden’s Plea Deal, N.Y. TIMES (Aug. 19, 2023) ;
153
Schmidt, supra note 152; Swan, supra note 141.
154
Transcript of Record at 10, U.S. v. Robert Hunter Biden, No. 23-mj-274-MN, No. 23-cr-61-MN (D. Del. July, 26,
2023.
155
Id. at 92-93.
156
Id. at 46-47.
24
When Judge Noreika asked if there was precedent for either of these provisions, prosecutors
were unable to provide any.157
At the conclusion of the hearing, Judge Noreika expressed discomfort with the structure
of the plea and pretrial diversion agreements and the constitutionality of the provision that would
prevent prosecutors from filing future charges against Hunter Biden without judicial approval.158
Ultimately, Judge Noreika concluded that she could not accept the plea agreement and postponed
the proceedings.159 Negotiations to modify the plea agreement were abandoned before the
announcement of Weiss’s special counsel appointment.160
(iv) The Biden Justice Department made inconsistent and false statements to
Congress about the independence of its investigations into Hunter Biden.
The Department has made inconsistent statements to the Judiciary Committee about the
independence of its investigation into Hunter Biden, raising serious concerns that political
appointees of Joe Biden have obstructed the investigation.
On March 1, 2023, Attorney General Garland told the Senate Judiciary Committee that
U.S. Attorney David Weiss “has full authority . . . to bring cases in other jurisdictions if he feels
it’s necessary.”161 Then, on June 7, 2023, Weiss wrote to the Judiciary Committee, stating: “I
have been granted ultimate authority over this matter, including responsibility for deciding
where, when, and whether to file charges . . . .”162 On June 30, however, Weiss claimed in a
second letter to the Judiciary Committee that “my charging authority is geographically limited to
my home district.” He expanded:
If venue for a case lies elsewhere, common Departmental practice is to

contact the United States Attorney’s Office for the district in question and
determine whether it wants to partner on the case. If not, I may request
Special Attorney status from the Attorney General pursuant to 28 U.S.C. §
515. Here, I have been assured that, if necessary after the above process, I
would be granted § 515 Authority in the District of Columbia, the Central
District of California, or any other district where charges could be brought
in this matter.163
In transcribed interviews of two senior leaders of the FBI Baltimore Field Office,
however, the Judiciary Committee learned that Weiss had to follow a “cumbersome” and
157
Id. at 46, 103.
158
Id. 95-98.
159
Id.; see also, Transcript of Record at 54-55, U.S. v. Robert Hunter Biden, No. 23-mj-274-MN, No. 23-cr-61-MN
(D. Del. July 26, 2023).
160
U.S. Motion to Voluntarily Dismiss Criminal Tax Information Without Prejudice so that Tax Charges Can Be
Brought in a District Where Venue Lies, U.S. v. Robert Hunter Biden, No. 23-mj-274-MN, No. 23-cr-61-MN (D.
Del. Aug. 11, 2023).
161
Oversight of the Department of Justice: Hearing Before the S. Comm. on the Judiciary, 118th Cong. (2023)
(statement of Merrick Garland, Att’y Gen., U.S. Dep’t of Justice).
162
Letter from David C. Weiss, U.S. Att’y, Dist. of Del., to Rep. Jim Jordan, Chairman, H. Comm. on the Judiciary
(June 7, 2023).
163
Letter from David C. Weiss, U.S. Att’y, Dist. of Del., to Rep. Jim Jordan, Chairman, H. Comm. on the Judiciary
(June 30, 2023).
25
“bureaucratic” process to bring charges against Hunter Biden outside of Delaware.164 The
testimony from these two FBI witnesses buttresses the existing evidence that Weiss did not have
full and sole authority over the Justice Department’s Hunter Biden investigation. In addition,
Shapley testified that two U.S. Attorneys denied partnering with Weiss to bring charges against
Hunter Biden. According to Shapley, in March 2022, the Justice Department’s Tax Division
presented the case against Hunter Biden to the U.S. Attorney’s Office in the District of
Columbia.165 Although the office’s First Assistant was “optimistic” about the case and willing to
“assign an AUSA to assist[,]” U.S. Attorney Matthew Graves, appointed by President Biden,
“personally reviewed the report and did not support it.”166 Shapley testified that he learned about
Graves’s decision to not partner with Weiss in the October 7, 2022 meeting during which Weiss
indicated that Graves “would not allow him to charge in his district.”167 At that same meeting,
Weiss also stated that “he has no authority to charge in California” and if he wanted to bring
charges in California, “he would have to request special counsel authority in order to charge
it.”168 In January 2023, Shapley learned that U.S. Attorney Martin Estrada, also appointed by
President Biden, refused to partner with Weiss and “had declined to bring charges in the Central
District of California.”169
(v) President Biden has made repeated statements about Hunter Biden’s
innocence and his own purported lack of involvement in his son’s business
dealings, prejudicing the Department’s investigation.
President Biden, by himself and through his staff, has prejudiced the Department’s
investigation by making repeated public statements about Hunter Biden’s innocence. These
statements could represent attempts to use the authority of his office to influence the
Department’s actions and decision-making in the criminal investigation of his son, an
investigation which could implicate the President himself.
Since becoming president, President Biden has continued to use his office to promote his
and Hunter Biden’s innocence. On October 11, 2022, a reporter asked President Biden about
potential charges against Hunter.170 While acknowledging that Hunter Biden lied on his
application to purchase a gun, President Biden stated, “I’m confident that he is—what he says
and does are consistent with what happens.”171 President Biden then reiterated that he has “great
confidence in [his] son.”172 In May 2023, President Biden again defended his son, stating, “[M]y
164
Transcribed Interview of Thomas Sobocinski at 44, 68, 103 (Sept. 7, 2023).
165
166
Id.
167
Id. at 28.
168
Id. at 102.
169
Id. at 31. In testimony to the Judiciary Committee on September 20, 2023, Attorney General Garland stated
that Weiss had full authority over the investigation because Garland “promised” Weiss that he would have full
authority. In particular, Garland testified that Weiss “had the authority because I promised that he would have the
authority.” This statement—that Weiss had full authority because he would have full authority if he sought it—
appears to be self-contradictory and inconsistent with Garland’s prior statement in March 2023 that Weiss had full
authority at the time of the statement.
170
Kevin Liptak & Evan Perez, Biden addresses possible criminal charges against Hunter Biden and says he’s
‘proud’ of son’s fight against drug addiction, CNN (Oct. 12, 2022).
171
Id.
172
Id.
26
son has done nothing wrong.”173 He added, “I trust him. I have faith in him.”174
In August 2023, a reporter brought up testimony that President Biden was “on
speakerphone” with Hunter Biden’s former business associates “talking business,” potentially
implicating President Biden in these crimes.175 President Biden shot back, “I never talked
business with anybody. I knew you’d have a lousy question.”176 When the reporter asked
President Biden to explain why the question was lousy, he responded, “Because it’s not true.”177
Senior employees of the Executive Office of the President have also publicly commented
on Hunter Biden’s innocence and President Biden’s purported lack of involvement in his son’s
foreign business dealings. For example, former White House Chief of Staff Ron Klain stated,
“Of course the president is confident that his son didn’t break the law” and that President Biden
“is confident that his family did the right thing.”178 Klain added, “[t]hese are actions by Hunter
and his brother. They’re private matters. They don’t involve the president. And they certainly
are something that no one at the White House is involved in.”179 On April 5, 2022, then-White
House Press Secretary Jen Psaki agreed with a reporter’s question that the President has “never
spoke[n] to his son about his overseas business dealings.”180 On July 24, 2023, in an exchange
with a reporter, White House Press Secretary Karine Jean-Pierre stated that President Biden “was
never in business with his son.”181 Two days later, Jean-Pierre again reiterated at a press
briefing, that “nothing has changed,” again denying that President Biden had any involvement
with his son’s foreign business dealings.182 Yet these statements seem flatly inconsistent with
evidence that the Committee has gathered thus far.
IV. Scope of Impeachment Inquiry
The Committees’ inquiry into possible impeachable offenses committed by President

Biden requires pursuing investigative leads generated by the Committees in the course of their
oversight work to date. In addition to the thousands of documents the Committees have already
reviewed and many interviews that the Committees have already conducted, the Committees will
obtain additional evidence. Because the impeachment inquiry will go where that evidence leads,
the investigation could head in directions that the Committees do not currently foresee.
However, given the evidence gathered to date, the impeachment inquiry will initially focus on
the following questions.
First, did Joe Biden, as Vice President and/or President, take any official action or
effect any change in government policy because of money or other things of value provided to
173
Katherine Doyle, Biden defends son Hunter ahead of possible federal tax, gun charges, NBC News (May 5,
2023).
174
Id.
175
Alexander Hall, Biden scorched for response to question about talking to Hunter’s business associates:
‘Pathological liar’, FOX NEWS (Aug. 10, 2023)
176
Id.
177
Id.
178
Id.
179
Id.
180
Press Briefing by Press Secretary Jen Psaki, April 5, 2022, THE WHITE HOUSE (April 5, 2022).
181
Press Briefing by Press Secretary Karine Jean-Pierre, THE WHITE HOUSE (July 24, 2023).
182
Press Briefing by Press Secretary Karine Jean-Pierre and National Security Council Coordinator for Strategic
Communications John Kirby, THE WHITE HOUSE (July 26, 2023).
27
his family or him from foreign interests? The Committees have uncovered that payments: (1)
went to members of Joe Biden’s family, and (2) occurred or began during Joe Biden’s Vice
Presidency; and (3) originated from certain countries in which then-Vice President Biden played
an official role on behalf of the Obama-Biden Administration. Moreover, this money reached the
Biden family through a layered and obfuscated payment structure, which usually involved
intermediaries and incremental distributions of funds.183 In certain countries, during or shortly
after then-Vice President Biden delivered speeches and messages on behalf of the Obama-Biden
Administration about fighting corruption (e.g., Romania, Ukraine), his son engaged in business
deals with individuals (e.g., Gabriel Popoviciu, Mykola Zlochevsky) who were under
investigation for corruption by those countries.184 The Committees will investigate whether the
foreign money paid to the Biden family had any impact on Joe Biden’s conduct as President or
Vice President, including the bribery allegations set forth in the FBI FD-1023 form. The
Committees will also investigate whether any of this foreign money reached Joe Biden directly
or was used to directly benefit him, such as by paying his bills.
Second, did Joe Biden, as Vice President and/or President, abuse his office of public
trust by providing foreign interests with access to him and his office in exchange for payments
to his family or him? During his Vice Presidency, Joe Biden spoke, met, and socialized with his
son’s foreign business associates. On at least two occasions—2014 and 2015—Joe Biden
attended small, private dinners in Washington, D.C. with foreign individuals who had paid or
would pay his son millions of dollars.185 In 2014, one of the individuals who attended the dinner
was Yelena Baturina—a Russian oligarch and the wealthiest woman in Russia—who around the
timeframe of the dinner wired $3.5 million to Rosemont Seneca Thornton.186 In 2015, one of the
individuals who attended the dinner with the Vice President—Vadym Pozharsky—was an
executive of Burisma, the Ukrainian company that paid Hunter Biden $1 million per year and
whose president—Mykola Zlochevsky—was under investigation for corruption. In the spring of
2015, Hunter Biden and his business associates attended a breakfast at the Naval Observatory,
where the discussion focused on who would be the next Secretary General of the United Nations;
one of the participants was a lobbyist for a Kazakhstani individual who was seeking the
position.187 The Committees will investigate whether these foreign interests were given access to
Joe Biden as a result of payments made to his family or him.
Third, did Joe Biden, as Vice President and/or President, abuse his office of public
trust by knowingly participating in a scheme to enrich himself or his family by giving foreign
interests the impression that they would receive access to him and his office in exchange for
payments to his family or him? As reviewed above, Joe Biden called into business meetings
183
See, Memorandum (May 10, 2023), H. Comm. on Oversight & Accountability. From Maj. Comm. staff to Comm.
Family’s Influence Peddling and Business Schemes; see also, Memorandum (August 9, 2023), H. Comm. on
Oversight & Accountability. From Maj. Comm. staff to Comm. Members. Re: Third Bank Records Memorandum
from the Oversight Committee’s Investigation into the Biden Family’s Influence Peddling and Business Schemes.
184
Id.
185
See, Memorandum (August 9, 2023), H. Comm. on Oversight & Accountability. From Maj. Comm. staff to
Comm. Members. Re: Third Bank Records Memorandum from the Oversight Committee’s Investigation into the
Biden Family’s Influence Peddling and Business Schemes.
186
Family’s Influence Peddling and Business Schemes.
187
28
held by his son and spoke to the attendees on speakerphone. He also attended dinners with
Hunter Biden and his son’s foreign business associates. The evidence suggests that Joe Biden
knew or must have known that these interactions would give his son’s foreign business associates
the appearance that they would have access to him and his office if they were to make substantial
payments to his son. And if this is true, then Joe Biden was using his office to enrich his family,
even if he ended up not providing his son’s foreign business associates with such access. The
Committees will therefore investigate whether Joe Biden engaged in a scheme with his son to
secure foreign money by giving foreign business interests the impression that they would be
provided with access to Biden and his office if they made payments to his son.
Fourth, did Joe Biden abuse his power as President to impede, obstruct, or otherwise
hinder investigations (including Congressional investigations)188 or the prosecution of Hunter
Biden? To answer this question, the Committees will need to obtain information regarding the
federal criminal investigation of Hunter Biden, such as the failure by the Department of Justice
to bring felony tax charges against Hunter Biden for tax years 2014 and 2015, despite IRS
investigators’ disclosures to Congress that the U.S. Attorney’s Office in Delaware had ample
evidence to support those charges. The Committees will also need to procure information
regarding possible retaliation against those investigators. The inquiry will also review the
understanding that was eventually struck by Hunter Biden’s legal team and federal prosecutors
(including the plea agreement and pretrial diversion agreement)189 after the IRS whistleblowers’
disclosures to Congress and before that understanding being questioned by a federal judge.190
And it will review whether any political appointees of Joe Biden obstructed the criminal
investigation of Hunter Biden and whether Joe Biden or anyone at the White House had any
involvement in that obstruction directly or indirectly, such as through the issuance of public
statements.
* * *
Necessarily, the impeachment inquiry will span the time of Joe Biden’s Vice Presidency
to the present, including his time out of office. The impeachment inquiry will focus on whether
the President has engaged in corruption, bribery, and influence peddling during his time as Vice
President and President. The impeachment inquiry will simultaneously investigate whether
actions have been taken by the Biden Administration to obstruct or hinder accountability for the
same potential corruption, bribery, and influence peddling. Due to the existing evidence of self-
dealing and personal and familial enrichment by Joe Biden through the abuse of his official roles,
the impeachment inquiry will require access to records of not only President Biden but the
188
For example, the Oversight Committee has requested information regarding the classified materials discovered in
the President’s home—where his son has resided during the time period relevant to this investigation—and personal
office, but the White House has provided no information to the Committee regarding the contents of or its full
approach towards those documents. The refusal to cooperate is despite growing evidence accumulated by the
Oversight Committee that the White House has not been forthcoming regarding the classified materials discovered
in 2022 and that such actions represent potentially a serious violation of federal law for which a former president has
faced federal indictment. See Letter from Hon. James Comer, Chairman, H. Comm. on Oversight & Accountability
to Stuart Delery, White House Counsel (Jan. 10, 2023); see also Letter from Hon. James Comer, Chairman, H.
Comm. on Oversight & Accountability to Ron Klain, White House Chief of Staff (Jan. 15, 2023).
189
Betsy Woodruff Swan, Read the proposed Hunter Biden plea agreement, POLITICO (July 26, 2023),
https://www.politico.com/news/2023/07/26/proposed-hunter-biden-plea-agreement-00108426.
190
Betsy Woodruff Swan, Read the proposed Hunter Biden plea agreement, POLITICO (July 26, 2023),
https://www.politico.com/news/2023/07/26/proposed-hunter-biden-plea-agreement-00108426.
29
people and entities in his proximity throughout the relevant time period, including those of his
family members and Obama-Biden and Biden-Harris Administration officials.
Because of the nature of the Biden family’s business practices, the Committees anticipate
the impeachment inquiry will require access to a variety of sources of information. In addition to
bank records and other financial documents the Committees will obtain through subpoena, if
necessary, the Committees anticipate the impeachment inquiry will require the production of
documents by the United States Departments of State, Justice, Treasury, and Homeland Security,
the National Archives, and other government agencies, as well as certain documents from state
governments and international sources. The Committee will also conduct depositions or
transcribed interviews of people with firsthand knowledge of the Biden family’s business
practices and finances, in addition to former and current Administration officials. When
possible, the Committees will request that this information be provided voluntarily, but the
Committees anticipate—based on statements made to the Committees during their regular
oversight work—that certain individuals will require subpoenas to appear or cooperate with the
Committees’ impeachment inquiry in a timely manner. The Committees will use all of the tools
at their disposal to conduct a thorough and needed investigation and fulfill the constitutional
responsibility of determining whether articles of impeachment against President Biden should be
drafted and referred to the full House.
30

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MEMORANDUM

TO: Members of the Committee on Oversight and Accountability, Committee on

DATE: September 27, 2023

RE: Impeachment Inquiry

The Committees have also uncovered substantial information, including through

As a result of the information assembled by the Committees, on September 12, 2023,

II. Purpose of Impeachment Inquiry

III. Basis of Impeachment Inquiry and Information Obtained to Date

A. Summary of the Oversight Committee’s Financial Investigation

(i) Influence Peddling in Ukraine and Payments from Burisma

(ii) Financial Records and Testimony Regarding Burisma Payments

In addition to this sudden change in the Obama-Biden Administration’s strategy

Q: And that brand is what, in your opinion, was the majority of

A: I didn’t say majority, but I wouldn’t speculate on

You aren’t talking about Dr. Jill or anybody else. You’re

A: Yeah, that’s fair to say. Listen, I think it’s – I don’t think

(iv) Payment from Russia

C. Biden Influence Peddling in Romania

(i) CEFC China Energy and Related Chinese Companies

HO also advised his boss, Ye Jianming, the then-chairman of CEFC China, to

FBI Agent: Okay.

Walker: It was out-of-office. Ah, we were in ah.., D.C. at the Four

IRS Agent: Hmph hmph.

IRS Agent: Hmph hmph.

Walker: …then he’d ah, leave.

FBI Agent: Okay.

Walker: That was it.

FBI Agent: Just said hello to everybody and then…

FBI Agent: …took off?

Walker: He literally sat down. I don’t even think he drank water. I

FBI Agent: …bolster your chances at…

Walker: Hmph hmph.

FBI Agent: …makin’ a deal work out.

(ii) BHR Partners and Jonathan Li

A: Jonathan Li and President Biden had coffee. So it might’ve been,

Q: Where was that, that they had coffee?

A: They had coffee in Beijing.116

(i) Testimony of IRS Whistleblowers

Supervisory Special Agent Gary Shapley provided this information in a transcribed

According to IRS whistleblower Supervisory Special Agent Gary Shapley, the

If venue for a case lies elsewhere, common Departmental practice is to

IV. Scope of Impeachment Inquiry

The Committees’ inquiry into possible impeachable offenses committed by President

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