Bribery Dressed as Policy?

Part two, the geometry

Credit: Boris Bobrov

(You can find part one here)

To recap for those just joining us: Part one of this story established the policy context for the Caesar Act repeal, which was the correct argument made by serious people who wanted Iran and Russia kept out of post-Assad Syria. We were on record calling for it in 2024. It was the right call then and is the right call now. The problem was legislators not brave enough to take on the corruption of America’s new ruling class. The people arguing for lifting sanctions on Syria made the right call for the right reason.

Part one also established that the people who benefited most from the repeal had done almost no registered lobbying to undo it. Lobbying and registering for FARA was Earth 1.0. There’s a new game in town.

Senate Finance Committee correspondence, Albanian and Qatari corporate filings, OFAC releases, the parties’ statements and New York Times reporting give us the contours of three financial vehicles centered on the President’s indefatigable son-in-law:

• Affinity Partners, the private equity firm Jared Kushner founded in July 2021, six months after leaving the White House (the first time). The firm reported to Senator Ron Wyden’s Senate Finance Committee that 99% of its capital comes from foreign sources, primarily the sovereign wealth funds of Saudi Arabia, the United Arab Emirates and Qatar. The Saudi Public Investment Fund’s $2 billion commitment was approved despite the documented objections of the fund’s own screening panel, which had found Kushner’s operations unsatisfactory in all respects. Crown Prince Mohammed bin Salman (MBS) overruled the panel.

  According to Wyden, Affinity has collected approximately $157 million in management fees from foreign clients through 2024, including roughly $87 million from the Saudi government directly, and has returned zero investment profits to its clients during that period. But it has returned some pretty striking policy wins in Washington, if that was indeed the purpose of the fund, as Wyden alleges. Wyden’s letter to the firm’s chief legal officer in September 2024 also documented an unidentified sixth foreign beneficial owner of the parallel fund whose identity Affinity has declined to disclose. The investment agreements expire in August 2026 — in the middle of Trump’s second term — at which point the foreign sovereign investors can renegotiate or withdraw.

  The structural feature here matters more than any individual fee number. A foreign government cannot make a campaign contribution to a US presidential candidate. A foreign government can make a five-year limited-partnership commitment to a private equity fund owned by that candidate’s son-in-law, pay management fees on the full principal regardless of whether the capital is ever deployed, and renegotiate the terms in the middle of a presidential term. Wyden’s June 2024 letter directly called out this FARA loophole.

• Sazan Island resort: Sazan is the largest island in Albanian waters, a 562-hectare former communist-era naval base in the Otranto Strait. Atlantic Incubation Partners LLC — a Delaware-registered Kushner vehicle — was granted strategic-investor status by Albania’s Strategic Investments Committee in December 2024, three weeks before Trump’s second inauguration. The $1.4 billion project covers 45 hectares of the island.

  What the December 2024 grant did not disclose is who the beneficial owners actually were. The Albanian implementing company, Sazan Operations sh.p.k., was registered on April 1, 2026, and the Albanian press review of corporate filings shows 100%ultimate ownership tracing through a six-company offshore cascade to Ramez and Mohamad al-Khayyat in Doha. To get there, you must navigate a maze through a Netherlands-based holding company called Blue Industries Investment Holding B.V., which itself holds a 24% block among five undisclosed Albanian shareholders, a stake deliberately structured below the 25% threshold for disclosure of the ultimate beneficial owner under EU and Albanian transparency law. All of this is nested in a 6-layer ownership structure that is entirely legal, if sketchy.

  Ramez al-Khayyat told the New York Times directly that the Khayyat-Kushner relationship is a joint venture between the two companies, and that they are managing it together. The Affinity brand, which the Albanian government cited in its press releases, never appears as a contracting party in the Albanian filings. On December 30, 2025 — exactly one year after the original strategic-investor grant — the Strategic Investments Committee adopted a second decision shifting the cost of demining Sazan from the investor to the Albanian Ministry of Defence. Ivanka Trump visited Vlorë in late January 2026 to tour the island, meet the architects and visit with Prime Minister Edi Rama. Notably, Albania is Europe’s fastest-growing tourism destination and a frontrunner for EU membership.

• The Syrian portfolio: UCC Holding, the Khayyat-family-controlled construction conglomerate, signed the final $4 billion concession to redevelop Damascus International Airport in November 2025. US Special Envoy Tom Barrack attended the signing ceremony in Damascus. The consortium includes Cengiz İnşaat and Kalyon İnşaat of Turkey, and Assets Investments USA LLC. The $7 billion Syrian power deal under the international consortium had been moving through ministerial site handovers in Mhardeh, al-Taym, Zayzoun, and al-Tarifawi since June 2025 (i.e., before sanctions ended). Estithmar Holding, also Khayyat-controlled, is acquiring a 60% stake in Syria’s Shahba Bank and approximately 30% of Syria International Islamic Bank — the first major foreign banking acquisitions in Syria since the regime change in late 2024.

  Tom Barrack represents the convergence point. He was the public face of the executive-branch case for repeal. He was simultaneously the United States official physically present at the airport signing ceremony in Damascus alongside Ramez al-Khayyat. His March 2025 ethics agreement, addressed to State’s Acting Legal Adviser Richard Visek, scoped his recusal commitments to Türkiye duties only — three weeks before he received the Syria portfolio. His Form 278e public financial disclosure includes a footnote stating that DigitalBridge, in which he retains a carried interest, is pursuing digital-asset investments in the Middle East in Abu Dhabi, Kuwait, Qatar, Saudi Arabia, and Türkiye. The post-confirmation Certification of Ethics Agreement Compliance, due roughly July 2025, has not been made public, so far as we can find, as of the publication of this article. No State Department recusal memo for the Syria, Lebanon, or Iraq portfolios has been published on State’s FOIA reading room or on state.gov.

Here’s a refresher on Barrack. He was acquitted in November 2022 of charges that he had acted as an unregistered foreign agent of the United Arab Emirates between 2016 and 2017. The federal indictment in the Eastern District of New York named senior Emirati officials referred to as Emirati Officials 1 through 5. Publications Bloomberg, Middle East Eye and emptywheel subsequently identified them as Mohammed bin Zayed Al Nahyan, Tahnoun bin Zayed Al Nahyan, Ali Mohammed Hammad al-Shamsi, Abdullah Khalifa al-Ghafli and US Ambassador Yousef Al Otaiba. None of the Emirati officials has been charged. In February 2026, regional press reported that Barrack, by then the United States envoy responsible for the portfolios of Syria, Lebanon, and Iraq, met publicly with Tahnoun bin Zayed in his capacity as UAE National Security Adviser (and not, we assume, as Donald Trump and Steve Witkoff’s largest outside investor in World Liberty Financial). The State Department published no recusal memo. Tahnoun is the same official identified in the 2021 indictment as one of the Emirati principals whose direction Barrack was alleged to have taken.

Affinity Partners is the financial mechanism that makes all of this work without requiring any party to register as a foreign agent. According to Wyden’s letter, the firm is structured as a private investment fund that is not legally subject to the same anti-money laundering and beneficial ownership reporting requirements as other financial institutions because it is excluded from the definition of investment company under the Investment Company Act of 1940. That exclusion matters and is the structural reason a foreign sovereign wealth fund can pay $87 million to the President’s son-in-law without any disclosure register in the United States Government tracking the relationship as foreign influence. House Judiciary Ranking Member Jamie Raskin’s April 2026 letter to Affinity called this a glaring and incurable conflict of interest. When Republicans took the Senate, Senator Wyden’s investigation by the Senate Finance Committee effectively stalled. The Department of Justice has not acted on the October 2024 special counsel referral.

What, exactly, did the President’s family stand to lose if Section 8369 did not pass?

The Khayyat brothers’ $12 billion Syrian portfolio could not have been financed by any major international bank as long as the Caesar Act remained in force, because the law’s secondary sanctions exposure meant that any non-US bank moving funds into Syrian construction faced a US enforcement risk. With the law in place, the Khayyats would never line up credit lines for the Damascus airport. The removal of the sanctions opened the door to their investment (which kicked off at a suspiciously fast clip). With the Khayyats’ Syrian payday locked in, the joint-venture math on Sazan changed. Maybe this is the return Sen Wyden has been searching for?

The lawful integration of those three structures, executed across 2024 and 2025, is the structural reason FARA could not catch what was happening. The Khayyats did not need to register as foreign agents. Why pay to lobby the family of your investment partners? FARA and the existing disclosure architecture are not structures to police this kind of influence peddling, if, indeed, that is what is going on here.

The disclosure architecture’s failure is not the only thing the repeal accomplished, however.

The Caesar Act was not a wall designed primarily to keep Khayyat money out of Syria. It was a wall designed to keep something else out. Part three is about what came back in once the wall came down.

Come back Monday for the discussion about how bringing down that wall ushered in Assad’s chief economic enablers, the Russians, Iran and Hezbollah.