September 25,2024

Wyden Investigation of Kushner Firm Continues; New Letter Outlines Affinity Partners’ Fee Structure, Lack of Return to Investors, Questionable Deals with Foreign Governments

Amid Ongoing Investigation, Finance Chair Questions Whether Kushner Firm is Designed as a Workaround for Foreign Governments to Pay Trump Officials without Disclosure

Washington, D.C. – On Tuesday, Senate Finance Committee Chair Ron Wyden, D-Ore., continued his investigation into Affinity Partners, the firm owned by Jared Kushner, son-in-law and former top advisor of ex-President Donald Trump, with a letter detailing new findings on payments to Affinity from foreign governments and stating his concern that the firm represents a compensation scheme designed in part to skirt federal disclosure requirements.

Wyden wrote: “While I appreciate Affinity’s cooperation in this matter thus far, the information provided has heightened my concerns that investments in funds managed by Affinity create unprecedented conflicts of interest, and that Affinity’s investors may not be motivated by commercial considerations, but rather the opportunity to funnel foreign government money to members of President Trump’s family, namely Jared Kushner and Ivanka Trump.

“Affinity’s failure to deploy capital in a timely fashion while charging excessive fees has reinforced my view that Affinity is likely part of a compensation scheme involving U.S. political figures designed to circumvent the Foreign Agents Registration Act.”

The full text of the letter is available here. Key findings of Senator Wyden’s ongoing investigation include:

Affinity has pocketed as much as $157 million in fees from foreign clients, including $87 million from the Saudi government.

Affinity disclosed to committee investigators that the firm is charging its lead investor, the Saudi Public Investment Fund, a 1.25 percent annual fee on $2 billion in committed funds.
Affinity also disclosed that it is charging its other investors, including the yet undisclosed investor, a fee closer to 2 percent on committed funds.
Affinity’s fees structure is unusually high, given market trends and the relative inexperience of Kushner and the firm’s Trump-connected employees in the industry.

Affinity has generated no return on investment as of July 2024 and failed to deploy capital in a timely fashion.

Despite Affinity’s significant management fees, it deployed relatively little capital over a period of years.
Affinity disclosed that its funds have not generated any return on investment and have not distributed a penny of earnings back to clients. According to financial statements and other documents sent to clients, Affinity has marked “N/A” for “not applicable” in line items related to the fund’s annual rate of return.

Sovereign wealth fund investments and prospective real estate deals give foreign governments leverage over the Trump family.

Affinity indicated to the committee that government officials in Albania and Serbia approached the firm about potential partnerships in real estate deals. (Affinity did not disclose the identity of those Albanian and Serbian officials.) Affinity also confirmed that these foreign governments will have complete control over all decisions related to permitting, local taxation, and licenses necessary for the projects to move forward, giving them significant control over a lucrative Trump family investment.
Affinity confirmed that an upcoming Belgrade project, on the site of a former NATO bombing, will include a museum that has been described as a monument to “victims of NATO aggression.”
Affinity confirmed that its investors can renegotiate their investment agreements or withdraw all of their funds once their initial five-year investment period ends in August 2026, in the middle of a potential second Trump term in office. This would give foreign governments and entities unusual influence over the finances of the sitting president’s family, in the event he is elected, even beyond the influence they had and exercised in his first term.

Affinity’s dependence on foreign governments suggests a compensation scheme designed to circumvent FARA and other U.S. laws.

While former government officials like those who own and are employed by Affinity Partners would typically be required to disclose paid advisory roles with foreign governments, a loophole in disclosure requirements for investment firms allows foreign actors to funnel money to politically exposed U.S. persons for “investment advisory services” without disclosure. Affinity’s foreign financial ties and subsequent payments to Kushner and his employees have come to light via public reporting and the Finance Committee’s investigation, not legally-required disclosure.

Senator Wyden’s letter included several new questions regarding Affinity’s investors, structure, foreign financial ties and investments and payouts to Kushner and other employees. The questions follow below:

Please provide a list of all investors and, if entities, any beneficial owners thereof in private investment funds managed by Affinity, including Affinity Partners Fund I LP and Affinity Partners Parallel Fund I LP, since the firm’s inception in 2021. For each investor and beneficial owner, please provide the following:
1. The amount invested in, and any amounts contributed to, private investment funds managed by Affinity in each calendar year from 2021 to 2023.
2. The total amount of fees, expenses, reimbursements, and other sums paid to Affinity for each calendar year from 2021 to 2023.
3. The annual internal rate of return for each investor and general partner and/or fund manager in Affinity funds for each calendar year from 2021 to 2023.
4. A copy of the investment agreement with Affinity.
For each private investment fund managed by Affinity, please detail all fund income (broken down by character, including capital gains accruals) and distributions since Affinity’s inception in 2021.
For each private investment fund managed by Affinity, please provide all quarterly and annual performance measurements, including quarterly and annual rates of return since Affinity’s inception in 2021. Please also provide copies of all quarterly and annual performance reports distributed to the funds’ adviser(s).
Please provide copies of all annual financial statements and schedules of investments for private investment funds managed by Affinity since Affinity’s inception in 2021.
Please provide copies of all of Affinity’s annual financial statements since Affinity’s inception in 2021.
Affinity’s 2024 Form ADV disclosed that its Affinity Partners Parallel Fund I LP, which has $2.97 billion in assets under management, is 100% owned by non-United States persons and has six foreign beneficial owners. Please provide the identity of the 6 beneficial owners of this fund.
For each year since Affinity’s inception in 2021, please provide annual gross income and net income for each private investment fund managed by Affinity.
Please provide how much compensation Jared Kushner has received from Affinity for each calendar year from 2021 to 2023. Please describe in detail how much Kushner was paid annually by Affinity in salary, bonuses, other compensation, dividends, and any other accruals or distributions associated with his equity interest in Affinity, Affinity funds, or Affinity affiliates.
For each year since Affinity’s inception in 2021, please identify how much Affinity has spent on employee salaries, bonuses, and other compensation. Please also provide a detailed breakdown of all compensation paid to each of Affinity’s 10 highest paid employees for each year.
For each year since Affinity’s inception in 2021, please provide Maj. Gen. Miguel Correa’s total annual compensation and investment gains from Affinity.
Please provide a list of all Affinity shareholders and beneficial owners since the firm’s inception in 2021.
Please provide a list of all payments from each of the following to Affinity since Affinity’s inception in 2021. For each payment, please include the date of the payment, the dollar amount, and the stated purpose of the payment.
1. Saudi PIF or any other investors (sovereign wealth or otherwise) from the Kingdom of Saudi Arabia.
2. Qatar’s Investment Authority or any other investors (sovereign wealth or otherwise) from Qatar.
3. Abu Dhabi Investment Authority, Abu Dhabi Investment Council, Emirates Investment Authority, Mubadala Development Company, Mubadala Investment Company, or any other investors (sovereign wealth or otherwise) from the United Arab Emirates.
For all investments in real estate in Albania being considered by Affinity, please provide the following information:
1. A list of all individuals and entities partnering with Affinity in the development of Albanian real estate.
2. A list of all sites in Albania being considered for real estate development by Affinity and its partners and a description of Affinity’s development plans for each site.
3. The dollar value Affinity is considering investing in each Albanian real estate project, as well as the amount being invested by each of Affinity’s partners for each project.
4. A detailed description of the terms of all agreements between Affinity and the government of Albania related to the development of real estate in Albania. This should include specific details regarding the Albanian government’s financial interest in each project, the Albanian government’s role in each project, and all revenue sharing agreements between Affinity and the Government of Albania for each project.
5. A list of all regulatory approvals or permits Affinity and its partners need to obtain from the Albanian government for each real estate development to move forward. For each regulatory approval/permit, please specify which approvals have already been cleared by the Albanian government.
According to public reports, Ivanka Trump is playing a direct role in negotiations related to Affinity’s efforts to invest in real estate developments in Albania. Please describe Ivanka Trump’s role in these projects, and how she came to be involved in Affinity’s efforts to develop coastal real estate in Albania.
Please provide copies of all communications between Affinity employees and all members of the Trump family, including Ivanka Trump, related to Albania.
Affinity indicated to the Committee that the Albanian government first approached Affinity to discuss a potential deal to invest in real estate in Albania. Please provide a detailed list of the Albanian government personnel, or individuals contacting Affinity on behalf of the Albanian government, that first contacted Affinity to discuss real estate investments in Albania. Please also provide a list of the Affinity employees, or individuals affiliated with Affinity, who were first contacted by the Albanian government.
Affinity indicated to the Committee that the Albanian government, as part of its partnership with Affinity, is responsible for obtaining all necessary approvals, licenses and permits related to any real estate investments by Affinity in Albania. Are these terms spelled out formally in any agreements negotiated between Affinity and the Albanian government? If so, please provide the Committee a copy of those agreements.
For all investments in real estate in Serbia being considered by Affinity, please provide the following information:
1. A list of all individuals and entities partnering with Affinity in the development of Serbian real estate.
2. A list of all sites in Serbia being considered for real estate development by Affinity and its partners and a description of Affinity’s development plans for each site.
3. The dollar value Affinity is considering investing in each Serbian real estate project, as well as the amount being invested by each of Affinity’s partners for each project.
4. A detailed description of the terms of all agreements between Affinity and the Government of Serbia related to the development of real estate in Serbia. This should include specific details regarding the Serbian government’s financial interest in each project, the Serbian government’s role in each project, and all revenue sharing agreements between Affinity and the Government of Serbia for each project.
5. A list of all regulatory approvals or permits Affinity and its partners need to obtain from the Serbian government for each real estate development to move forward. For each regulatory approval/permit, please specify which approvals have already been cleared by the Serbian government.
Please provide copies of all communications between Affinity employees and all members of the Trump family, including Ivanka Trump, related to Serbia.
Affinity indicated to the Committee that the Serbian government first approached Affinity to discuss a potential deal to invest in real estate in Serbia. Please provide a detailed list of the Serbian government personnel, or individuals contacting Affinity on behalf of the Serbian government, that first contacted Affinity to discuss real estate investments in Serbia. Please also provide a list of the Affinity employees, or individuals affiliated with Affinity, who were first contacted by the Serbian government.
Affinity indicated to the Committee that the Serbian government, as part of its partnership with Affinity, is responsible for obtaining all necessary approvals, licenses and permits related to any real estate investments by Affinity in Serbia. Are these terms spelled out formally in any agreements negotiated between Affinity and the Serbian government? If so, please provide the Committee a copy of those agreements.

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