Revenge of the Money Launderers

The “FinCen files” story reveals: getting caught doesn’t stop banks from taking dirty money. It may even encourage them

On December 11, 2012, U.S. Justice Department officials called a press conference in Brooklyn. The key players were once and future bank lawyer Lanny Breuer (disguised at the time as Barack Obama’s Assistant Attorney General in charge of the DOJ’s Criminal Division), and Loretta Lynch, the U.S. Attorney for the Eastern District of New York, and future Attorney General. The duo revealed that HSBC, the largest bank in Europe, had agreed to a $1.9 billion settlement for years of money-laundering offenses.

An alphabet soup of regulatory agencies was represented that day, from the Justice Department, to Immigration and Customs Enforcement (ICE), the U.S. Treasury, the New York County District Attorney, and the Office of the Comptroller of the Currency, among others.

The regulators outlined a slew of admissions, with HSBC’s headline offense being the laundering of $881 million for Central and South American drug outfits, including the infamous Sinaloa cartel.

The laundering was so brazen, regulators said, the bank’s Mexican subsidiary had developed “specially shaped boxes” for cartels to pack with cash and slide through teller windows. The seemingly massive fine reflected serious offenses, including violations of the Bank Secrecy Act (BSA), the International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA).

The next years would follow up with a flurry of similar settlements extracting sizable-sounding fees from other transnational banks for laundering money on behalf of terrorists, sanctioned businesses, mobsters, drug dealers, and other malefactors. Firms like JP Morgan Chase ($1.7 billion), Standard Chartered ($300 million), and Deutsche Bank ($258 million) were soon announcing settlements either for laundering, sanctions violations, or both.

Even seasoned financial reporters accustomed to seeing soft-touch settlements scratched their heads at some of the deals. In the case of HSBC, the stiffest penalty doled out to any individual for the biggest drug-money-laundering case in history — during which time HSBC had become the “preferred financial institution” of drug traffickers, according to the Justice Department — involved an agreement to “partially defer bonus compensation for its most senior executives.” If bankers can’t get time for washing money for people who put torture videos on the internet, what can they get time for?

When I did a story on the case in early 2013, I found the HSBC settlement was the latest step in a dizzying, decade-plus cycle of offenses and ignored reprimands, involving multiple regulatory bodies. The number of times HSBC had blown off compliance orders seemed too absurd to be real. In one stretch between 2005 and 2006, the bank received (and, apparently, ignored) 30 formal warnings just from the Office of the Comptroller of the Currency.

Prosecutors insisted the deferred prosecution settlements slapped on companies like HSBC, Standard Chartered, and JP Morgan Chase were tougher than jail terms. The deals would place banks in a permanent state of quasi-arrest, with regulators granted enormous supervisory power and serious charges pre-filed and hanging over the firms going forward.

As one federal investigator put it to me back then, “This way, we have them by the short ones.”

Fast-forward eight years. On September 20th, a combination of Buzzfeed and the International Consortium of Investigative Journalists (ICIJ) published the details of a major document leak highlighting a decade of money-laundering incidents, involving hundreds of billions of dollars and a number of the world’s biggest banks. The leak centered on a cache of over two thousand “suspicious activity reports,” or SARs, filed by those banks to the Financial Crimes Enforcement Network, a regulatory arm of the U.S. Treasury.

Though the ICIJ was also behind the release of the Panama Papers, investigative editor Michael Hudson told me he believes the FinCen leak is “the most important” project they’ve worked on. Instead of being about one group of actors, or one jurisdiction, these revelations span the banking sector as a whole.

“It shows the widest set of problems,” he says.

The story has been covered around the world, but some press accounts particularly here in the States seem to have missed the punchline, i.e. that the banks figuring most prominently in the FinCen leak are exactly the same institutions paraded before the public as subjects of “message-sending” punishments back in 2012-2014.

HSBC, for instance, continued to take in questionable money through 2012 and beyond, including $30 million from Hong Kong accounts related to a Ponzi scheme called World Capital Market. WCM was suspected of bilking “investors” — most of them ordinary people scraping together five or ten thousand dollars and throwing them at false promises of guaranteed returns — of nearly $80 million.

The leaked records show HSBC flagged the account as suspicious as early as 2013, but continued to take the money from this and a wide variety of other dicey accounts. Although regulators saw all of this information, the Department of Justice not only didn’t take action, it announced in 2017 that HSBC had “lived up to all of its commitments” and agreed to file a motion to lift the deferred prosecution deal.

A similar pattern held with JP Morgan Chase, which in 2013 was hit with a cease and desist order over “systemic deficiencies” in its money-laundering controls, yet continued to do business with rogue accounts, including some infamous and obvious ones. To give some sense of the sums involved, JPM made roughly a half-billion dollars just servicing the accounts for con artist Bernie Madoff.

As far back as 2006, JP Morgan Chase knew enough to pull its own money out of investments in hedge funds tied to Madoff, but never told investors, and continued to manage his accounts for years. The bank ultimately settled with the government over the Madoff episode in 2014, after the 2013 “cease and desist” order, while continuing to manage money for other malodorous accounts — including, according to the ICIJ, more than $1 billion for Jho Low, the fugitive financier behind Malaysia’s infamous 1MDB fund.

In a detail that should infuriate the #Resistance crowd, Jamie Dimon’s bank also continued to do business in huge sums for former Trump campaign manager Paul Manafort even after Manafort stepped down in scandal, and even after the bank flagged Manafort’s accounts. From the ICIJ report:

JPMorgan also processed more than $50 million in payments over a decade, the records show, for Paul Manafort, the former campaign manager for President Donald Trump. The bank shuttled at least $6.9 million in Manafort transactions in the 14 months after he resigned from the campaign amid a swirl of money laundering and corruption allegations spawning from his work with a pro-Russian political party in Ukraine.

“If you look at the cases where they tried to punish and deter the big banks, the headline-making efforts just haven’t worked,” says Hudson. “In the aftermath of these supposed crackdowns, the banks continued to move money in staggering amounts, for powerful and dangerous characters.”

“The big takeaway is, the system just doesn’t work,” adds former federal prosecutor Paul Pelletier. “I think these SARs represent about $2 trillion in suspicious transactions, and nearly all of it went through. And this is just a small fraction of the overall amount of money.”

According to Hudson, the FinCen files represent about two-tenths of one percent of the suspicious activity reports filed between 2011 and 2017.

In the aftermath of the HSBC deal in 2012, money laundering cases began to attract a fair amount of press attention. HSBC’s case even became one of the subjects for Oscar-winning documentarian Alex Gibney’s “Dirty Money” series:

At the time, there was an expectation that these stories could be told in the past tense, because firms like HSBC had been busted. The FinCen leaks show the opposite. The settlements may actually have been an accelerant, allowing for the appearance of regulation, while alerting banks to broader weaknesses that encouraged more brazen behavior going forward. We may have to change the way we think about “dirty money,” from being an outside contaminant, to endemic to the system at its core.


Public legend about movement of ill-gotten cash usually centers on crooks sitting under ceiling fans in tropical locales, receiving mysterious wire transfers in places outside the physical reach of American regulators, like VanuatuPanama, or the British Virgin Islands. The FinCen leaks make clear the real hub of money laundering is in what Hudson calls the “choke point” of New York, where the world’s largest financial institutions have streamlined the process of moving shady money.

SARs don’t always indicate a crime. They’re the regulatory equivalent of a call to police to check something out that doesn’t add up. Bank monitors who compile them might be spotting something in their account rolls like high numbers of cash transactions, large numbers of wire transfers to a country where the customer doesn’t do business, etc.

The requirement to produce these reports creates a cat-and-mouse game for banks. Every time compliance officers discover derogatory information that leads to an account being closed, it’s a direct hit to a bank’s revenues. On the other hand, to keep regulators off their backs, banks have to be seen to be doing all they can to sniff out illegalities. Therefore there’s an incentive for banks to cycle through creative ways of looking like they’re engaging in compliance, without actually doing so.

A bank might create sizable AML departments, but pad them with inexperienced, entry-level employees incapable of spotting problems (see here for the HSBC example I wrote about years ago). A firm may hire a top-of-the-line department head, but not give him or her real resources. Required hiring boxes may be checked, but the company may non-report or under-report problems. Companies may even generate huge numbers of suspicious activity reports while leaving key data like names or addresses missing.

In a different scenario, reports are filed too late for action to be taken. SARs are supposed to be filed within 30 days, for instance, but the FinCen documents were filed to the government an average of 166 days after the initial detection of a potential problem.

In another stalling method, banks informally agree not to close suspicious accounts until a certain number of SARs have accrued. When the Senate Permanent Subcommittee on Investigations looked at HSBC in 2012, for instance, they found internal emails from bank executives suggesting that HSBC’s Mexico operations had settled on a policy of not closing accounts until four SARs had been filed.

When the company’s chief compliance officer found out about its subsidiary HMEX’s standard, he wrote, in a bemused tone, “4 SARs seems awfully indulgent, even by local standards.” HMEX later cut the standard to two SARs, which seems to be the exception rather than the rule. In the FinCen leaks, companies are seen repeatedly filing reports about the same actor, each time implying they’ve dug just enough to write a report, but never quite enough to actually close the account.

Of course, in banking, size matters. “Maybe the bank looks at a wire transfer and says, ‘This smells.’ Do that in a $12,000 transaction, and they’ll kick you out of the bank,” says Pelletier. “Do it at $12 million, and they’ll let it go.”

What’s unique about this leak it shows bad behavior the banks actually reported. As one former investigator put it this week, “This is the stuff they actually have a suspicious activity report for!” That banks keep taking the money is bad, but the fact that regulators keep receiving the reports and letting shady transactions slide makes the dirty-money problem a bizarre symbiosis of private rapaciousness and (at best) governmental apathy.

While credit card companies are able to detect fraud and banks are able to detect suspicious activity thanks to technological advances, the government lacks the same capability, in part perhaps because the reporting system is not automated. Since it’s a crime to leak a “SAR” — you “literally have to steal one” to make one public, as one former investigator puts it — they’ve rarely been seen by the public. The ICIJ has now put them on display:

The government receives millions of these written reports, which often appear to reflect a fair amount of person-hours of research by the bank. However, the government lacks what one investigator described to me as an “AI-type test” for passive review of this material, and lacks the personnel to go through it all individually.

At best, a federal investigator may go through the SAR database to check an individual or company already targeted in another probe. This particular batch of SARs seems to have been gathered as part of a congressional investigation into Russian interference, for instance. The rest of the reports are fated to be memory-holed by overwhelmed regulators.

What do you get in this seeming worst-case scenario, when banks pretend to monitor, and regulators pretend to collect the monitoring? A short list of some of the messes found in the FinCen docs:

— In one ridiculous case, Deutsche Bank’s New York branch processed $2.6 billion and $700 million, respectively, for a pair of companies called Ergoinvest and Chadborg trade. Both companies declared annual incomes of $35,000, and the statements for both firms bear the signature of the same obscure dentist in Belgium, who claims he doesn’t even own a car. Yet the money kept rolling through! The companies earned British registrations through “formation agencies” located in the Baltics, where investigators have found a rat’s nest of problems in recent years. Deutsche Bank, the originator of 62% of the leaked SARs (perhaps reflecting the focus of the Russia investigation that produced the FinCen docs), moved at least $150 billion just from one small Tallinn-based bank, Danske Estonia, for instance.

— Ukrainian Ihor Kolomoisky was the subject of raids by federal investigators earlier this summer, and has been profiled in colorful news reports that read like movie scripts. In one piece, he allegedly dropped crayfish meat by remote control into a tank to be devoured by sharks in the middle of a meeting, as a Dr. Evil-style intimidation tactic.

ICIJ @ICIJorg

Learn about the 22 properties Kolomoisky and his associates purchased between 2006 and 2015 – with this interactive map made by @pirhoo. #FinCENFiles

Michael Sallah @MikeSallah7

The Oligarch Who Ate Cleveland: Untold story of how Deutsche Bank helped Igor Kolomoisky acquire an empire in real estate in America’s heartland — the money siphoned from Ukraine’s largest bank. @TanyaKozyreva and me and team from @ICIJorg https://t.co/2aWlZGtPQt via @ICIJorg

The crux of accusations by prosecutors is that Kolomoisky employed gangland tactics at home (including using “armed goons” to take over an oil company), then funneled the money to places like the States, to be invested in legit vehicles like real estate. This is exactly the kind of person the SAR process is designed to identify and disqualify quickly. Nonetheless, the FinCen files show Deutsche Bank, which had entered into a settlement deal in 2015 for moving over $11 billion in suspicious transactions, moved at least $240 million for a Kolomoisky-connected account at exactly that time, between 2015 and 2016.

— Even as Russian aluminum baron Oleg Deripaska garnered enormous media attention in recent years, including during the Russiagate furor, he continued to move money freely through the American banking system. The FinCen files contain a total of 58 SARs related to Deripaska, issued between 1997 and 2017, covering an amazing $12.41 billion in transactions. The Bank of New York Mellon flagged 16 transactions involving a Deripaska subsidiary company called Mallow Capital, but apparently kept doing business. To quote the ICIJ, “Mellon said Mallow Capital appeared to be a shell company operating in a high-risk area with no known legitimate business purpose. In 2012 and 2013, Mallow sent itself nearly $420 million using different British Virgin Islands addresses and different banks…”

The FinCen leaks highlight two major weaknesses of the regulatory system. One is the longstanding absence of a requirement that anyone opening a U.S. account name a “beneficial owner,” i.e. who is really controlling the account. The other is correspondent banking. Banks in the U.S. are required to “know your customer” in addition to monitoring and reporting domestic accounts. Still, any foreign bank with a license may open “correspondent” accounts in those same regulated Western banks. A lot of the worst instances catalogued in the FinCen leaks involve these correspondent accounts, opened in Asia, Eastern Europe, the Middle East, etc.

In the long run, the regulatory system ends up serving as a de facto partner for banks that all but admit they’re taking in money from Ponzi schemers, mobsters, drug lords, and rogue states.

This is a “feature, not a bug” problem. Going back to the years after the crash, regulators spoke often about the need to carefully construct settlements, so that even repeat offenders might remain viable.

In late 2012, for instance, at a press conference announcing a market manipulation settlement for the Swiss Bank UBS, Breuer told reporters, “Our goal here is not to destroy a major financial institution.”

This is a bank that has broken the law before,” a reporter said that day. “So why not be tougher?”

“I don’t know what tougher means,” Breuer answered.

Some time later, then-Attorney General Eric Holder gave a video message on the theme, “There is no such thing as Too Big to Jail.” While insisting “no one is above the law,” Holder pointed out that some criminal charges carried automatic regulatory penalties that “may even trigger the loss of that institution’s charter.” This, he implied, is not always a good thing.

This issue had come up at the HSBC press conference the previous year, when Breuer said, “had the US authorities decided to press criminal charges, HSBC would almost certainly have lost its banking license in the US.”

For that reason, Holder insisted, regulators often “must go the extra mile to coordinate closely with the regulators who oversee these institutions’ day-to-day operations.”

Translated, this meant the Justice Department was crafting punishments to make sure banks landed on their feet and remained functional as American businesses, even in the face of public reprimand.

A typical settlement involved a fine that sounded large but was really equal to months or weeks of profit, with penalties in some cases also being deductible, so taxpayers could share in the joys of paying a bank’s debt to society. In other words, settlements were designed not to hurt too much, but just the right amount.

Even a “record” harsh settlement doled out to the French bank BNP-Paribas in 2014 for sanctions violations, which included a rare plea to a real criminal charge in addition to a $9 billion penalty, only incurred a one-year exile from U.S. dollar transactions. Even when throwing the proverbial book at firms, regulators made sure to pave clear roads to redemption.

This was not necessarily a bad thing. There’s no reason why anyone should want systemically-important institutions (who are often major employers) to be wiped off the face of the earth, willy-nilly. The problem is that if you completely remove the threat of a lost charter, it signals to everyone that regulators will tolerate even open repeat violations. In this light, even a “tough” public punishment becomes a license to steal.

Hudson, for instance, notes that announcements of many of the biggest money laundering settlements involving the firms in the FinCen files were accompanied by jumps in the company’s share prices. HSBC’s shares rose in London and Hong Kong after the 2012 settlement, and even BNP’s criminal plea deal prompted a 3.6% jump in share price. Markets see the settlements as seals of approval going forward, and “send the signal that the regulators are looking to do a deal,” Hudson says.

The irony of all this is that the Trump era has seen much gnashing of teeth over America’s withdrawal from global bureaucracies like the Paris Agreement, the “Open Skies” arms control treaty, the Iran deal, and other conventions. Meanwhile, in the one place we want an isolationist-style wall, around the Federal Reserve-connected American banking system, barriers are wearing away. Only in crime, it seems, is America becoming more global in outlook.

Giuliani Promised a Surprise Before the Election. Comey Delivered One.

Once, in his days as New York’s chief federal prosecutor and later as the city’s mayor, Rudolph W. Giuliani was a master of releasing damaging leaks aimed at the kneecaps of opponents. Sometimes, they were true.

.. witnesses told the inspector general that a fear of leaks from within the F.B.I. drove the agency’s former director, James Comey, to break with established policy against opening or discussing investigations in the run-up to an election.

.. The former attorney general, Loretta Lynch, told investigators that Mr. Comey “said, ‘It’s clear to me that there is a cadre of senior people in New York who have a deep and visceral hatred of Secretary Clinton.’ And he said, ‘It is deep.’”

.. Mr. Comey said he found it “stunning,” Ms. Lynch told the investigators. She replied to him: “I’m just troubled that this issue — meaning the, the New York agent issue and leaks — I am just troubled that this issue has put us where we are today with respect to this laptop.”

.. On Oct. 25, 2016, three days before Mr. Comey’s stunning announcement, Mr. Giuliani appeared on a Fox morning television show.

“We got a couple of surprises left,” Mr. Giuliani said.

He chortled, and when asked to expand on the subject, replied, “And I think it’ll be enormously effective.”

On Thursday, Oct. 27, Mr. Giuliani appeared on another Fox show and said he was talking about “pretty big surprises.” He added, “We’ve got a couple of things up our sleeve that should turn this thing around.”

The news of the reactivated email inspection arrived the following day

.. Upon inspection by the F.B.I., the emails on the laptop turned out to be much ado about hardly anything — many of them had already been reviewed, and the authorities decided they did not warrant changing the conclusion

.. In interviews this week, including on Fox, Mr. Giuliani said that the “surprise” he was talking about in 2016 had nothing to do with the email investigation, but was a speech that Mr. Trump was going to give right before the election blasting Mrs. Clinton.

It’s hard to imagine that anyone, Mr. Giuliani included, would have classified a Trump campaign speech as a “pretty big surprise.”

.. On the day of Mr. Comey’s announcement in 2016, Mr. Giuliani was so pleased that he blurted out a description of his sources for inside information on the email case.

“The other rumor that I get is that there’s a kind of revolution going on inside the F.B.I. about the original conclusion being completely unjustified, and almost a slap in the face of the F.B.I.’s integrity,” Mr. Giuliani said in a radio interview with Lars Larson, the conservative talk show host.

“I know that from former agents. I know that even from” — Mr. Giuliani paused, then continued — “a few active agents who obviously don’t want to identify themselves.”

.. And now Mr. Giuliani is telling a new version. All his predictions were just speculation by retired agents, he said on Fox Business recently.

“We knew just by instinct,” he said, “that the New York office was enraged.”

A Higher Sanctimony

Comey’s memoir shows he is more like Trump than he cares to admit.

But Mr. Trump told an interviewer that he had fired Mr. Comey because the FBI chief wouldn’t say publicly that the FBI wasn’t investigating Mr. Trump. The President also threatened Mr. Comey with a false claim about Oval Office “tapes.” Mr. Comey responded by leaking documents that caused Mr. Rosenstein to name a special counsel, which has put Mr. Trump’s Presidency in mortal peril.

.. The main lesson from Mr. Comey’s book is that Mr. Trump’s abuse of political norms has driven his enemies to violate norms themselves.

.. The most notable fact in the book is how little we learn that is new about Mr. Trump.

.. Mr. Trump is preoccupied with his critics and the validation of his presidential victory. He is clueless that his bullying and flattery would repel Mr. Comey

.. The book mainly adds Mr. Comey’s moral and aesthetic contempt for Mr. Trump.

.. Mr. Comey’s comparison of Mr. Trump to a “mafia” boss is hilariously overstated. Don’t they call it “organized” crime? And what about that code of silence known as omerta? The Trump White House can’t keep anything secret.

.. Mr. Comey reveals in his excessive self-regard that he is more like Mr. Trump than he cares to admit. Mr. Trump’s narcissism is crude and focused on his personal “winning.” Mr. Comey’s is about vindicating his own higher morality and righteous belief.

.. He accuses Mr. Rosenstein of acting “dishonorably” by writing the memo describing how Mr. Comey mishandled the Clinton probe. Yet he barely engages Mr. Rosenstein’s arguments, which quoted from former Justice officials of both parties. Mr. Rosenstein wrote that Mr. Comey was “wrong to usurp” the authority of Attorney General Loretta Lynch and wrong to “hold press conferences to release derogatory information” about Mrs. Clinton.

That mistake made Mr. Comey feel obliged to intervene again in late October—this time to announce the reopening of the probe in a way that helped Mr. Trump. Had Mr. Comey followed Justice protocol in July, he would not have had to make himself the issue in October, damaging the reputation of the FBI and Justice in the bargain.

.. This has been the habit across Mr. Comey’s career, though you’ll find no mention in his memoir of Steven Hatfill, the government scientist he wrongly pursued for years as the anthrax terrorist; or Frank Quattrone, the Wall Street financier he prosecuted twice for obstruction of justice only to be rebuked by an appeals court; or Judith Miller’s recantation of her testimony against Scooter Libby.

Mr. Comey has also had little to say so far about the controversy over the Steele dossier and his handling of the Russian investigation of Mr. Trump. Did he know that the dossier was commissioned by Democrats for the Clinton campaign? He also has nothing to say about the dismissal of his former FBI deputy, Andrew McCabe, for “lack of candor.”

Mr. Comey is getting his moment of revenge as much of the press revels in the attacks on Mr. Trump. Yet his career, reinforced by his memoir, is a case study in the perils of the righteous prosecutor. It also shows why Mr. Comey’s view of the FBI as “independent” of supervisory authority is wrong and dangerous. A presidential bully who abuses power needs to be checked, but so does an FBI director who turns righteousness into zealotry.

James Comey’s memoir: Trump fixates on proving lewd dossier allegations false

According to Comey’s account in a new memoir, Trump “strongly denied the allegations, asking — rhetorically, I assumed — whether he seemed like a guy who needed the service of prostitutes. He then began discussing cases where women had accused him of sexual assault, a subject I had not raised. He mentioned a number of women, and seemed to have memorized their allegations.”

The January 2017 conversation at Trump Tower in Manhattan “teetered toward disaster” — until “I pulled the tool from my bag: ‘We are not investigating you, sir.’ That seemed to quiet him,” Comey writes.

Trump did not stay quiet for long. Comey describes Trump as having been obsessed with the prostitutes portion of the infamous dossier compiled by former British intelligence officer Christopher Steele, raising it at least four times with the FBI head.

.. Trump offered varying explanations to convince Comey it was not true. “I’m a germaphobe,” Trump told him in a follow-up call on Jan. 11, 2017, according to Comey’s account. “There’s no way I would let people pee on each other around me. No way.” Later, the president asked what could be done to “lift the cloud” because it was so painful for first lady Melania Trump.

.. In his memoir, Comey paints a devastating portrait of a president who built “a cocoon of alternative reality that he was busily wrapping around all of us.” Comey describes Trump as a congenital liar and unethical leader, devoid of human emotion and driven by personal ego.

.. Interacting with Trump, Comey writes, gave him “flashbacks to my earlier career as a prosecutor against the Mob.

  • The silent circle of assent.
  • The boss in complete control.
  • The loyalty oaths.
  • The us-versus-them worldview.
  • The lying about all things, large and small, in service to some code of loyalty that put the organization above morality and above the truth.”

.. The result, in Comey’s telling, is “the forest fire that is the Trump presidency.”

.. “You can’t be kicked out of the room so he can talk to me alone,” Comey told Sessions, according to the book. “You have to be between me and the president.”

.. “Sessions just cast his eyes down at the table, and they darted quickly back and forth, side to side. He said nothing. I read in his posture and face a message that he would not be able to help me.”

.. Comey delivers an indirect but unmistakable rebuke of the GOP’s congressional leaders as well: “It is also wrong to stand idly by, or worse, to stay silent when you know better, while a president brazenly seeks to undermine public confidence in law enforcement institutions that were established to keep our leaders in check.”

.. “I have one perspective on the behavior I saw, which while disturbing and violating basic norms of ethical leadership, may fall short of being illegal,” he writes.

.. “They lose the ability to distinguish between what’s true and what’s not,” Comey writes. “They surround themselves with other liars . . . Perks and access are given to those willing to lie and tolerate lies. This creates a culture, which becomes an entire way of life.”

.. Comey also writes that in a post-election briefing for senators, then-Sen. Al Franken (D-Minn.) confronted him about “what you did to Hillary Clinton.” Comey responded, “I did my best with the facts before me.” A teary-eyed Senate Minority Leader Charles E. Schumer (D-N.Y.) grabbed him by the hand afterward and said, “I know you. You were in an impossible position,” Comey writes.

.. Comey is critical of then-Attorney General Loretta E. Lynch, saying she had a “tortured half-out, half-in approach” to the Clinton investigation and that he considered calling for the appointment of a special prosecutor.

.. “As he extended his hand,” Comey adds, “I made a mental note to check its size. It was smaller than mine, but did not seem unusually so.”

.. Comey recalls being struck that neither Trump nor his advisers asked about the future Russian threat, nor how the United States might prepare to meet it. Rather, he writes, they focused on “how they could spin what we’d just told them.”

.. “I decided not to tell him that the activity alleged did not seem to require either an overnight stay or even being in proximity to the participants,” Comey writes. “In fact, though I didn’t know for sure, I imagined the presidential suite of the Ritz-Carlton in Moscow was large enough for a germaphobe to be at a safe distance from the activity.”

.. Comey writes that he believed Trump was trying “to establish a patronage relationship,” and that he said: “I need loyalty. I expect loyalty.”

.. Trump broke the standoff by turning to other topics, Comey writes, speaking in torrents, “like an oral jigsaw puzzle,” about the size of his inauguration crowd, his free media coverage and the viciousness of the campaign. He talked about the Clinton email investigation as in three phases, as if it were a television series: “Comey One,” “Comey Two” and “Comey Three.” Trump also tried to convince Comey that he had not mocked disabled New York Times reporter Serge Kovaleski at a campaign rally, and then turned to the detailed allegations of sexual assault against him.

“There was no way he groped that lady sitting next to him on the airplane, he insisted,” Comey writes. “And the idea that he grabbed a porn star and offered her money to come to his room was preposterous.”

.. And then Trump brought up “the golden showers thing,” Comey writes. The president told him that “it bothered him if there was ‘even a one percent chance’ his wife, Melania, thought it was true.” Comey writes that Trump told him to consider having the FBI investigate the prostitutes allegation to “prove it was a lie.”

.. As the dinner concluded, Trump returned to the issue of loyalty.

“I need loyalty,” Trump tells Comey, according to the book.

“You will always get honesty from me,” Comey replies.

“That’s what I want, honest loyalty,” Trump said, reaching what Comey writes was “some sort of ‘deal’ in which we were both winners.”

.. The president, Comey recalls, “launched into one of his rapid-fire, stream-of-consciousness monologues” — this time about a recent Super Bowl interview with then-Fox News Channel personality Bill O’Reilly in which Trump complimented Russian President Vladi­mir Putin.
.. “But he’s a killer,” O’Reilly told Trump.The president’s reply: “There are a ton of killers. We’ve got a lot of killers. What do you think? Our country’s so innocent?

Trump fumed to Comey about the media criticism he received.

I gave a good answer,” Trump said, according to Comey. “Really, it was a great answer. I gave a really great answer.

Trump sought validation: “You think it was a great answer, right?”

Comey replied, “We aren’t the kind of killers that Putin is.”

Trump apparently did not take the correction well. Comey writes that the president’s eyes changed and his jaw tightened, and Priebus escorted him out.

.. Comey describes soon receiving an “emotional call” from Homeland Security Secretary John F. Kelly.

“He said he was sick about my firing and that he intended to quit in protest,” Comey writes. “He said he didn’t want to work for dishonorable people who would treat someone like me in such a manner. I urged Kelly not to do that, arguing that the country needed principled people around this president. Especially this president.”

Kelly did not resign. Two and a half months later, he was named White House chief of staff.