Recommendations:

- Law enforcement in the U.S. and Europe should investigate whether the Presidential family of Republic of Congo laundered public funds by purchasing property in New York, building on investigations into the family’s assets and middlemen pioneered by French and Portuguese authorities, and seize the apartment if appropriate. 

- U.S. investigators and relevant Congressional committees should carefully consider these allegations and, if appropriate, hold Donald Trump and the Trump Organization accountable for their part in the transactions in question.  

- In the U.S., the Treasury Department should initiate a rulemaking to require the real estate sector to perform anti-money laundering checks on clients, including enhanced checks on politically exposed persons. As part of this rule, the Treasury Department should also require the disclosure of ultimate beneficial owners of companies purchasing real estate throughout the U.S.  

- Every country should require lawyers that carry out transactions for their clients, including the buying and selling of real estate and the creation of companies, to know the real identity of their clients and the source of their clients’ funds. 

- Every country should require all companies and trusts to disclose publicly who ultimately owns and controls them, and to make this information public.