All The President's Money

How do you separate noise from evidence when politics and business collide? In this book, Chairman James Comer argues that the clearest road to truth is the bank-led paper trail—Suspicious Activity Reports (SARs), wire confirmations, and LLC ledgers—corroborated by emails, texts, and sworn testimony. Comer contends that a pattern of foreign money—especially from Chinese-linked CEFC and Ukrainian firm Burisma—reached Biden family members through a web of intermediaries and shell companies, with timing and labeling that suggest influence-peddling rather than bona fide services. To see it, you follow the money first, then match it to communications and calendar events.

You learn that banks filed roughly 170 SARs on accounts tied to Hunter Biden and other Biden family entities—an extraordinary volume that triggered aggressive oversight. From there, subpoenas pulled bank records tracing foreign wires into associate-controlled LLCs (Robinson Walker LLC, Rosemont Seneca Bohai, Hudson West III) and then into Biden-affiliated accounts (Owasco PC, Lion Hall Group, JBBSR Inc.). The committee quantifies more than $18 million to Biden family members from foreign sources (about $27 million including associates), and frames the structure—layered transfers, “loan” labels, rapid splits—as classic obfuscation you’d expect in money laundering typologies (Note: SARs are not proof of crime; they are bank-filed red flags that guide investigators).

The evidentiary spine: SARs, banks, and matching communications

The core argument rests on documentary convergence. SARs and bank subpoenas produce dates, amounts, and accounts; the Hunter Biden laptop (later validated by independent forensic work, including CBS’s Catherine Herridge reporting) supplies contemporaneous messages, contracts, and attachments that often name the very accounts receiving the funds. Witnesses—Tony Bobulinski, Devon Archer, Jason Galanis, Eric Schwerin—add narrative texture that either aligns with the documents or contradicts sworn denials, which the committee uses as leverage for referrals.

Two anchor stories: CEFC and Burisma

CEFC, chaired by Ye Jianming and described here as state-aligned within China’s Belt and Road orbit, sent multimillion-dollar transfers via vehicles like Northern International Capital and State Energy HK. Notable examples include a $5 million wire into Hudson West III on August 8, 2017 (with rapid movements to Owasco PC) and a $3 million State Energy HK wire to Robinson Walker LLC on March 1, 2017, followed by disbursements to Biden family members over ten weeks. In the Burisma chapter, Rosemont Seneca Bohai (RSB) functions as the receiving node for monthly payments, with a bank letter naming Hunter Biden the “beneficial owner” and an RSB corporate resolution bearing his signature as “Secretary.” The committee argues these documents undercut later deposition denials of control.

Information control as a force multiplier

Comer frames the Hunter Biden laptop episode as pivotal. He argues that social-media suppression, the “51 intel officials” letter, and newsroom skepticism muted early scrutiny, shaping public perception in 2020. Only years later, after the Twitter Files and independent forensic validation, did the laptop’s contents gain broader acceptance—by then, much of the political damage (or insulation) was done. The committee points out that DOJ later used laptop-derived material in the gun-case prosecution (2024), bolstering its view that the contents were evidentiary, not disinformation.

Institutions, witnesses, and the fog of oversight

The storyline also runs through the FBI, DOJ, and IRS. Whistleblowers Gary Shapley and Joseph Ziegler describe investigative roadblocks—limits on lines of questioning, slow-walking, and restricted access to laptop materials or FD-1023 reports. Comer narrates a protracted battle with FBI Director Christopher Wray over a bribery-related FD-1023 (later linked to informant Alexander Smirnov, who was indicted for lying). Add in Speaker turnover and media theatrics, and you see how political timing, classification rules, and institutional caution can blunt congressional efforts (Note: Democrats dispute “obstruction” claims and argue the evidence does not implicate Joe Biden in bribe-taking or official acts).

What you should watch for

The book teaches you to track four things: (1) the volume and timing of wires; (2) who controls the receiving accounts; (3) what documents say about beneficial ownership and purpose; and (4) how testimony aligns—or fails to—with those records. When patterns repeat (foreign inflow, intermediary LLC, rapid splits, “loan” labels, family disbursements), Comer argues you’re looking at systemic influence-peddling. When testimony denies control but signatures and bank letters suggest otherwise, he pushes for perjury referrals.

Bottom line: you follow the SARs and ledgers to reconstruct intent, then test that reconstruction against emails, texts, calendars, travel logs, and witness accounts. Whether you accept the larger political thesis, the method—document-first, narrative-second—is what gives the case its force. And that method, Comer insists, is portable: it’s how you should read any high-stakes corruption probe, beyond partisan labels (In All the President’s Men, Woodward and Bernstein also centered paper trails over rhetoric—Comer consciously evokes that tradition).

Comer positions Suspicious Activity Reports (SARs) as the investigation’s ignition key and map legend. You should see SARs as bank-generated warnings that something about a transaction—amount, counterparties, timing, or account history—doesn’t fit normal patterns. Here, six U.S. banks filed roughly 170 SARs tied to accounts connected to Hunter Biden and other Biden family entities. That quantity, Comer argues, is historic and compelled deeper scrutiny. SARs alone aren’t proof, but they tell you where to point subpoenas and what accounts to prioritize.

How SARs unlock the trail

Once the committee gained Treasury access (after a months-long tug-of-war), staff used SAR pointers to subpoena bank records. That produced thousands of pages of wire data, check images, and account statements. By layering SAR narratives over bank records, you can reconstruct flow patterns: foreign-origin wires hit an associate-controlled LLC, then break into smaller transfers that ultimately land in entities like Owasco PC (Hunter Biden), Lion Hall Group (Jim and Sara Biden), or JBBSR Inc. The committee’s summary tallies over $18 million to Biden family members from foreign sources, and more than $27 million including associates.

Red-flag patterns you can trace

The book highlights several recurrent anomalies: dormant accounts that suddenly receive outsized single wires, rapid “layering” through multiple LLCs, and labels like “loan” or “consulting fees” that don’t align with verifiable deliverables. Specific examples anchor the pattern. On March 1, 2017, State Energy HK Limited wired $3 million to Robinson Walker LLC; within about ten weeks, roughly $1.065 million moved to Biden family members and related entities (Hunter, Jim, Hallie, and an unnamed “Biden”). On August 8, 2017, Northern International Capital wired $5 million into Hudson West III; that same day, $400,000 moved to Owasco PC. In a separate chain involving Hudson West and Lion Hall Group, about $40,000 ultimately reached Joe Biden’s personal account (the committee cites this as part of a broader “China money” loop).

From numbers to narrative

Bank records give you dates and dollars; communications provide purpose and control. That’s why the committee cross-references emails, WhatsApp messages, and contracts from the laptop to identify “beneficial owners,” intended recipients, and fees. When a Burisma email thread in May 2014 formalizes monthly payments to Rosemont Seneca Bohai and labels Hunter the “beneficial owner,” and bank records then show paired $83,333.33 transfers, the ledger and the language align. Likewise, witness accounts—Devon Archer confirming equal Burisma splits; Eric Schwerin acknowledging unpaid bookkeeping for Joe Biden and confirming pseudonym emails—become corroborants or contradictions you can weigh against the paper.

Limits and alternative views

You should keep perspective: SARs are designed to over-capture risk and do not imply guilt. Democrats and many media outlets argue that the committee’s patterns lack proof that Joe Biden took official actions in exchange for funds, or that family “brand monetization” equals bribery. They also note that the Smirnov-linked FD-1023 later collapsed with his indictment, which they say undercuts credibility. Comer counters that even without Smirnov, the bank records and emails independently document foreign money flows inconsistent with normal consulting, and that investigators should not require a smoking-gun memo when the circumstantial structure is this elaborate (Note: prosecutors often build financial cases on patterns, not confessions).

Key idea

“Bank records do not lie” becomes the mantra—use SARs to find the accounts, then test every transfer against documents, travel, and testimony.

How you apply this method

If you analyze any complex influence case, adopt this playbook: start with SAR flags; subpoena upstream and downstream accounts; diagram flows (origin, intermediaries, end-beneficiaries); label each node with dates and documents; then probe for service evidence that would justify the fees. When labels like “loan” appear, look for promissory notes, interest schedules, and repayments. When timing aligns with high-level meetings or travel (e.g., Air Force Two introductions to Jonathan Li), ask whether access—not expertise—was the true product. That disciplined sequence transforms isolated transactions into a testable narrative.

You can’t understand the book’s argument without the Hunter Biden laptop saga because it’s both a source of evidence and a story about narrative power. Comer presents the laptop as a trove—emails, texts, contracts, photos—that match or clarify bank transfers flagged in SARs. Yet in 2020, when the New York Post first reported on it, Twitter throttled distribution, Facebook downranked it, and 51 former intelligence officials publicly framed it as potential Russian disinformation. Comer argues that this alignment of platform moderation and elite signaling muted scrutiny during the election window.

From suppression to verification

The narrative shifts as evidence accumulates. John Paul Mac Isaac, the Delaware repair shop owner, becomes the unlikely custodian whose materials eventually reach journalists and lawmakers. Over the next two years, reporters like CBS’s Catherine Herridge commission forensic reviews; by early 2023, Comer cites CBS confirming authenticity of key data. Meanwhile, Elon Musk’s Twitter Files expose internal debates and government-linked contacts around moderation decisions. Regardless of your politics, the practical effect is clear: what the public hears first often hardens into conventional wisdom, and course-corrections arrive late.

Why the laptop mattered to investigators

For you as a reader, think of the laptop as a Rosetta Stone. It contains bank letters (e.g., the May 2014 RSB instruction calling Hunter the “beneficial owner”), contracts, and message threads that help match dollars to decisions. When bank records show a $1,000,000 wire to Owasco PC for legal work tied to CEFC’s Patrick Ho (later convicted of FCPA offenses), messages and contacts in the trove help confirm who negotiated what and when. The DOJ’s later use of laptop content in the 2024 gun-case prosecution underscores that at least portions of the data met evidentiary standards (Note: chain-of-custody arguments persist over subsets of files, but multiple outlets have validated core material).

Media dynamics and institutional frictions

Comer devotes space to the media landscape: he criticizes mainstream outlets (NYT, CNN, MSNBC) for skepticism he deems excessive, and he spotlights friendly platforms that aired document scans and depositions. He also recounts CBS’s seizure of Catherine Herridge’s files during a corporate dispute—alleging that control over materials briefly shifted to a newsroom hostile to the investigation before pressure forced their return. Whether you agree with his framing, the episodes show how editorial control and timing can tilt public understanding, even when underlying documents are unaltered.

Separating three layers of “disinformation” claims

The book asks you to disaggregate: (1) initial press narratives that framed the laptop as dubious; (2) platform policies that suppressed distribution in real time; and (3) forensic analyses that later verified authenticity. Comer argues the first two created a durable misunderstanding that wasn’t undone by the third. The result, he says, was a lost year (or more) for investigators and voters. This is the enduring lesson: in high-velocity information wars, platforms can pre-empt the evidentiary process by shaping what you see when it matters most (In The Twitter Files and related hearings, staffers themselves conceded moderation missteps).

Key idea

Treat primary documents as anchors. Verify, then triangulate. Do not outsource certainty to trendlines on your feed or to letters by unnamed signatories.

Practical takeaway for you

When you evaluate any contested cache—emails, devices, leaks—ask three questions: Who vouches for authenticity and how (forensics, hash matches, corroborating bank data)? Who controls dissemination (platform policies, newsroom editors)? And what do time-stamped ledgers say when aligned with the cache? Those steps help you resist both credulity and cynicism. Comer’s point isn’t simply that the laptop is real; it’s that processes for validating and sharing it were warped at the very moment when scrutiny counted most.

The CEFC thread reads like a primer on state-adjacent influence. You meet Ye Jianming, CEFC’s chairman, presented here as tied to Chinese Communist Party priorities and Belt and Road aims. CEFC’s U.S.-facing emissary Gongwen “Kevin” Dong appears alongside intermediaries James Gilliar and Rob Walker. The book argues that CEFC vehicles—Northern International Capital, State Energy HK—wired millions into joint ventures and Delaware LLCs that benefited Hunter and Jim Biden, often through Hudson West III and Owasco PC. The committee casts CEFC not as a normal energy investor but as a geopolitical instrument seeking “returns” beyond profit.

The wires that matter

On August 8, 2017, Northern International Capital wired $5 million to Hudson West III. That same day, Hunter moved $400,000 to Owasco PC; subsequent flows reached Jim Biden’s Lion Hall Group (approx. $76,000). Earlier, State Energy HK wired $3 million to Robinson Walker LLC (March 1, 2017), later split into disbursements totaling about $1.065 million to Biden family members over ten weeks. Another CEFC-linked entity, CEFC Infrastructure (organized by Kevin Dong), received a $10 million injection in June 2017, with $100,000 moving to Owasco PC on August 4, 2017. These are the ledger entries Comer says reveal a foreign-origin funnel routed through layers.

SinoHawk vs. Hudson West: the bypass claim

Tony Bobulinski, introduced as CEO of SinoHawk (the initial JV with the Bidens), testifies that he expected CEFC capital to flow through SinoHawk with transparent governance. Instead, he says, the Bidens set up parallel structures—especially Hudson West III—to route money outside SinoHawk’s controls. Bobulinski also asserts that Joe Biden was the “big guy” entitled to 10% equity in a CEFC deal. The book treats this as blockbuster corroboration, supported by emails and texts (Note: Hunter and Jim Biden deny Bobulinski’s account; critics say the “big guy” line is ambiguous and not tied to official acts).

Patrick Ho and the legal cloud

Patrick Ho, described as CEFC’s No. 2, was arrested and later convicted of international bribery and money laundering. Bank records show a $1 million wire to Owasco PC for Ho’s legal representation. The committee uses Ho’s case and CEFC’s global profile to argue that the money environment surrounding the Bidens was not ordinary private equity, but one freighted with Foreign Corrupt Practices Act exposure and state-linked agendas. The argument doesn’t hinge on Joe Biden’s direct involvement; it turns on systemic risk and access monetization within his family’s network.

Ye Jianming’s disappearance and investigative limits

In 2018, Ye reportedly vanished into PRC custody. Comer speculates that Ye’s knowledge of payments made him either a liability or leverage point inside China’s system. Practically, his absence deprived Congress and U.S. prosecutors of a central witness. You see the constraint: the most probative sources may be unreachable, and subpoenas stop at national borders. The committee thus leans even more heavily on bank ledgers and domestic witnesses to draw inferences about CEFC’s intent (Note: Without Ye, definitive statements about CCP direction remain interpretive, though CEFC’s internal party organs are cited as markers of state alignment).

Key idea

When capital from an authoritarian, state-embedded firm flows into family-controlled LLCs through opaque paths, you must evaluate not just legality but exposure: leverage, kompromat risk, and policy externalities.

How you read CEFC patterns

Apply a due-diligence lens. Ask: Who sits behind the funds? What internal party organs exist? Which accounts receive inflows and who controls them? Do transfers align with meetings, speeches, or travel (e.g., Air Force Two introductions to Jonathan Li)? Are “fees” supported by work product? On each point, Comer argues CEFC fails normal governance tests. Even if you dispute intent, the paper trail suggests sophisticated layering—a hallmark of influence operations and financial-crime risk.

The Burisma chapter shows how a single corporate account—Rosemont Seneca Bohai (RSB)—can link emails, bank wires, and sworn testimony into a tight evidentiary package. If you only remember one exhibit, make it the May 14–15, 2014 bank-letter exchange: Burisma’s Vadym Pozharskyi asks for payment instructions; a finalized letter directs monthly fees to the RSB bank account and explicitly calls Hunter Biden the “beneficial owner.” The phrasing matters. In beneficial ownership regimes, who truly controls the money often trumps whose name sits on a signature card.

Paperwork beats denials

After Hunter Biden’s 2024 deposition distanced him from RSB—claiming he had no position or control—whistleblower disclosures surfaced an April 29, 2014 corporate resolution showing Hunter signing as “Secretary” of RSB to authorize a $142,300 car purchase (the same amount wired by Novatus Holdings). Bank records corroborate Burisma’s monthly wires landing in RSB—often as twin entries of $83,333.33 each. Devon Archer’s testimony supports the split: one for him, one for Hunter. The RSB corporate card, the committee says, also covered about $40,000 in Hunter’s travel and expenses. When you stack these, paperwork and payments contradict deposition distancing.

Tracing the money to benefit

From April 2014 to October 2015, the committee traces over $1.7 million from Burisma to Hunter via RSB and later through Owasco PC. The case does not solely hinge on titles; it turns on benefit, control, and intent. If a letter names you the beneficial owner, and if you sign as an officer authorizing high-value purchases, and if bank statements show consistent inflows and outflows aligned with your personal or corporate accounts, then benefit and control are evidenced even if you deny formal positions later.

Context and pushback

Defenders argue that Burisma paid for reputation and legal strategies common in frontier markets, that RSB was a convenient conduit, and that there’s no proof Joe Biden altered U.S. policy in exchange. Comer counters that formalizing payments into RSB while maintaining public ambiguity around roles suggests a deliberate attempt to shield optics, if not law. The committee uses the RSB episode as grounds for criminal referrals under 18 U.S.C. § 1001 (false statements) and, for Hunter, under § 1621 (perjury), claiming sworn denials were materially contradicted by documents.

What you learn about method

RSB teaches a simple rule: when testimony and documents collide, default to the ledger and signed instruments. The committee’s approach—obtain the letter naming the account, tie it to the corporate resolution showing authority, match those to monthly bank entries—builds a chain you can evaluate independent of rhetoric. This document-first posture can clarify any white-collar case where corporate veils and memory lapses complicate the picture (Note: Think Enron’s SPE structures or Theranos’s contradictory memos; paperwork ultimately anchored the outcomes).

Key idea

Beneficial ownership is the hinge. If you control where the money lands and how it’s spent, titles and press lines matter less than the transactions themselves.

Applying it yourself

If you audit any complex relationship, ask for: (1) bank instruction letters, (2) corporate resolutions around big-ticket purchases, (3) recurring invoice/payment pairs, and (4) credit-card statements tied to the corporate account. Those four items can pierce ambiguity fast. In Burisma–RSB, all four exist, which is why this chapter becomes a cornerstone of the committee’s perjury and false-statement referrals.

The final arc explains how institutional dynamics, witness management, and political theater shape outcomes as much as facts. If the bank records are the engine, depositions and hearings are the wheels, and media dynamics are the road conditions. Comer’s playbook is straightforward: secure SAR access, subpoena banks, depose key associates and family members, hold public hearings at inflection points, and issue criminal referrals when testimony contradicts documents. The goal is dual: build a prosecutable record and sustain public attention so stonewalls can’t bury the story.

Witnesses and contradictions

You meet a cast with competing motives. Tony Bobulinski delivers headline claims—Joe Biden as the “big guy,” CEFC as CCP-backed—supported by texts and emails, but contested by Hunter and Jim Biden. Devon Archer confirms equal Burisma splits and paints Hunter as a “brand” and access broker. Eric Schwerin admits to unpaid bookkeeping for Joe Biden and acknowledges pseudonym emails, softening claims of a hard wall between official duties and family business. Jason Galanis (a convicted felon) offers additional context on Harvest/Bohai structures. These testimonies, contradictory as they may be, become probes to test against the ledger.

FBI/DOJ frictions and the FD-1023 fight

IRS whistleblowers Gary Shapley and Joseph Ziegler describe being constrained from pursuing certain lines (e.g., questions about Joe Biden), lacking access to laptop materials, and seeing investigative decisions narrowed. Comer recounts confrontations with FBI Director Christopher Wray over an FD-1023 alleging a Ukrainian bribe; after initial resistance, the Bureau allowed a SCIF viewing—but with heavy redactions. Later, when informant Alexander Smirnov was indicted for lying, critics said it discredited the entire inquiry. Comer replies that the bank-led evidence stands on its own and that FD-1023 was one thread, not the spine.

Hearings, deposits, and legal escalation

Hunter Biden’s February 28, 2024 deposition yields admissions (millions from China; CEFC gifts like a diamond; introducing Jonathan Li to Joe Biden on Air Force Two; speakerphone calls with his father during business conversations) alongside lapses attributed to addiction and memory. The March 20, 2024 public hearing spotlights Bobulinski and Galanis, generating viral exchanges with Democrats like Jamie Raskin and AOC. Following these, on June 5, 2024, the committee issues criminal referrals against Hunter and James Biden for false statements (and perjury against Hunter), citing mismatches between testimony and documents.

Politics, media, and timing

Institutional turbulence matters. The ouster of Speaker McCarthy and delays in electing a successor cost weeks of subpoena leverage. Media framing often emphasized spectacle over spreadsheets, forcing the committee to release bank memos and graphics to refocus attention. The Hur special counsel report—described by Comer as a “whitewash” because it declined to prosecute President Biden for willful retention of classified documents while citing jury sympathy—becomes, in his telling, another example of elite impunity (Note: Hur’s reasoning is hotly debated; supporters see it as a standard application of prosecutorial discretion).

Key idea

In congressional probes, facts must survive procedure. Subpoena power, committee unity, and communication strategy can determine whether documents translate into accountability.

Your takeaway on process

If you lead or follow complex investigations, plan for parallel tracks: legal (subpoenas, depositions, referrals), evidentiary (bank records, device data, emails), and narrative (briefings, exhibits, press). Anticipate institutional resistance and build redundancies—multiple witnesses, cross-committee coordination (Oversight, Judiciary, Ways and Means), and external validators (forensic audits). And remember the central discipline emphasized throughout the book: return to the ledger when testimony wobbles and when media storms rage. That is how you keep the spine intact.