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The U.S. Offshore & Financial Crime Index: 2026 Update

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The U.S. Offshore & Financial Crime Index: 2026 Update

Date: February 15, 2026
Source Compilation: Public Records, DOJ, IRS-CI, OFAC, FinCEN, ICIJ

Executive Summary

This report provides a structured overview of newly documented offshore-linked financial crime cases and enforcement actions connected to the United States between 2024 and early 2026. The data integrates official sources including the Department of Justice (DOJ), IRS Criminal Investigation (IRS-CI), Office of Foreign Assets Control (OFAC), Financial Crimes Enforcement Network (FinCEN), and the ICIJ Offshore Leaks database.

Key Trends:

ยท Cryptocurrency as a Vector: Significant prosecutions of mixing services (Samourai Wallet) and scam laundering (Daren Li) show increased scrutiny of digital assets.
ยท Transnational Crime: The designation of the Cambodia-based Prince Group as a Transnational Criminal Organization (TCO) highlights the scale of online fraud targeting Americans.
ยท Foreign Influence: High-profile cases like that of former NY aide Linda Sun underscore efforts to combat undisclosed foreign influence and money laundering.
ยท Regulatory Surge: DOJ sanctions prosecutions nearly doubled from 2023 to 2024, and FinCEN continues aggressive enforcement across traditional and crypto financial sectors.

Part I: Cryptocurrency Laundering Networks

  1. Samourai Wallet: Crypto Mixing Service Prosecuted

The founders of Samourai Wallet, a cryptocurrency mixing service designed to obfuscate transactions, were sentenced in late 2025 for laundering over $2 billion, including hundreds of millions in criminal proceeds.

ยท Entity: Samourai Wallet
ยท Founders: Keonne Rodriguez (CEO), William Lonergan Hill (CTO)
ยท Platform Functions: “Whirlpool” (mixing), “Ricochet” (obfuscation)
ยท Criminal Sources Laundered: Drug trafficking, darknet marketplaces, cyber intrusions, fraud schemes, sanctioned jurisdictions, and murder-for-hire schemes.
ยท Financial Impact:
ยท Total Processed: Over $2 billion
ยท Criminal Proceeds Identified: $237+ million
ยท Forfeiture Order: $237,832,360.55
ยท Sentencing (November 2025):
ยท Keonne Rodriguez: 5 years prison, $250,000 fine.
ยท William Lonergan Hill: 4 years prison, $250,000 fine.
ยท Source: IRS – Samourai Wallet Founders Sentenced

  1. AML Bitcoin: Fraudulent Cryptocurrency Scheme

The founder of “AML Bitcoin” was sentenced for defrauding investors with false claims about the cryptocurrency’s technology.

ยท Founder/CEO: Rowland Marcus Andrade
ยท Charges: Wire fraud, money laundering
ยท Court Outcome: Convicted March 2025; Sentenced July 29, 2025, to 7 years (84 months) federal prison.
ยท Scheme: Raised millions through false and misleading statements to investors about the company’s technology.
ยท Source: IRS – AML Bitcoin Sentencing

  1. Daren Li: Laundering for Pig-Butchering Scams

A dual Chinese and St. Kitts & Nevis national was sentenced to 20 years for orchestrating the industrial-scale laundering of proceeds from “pig-butchering” cryptocurrency investment scams.

ยท Defendant: Daren Li (Age 41)
ยท Scheme: Pig-butchering cryptocurrency fraud.
ยท Financial Scale: $74 million laundered.
ยท Methodology: Nearly $60 million was funneled through U.S.-based shell companies and converted to cryptocurrency.
ยท Sentence: 20 years federal prison (Plea: November 12, 2024).
ยท Source: TRM Labs – Daren Li Sentencing

Part II: Foreign Influence & Political Corruption

  1. Linda Sun: Chinese Government Influence Operation

A former high-ranking New York state aide’s trial for acting as an unregistered agent of the Chinese government ended in a mistrial, with prosecutors seeking a retrial.

ยท Primary Individual: Linda Sun
ยท Role: Former Deputy Chief of Staff to NY Gov. Kathy Hochul; Deputy Diversity Officer under Gov. Andrew Cuomo.
ยท Background: Naturalized U.S. citizen, born in Nanjing, China.
ยท Spouse/Co-Conspirator: Chris Hu (Charged with money laundering, bank fraud, tax evasion).
ยท Charges: Originally 8 counts, expanded via superseding indictments (Feb & June 2025) to 19 counts, including foreign agent conspiracy, visa fraud, money laundering, wire fraud, and bribery.
ยท Alleged Benefits from Chinese Government:
ยท Millions of dollars in payments.
ยท All-expenses-paid trips to China.
ยท VIP tickets to events.
ยท Gifts, including Nanjing-style salted ducks.
ยท Assets Seized:
ยท Long Island home.
ยท Hawaii condominium ($1.9 million).
ยท Ferrari and other luxury cars.
ยท Case Status: Arrested September 3, 2024. Trial in late 2025 ended in a mistrial (hung jury). Prosecutors are seeking a retrial.
ยท Sources: AP News, NBC News

Part III: Transnational Criminal Organizations (TCOs)

  1. Prince Group: Cambodia-Based Scam Network Sanctioned

In October 2025, the U.S. designated Prince Holding Group, a conglomerate based in Cambodia, and its leader as a Transnational Criminal Organization for its role in large-scale online fraud and human trafficking.

ยท Organization: Prince Group (Prince Holding Group)
ยท Leader: Chen Zhi (aka “Duke”)
ยท DOB: December 16, 1987
ยท POB: Fujian, China
ยท Citizenships: Cambodia, Vanuatu, Cyprus
ยท U.S. Actions (October 14, 2025):
ยท OFAC Sanctions: 146 persons and entities designated.
ยท FinCEN Section 311: Huione Group severed from the U.S. financial system.
ยท UK Sanctions: Coordinated action on 6 entities and 6 individuals.
ยท Financial Impact:
ยท Americans lost to online scams in 2024: $16.6 billion (approx. $10 billion tied to SE Asia).
ยท Singapore asset seizure: S$150 million ($115.9 million).
ยท Hong Kong frozen assets: HK$2.75 billion ($354 million).
ยท Taiwan seized assets: T$4.5 billion ($147.09 million).
ยท Criminal Activities: “Pig-butchering” investment fraud, illegal online gambling, money laundering, sextortion, forced labor, human trafficking.
ยท Key Compounds: Jin Bei Casino and 10+ other scam compounds controlled by the group.
ยท Sources: Treasury.gov – TCO Designation, Steptoe – Sanctions Update

Part IV: International Money Laundering Networks

  1. Chinese Money Laundering Organization: Drug Proceeds

A Chinese-run money laundering organization pleaded guilty in April 2025 to laundering over $92 million in drug trafficking proceeds imported from Mexico.

ยท Amount Laundered: $92+ million (from drug trafficking via Mexico).
ยท Defendants:
ยท Maoxuan Xia (Chinese): Money laundering conspiracy.
ยท Shao Neng Lin (California citizen): Money laundering conspiracy.
ยท Zhou Yu (Chinese): Money laundering conspiracy.
ยท Methodology: Used shell company bank accounts to collect and deposit drug proceeds. Xia traveled within the U.S. to move cash; Lin and Yu opened the bank accounts.
ยท Potential Sentences: Up to 20 years per count.
ยท Source: Mofo – Anti-Money Laundering Quarterly

Part V: Major Fraud & Financial Crime Cases

  1. Hansen Helicopters: Illicit Aviation Scheme

The CEO of a Guam helicopter company was sentenced to over 33 years for running an illicit business using unregistered aircraft.

ยท CEO: John Walker (Hansen Helicopters Inc.)
ยท Sentence: 405 months (33.75 years) in prison.
ยท Forfeiture: $58.4 million.
ยท Scheme: Operation of an illicit helicopter business with unregistered/illegal aircraft.

  1. Dallas Investment Fraud: Fictitious Businesses

A Dallas man was sentenced to 20 years for running an investment fraud scheme through fictitious businesses.

ยท Defendant: Rahool Amin Makani (Dallas, Texas)
ยท Sentence: 20 years in prison.
ยท Restitution: Over $14 million.
ยท Scheme: Investment fraud using fictitious businesses.

  1. North Korean IT Worker Fraud Operation

An Arizona woman was sentenced for helping North Korean IT workers infiltrate over 300 U.S. companies using stolen identities.

ยท Defendant: Christina Marie Chapman (Arizona)
ยท Sentence: 102 months (8.5 years) in prison.
ยท Scope: 300+ U.S. companies infiltrated; identities of ~70 U.S. citizens stolen.
ยท Scheme: Facilitated remote employment for North Korean workers, generating revenue for the DPRK.

  1. Pandemic Fraud: “Feeding Our Future” (Minnesota)

Listed as one of the IRS’s top cases of 2025, this case involves one of the largest pandemic relief fraud schemes in Minnesota, with multiple defendants connected to federal relief programs. (Source: IRS – Top 10 Cases 2025)

Part VI: Offshore Corporate Structures (ICIJ Data)

The ICIJ Offshore Leaks database (Panama Papers, Paradise Papers, Pandora Papers) continues to document the use of secrecy jurisdictions by corporations and individuals with U.S. connections.

Companies with U.S. Links (BVI/Cayman/Panama)

ยท WOOSTER BUSINESS LIMITED (BVI) -> United States
ยท INTERMEDIA LTD. (Cayman) -> United States
ยท WELLINGTON ENTERPRISES LIMITED (Cayman) -> United States
ยท GLOBAL BUSINESS SOLUTIONS, GROUP INC. (BVI) -> Multiple
ยท SOUTHWEST COMPANY CORP. (Panama) -> Brazil

Major Corporations with Offshore Structures

ยท APPLE: Irish subsidiaries via BVI/Cayman.
ยท META (Facebook): BVI entities.
ยท GOOGLE-ALPHABET: Holding companies.
ยท MICROSOFT: Patent/royalty structures.
ยท AMAZON: European operations.
ยท UBER: European holdings.
ยท Nike: Tax optimization structures.
ยท Twitter: BVI entities.

Sources: ICIJ Offshore Leaks Database, Wikipedia – Pandora Papers

Part VII: Regulatory Enforcement Trends (2024-2025)

U.S. regulatory agencies have significantly ramped up enforcement across sanctions, anti-money laundering, and foreign investment.

ยท OFAC Enforcement:
ยท 2024: 12 enforcement actions, totaling $48.8 million in penalties. Focus: Russia-related sanctions, SDN evasion.
ยท 2025: 14 enforcement actions (as of Feb 2026).
ยท DOJ Sanctions Prosecutions:
ยท 2023: ~38 charges filed.
ยท 2024: 70+ charges filed (nearly doubled).
ยท Notable FinCEN Enforcement Actions (2024-2025):
ยท PAXFUL, INC. (Dec 2025): Money Services Business (MSB) enforcement.
ยท BRINK’S GLOBAL SERVICES USA (Jan 2025): Money services.
ยท SAHARA DUNES CASINO (Oct 2024): Casino AML violations.
ยท TD BANK (Oct 2024): Depository institution AML failures.
ยท BINANCE HOLDINGS (Nov 2023): Major MSB enforcement.
ยท CFIUS Enforcement (2024): Penalty authority increased; stricter scrutiny of foreign investments.
ยท Corporate Transparency Act (CTA): Implementation of beneficial ownership reporting is ongoing but partially delayed due to litigation. New AML obligations were added in 2024 for investment advisers and non-finance real estate transactions.

Sources: Crowe – Enforcement Trends 2025, FinCEN, Treasury – CFIUS

Part VIII: Key Individuals Summary

Sentenced (2024-2025)

Name Entity/Case Sentence Status
Keonne Rodriguez Samourai Wallet 5 years In prison
William Lonergan Hill Samourai Wallet 4 years In prison
Rowland Marcus Andrade AML Bitcoin 7 years Began Oct 2025
Daren Li Crypto Scam Laundering 20 years In prison
Rahool Amin Makani Investment Fraud 20 years In prison
John Walker Hansen Helicopters 405 months (33.75 yrs) In prison
Christina Marie Chapman North Korean IT Fraud 102 months (8.5 yrs) In prison

Awaiting Trial / Pleaded Guilty

Name Charges Status
Linda Sun Foreign agent, money laundering (19 counts) Mistrial; retrial sought
Chris Hu Money laundering, bank fraud, tax evasion Mistrial; retrial sought
Maoxuan Xia Money laundering conspiracy Guilty plea (Apr 2025)
Shao Neng Lin Money laundering conspiracy Guilty plea (Apr 2025)
Zhou Yu Money laundering conspiracy Guilty plea (Apr 2025)

Sanctioned / Fugitives

Name Role Status
Chen Zhi Prince Group Leader Sanctioned (Oct 2025); Status: Arrested in Cambodia (Nov 2025)
146 Individuals/Entities Prince Group Network Sanctioned by OFAC

Summary Statistics

Category Count / Value
Major Cryptocurrency Cases 3 (Samourai, AML Bitcoin, Daren Li)
Major Foreign Influence Cases 1 (Linda Sun – 19 counts)
Transnational Criminal Organizations 1 (Prince Group – 146 sanctioned)
Money Laundering Networks 1 (Chinese drug money – $92M)
DOJ Sanctions Charges (2024) 70+
Total OFAC Actions (2024-2025) 26
Americans Lost to Scams (2024) $16.6 billion
Total New Entities/Individuals Profiled 150+

Report Date: February 15, 2026
Data Sources: U.S. Department of Justice, IRS Criminal Investigation, U.S. Treasury (OFAC), FinCEN, ICIJ Offshore Leaks Database, Federal Court Filings.



Bernd Pulch โ€” Bio
Bernd Pulch โ€” Bio Photo

Bernd Pulch (M.A.) is a forensic expert, founder of Aristotle AI, entrepreneur, political commentator, satirist, and investigative journalist covering lawfare, media control, investment, real estate, and geopolitics. His work examines how legal systems are weaponized, how capital flows shape policy, how artificial intelligence concentrates power, and what democracy loses when courts and markets become battlefields. Active in the German and international media landscape, his analyses appear regularly on this platform.

Full bio โ†’ | Support the investigation โ†’

The Epstein Financial Network: What the Verified Records Show

https://rumble.com/v76b80i-290-million-158-million-1.5-billion-the-epstein-financial-network-explained.html

By INVESTIGATIVE DESK
February 26, 2026

More than six years after Jeffrey Epstein’s death in federal custody, the full scope of his financial and social network continues to emerge through court records, regulatory actions, and congressional investigations. Unlike unverified documents circulating online, the following account is based on official sources: court filings, government settlements, regulatory fines, and congressional correspondence.

THE JEFFREY EPSTEIN INDEX PROJECT HUB

The Banking Infrastructure

JPMorgan Chase: $290 Million Settlement

In June 2023, JPMorgan Chase reached a $290 million settlement with sexual abuse victims of Jeffrey Epstein, resolving a class-action lawsuit filed in November 2022 . The lawsuit alleged that the nation’s largest bank ignored repeated red flags about Epstein’s sex-trafficking operation while he was a client from approximately 1998 to 2013 .

U.S. District Judge Jed Rakoff approved the settlement in November 2023, noting that nearly 200 victims could receive compensation . The settlement followed months of embarrassing disclosures about how top JPMorgan executives maintained Epstein as a client despite numerous warning signs .

Separately, JPMorgan agreed in September 2023 to pay $75 million to the U.S. Virgin Islands to settle claims related to Epstein’s operations from his private island in the territory .

Deutsche Bank: $150 Million Fine

In July 2020, Deutsche Bank agreed to pay a $150 million fine to New York’s Department of Financial Services for “significant compliance failures” in its relationship with Epstein . The bank worked with Epstein from 2013 to 2018โ€”after JPMorgan dismissed him .

New York regulators found that Deutsche Bank processed hundreds of transactions totaling millions of dollars that should have triggered scrutiny . These included payments to Russian models, $800,000 in “suspicious” cash withdrawals, and more than $7 million to resolve legal issues .

“Whether or to what extent those payments or that cash was used by Mr. Epstein to cover up old crimes, to facilitate new ones, or for some other purpose are questions that must be left to the criminal authorities, but the fact that they were suspicious should have been obvious to bank personnel at various levels,” the regulator stated .

Deutsche Bank acknowledged its error, with CEO Christian Sewing calling it a “critical mistake” to accept Epstein as a client . The bank later agreed to pay $75 million to Epstein’s victims in a separate settlement .

Leon Black and the $158 Million Question

Documented Payments

Wall Street financier Leon Black paid Jeffrey Epstein approximately $158 million between 2012 and 2017 . According to an independent review conducted by the law firm Dechert for Apollo Global Management, these payments were for tax and estate planning services .

The Dechert review concluded that Black “had not engaged in any wrongdoing” and “had no awareness of Epstein’s criminal activity,” with all fees “for legitimate tax, estate and philanthropy planning services” that were “vetted and approved by outside law firms” .

However, Senate Finance Committee Ranking Member Ron Wyden has raised serious questions about the arrangement. In a July 2025 letter to IRS Commissioner Billy Long, Wyden noted that the payments helped Black avoid more than $1 billion in future estate tax liabilities .

Irregularities in the Arrangement

According to Wyden’s investigation, the majority of paymentsโ€”approximately $100 millionโ€”were made on an “ad hoc” basis without any written contract or business services agreement . The payments far exceeded what Black paid other professional advisors, including “some of the most renowned legal counsel in the nation” .

At an annualized rate of $34 million per year, Epstein’s compensation was double the median CEO pay for Fortune 500 companies . Yet Epstein lacked any professional training or certifications in accounting or tax law .

Black’s attorneys acknowledged to Wyden’s investigators that “not all of Epstein’s advice was useful” and that his ideas “would appear plausible at face value, but did not hold up under scrutiny” . In one instance involving a $20 million payment for a “step-up basis transaction,” Black’s attorneys stated the idea “was in the public domain and originated with his other legal advisors,” adding that “Epstein tried to take credit for the idea and secure compensation” .

U.S. Virgin Islands Settlement

In January 2023, Black agreed to pay $62.5 million to the U.S. Virgin Islands. The settlement agreement stated that Epstein “used the money Black paid him to partially fund his operations in the Virgin Islands” .

IRS Investigation Question

Despite these documented irregularities, Black’s attorneys confirmed in writing to Wyden’s investigators that the tax transactions at issue have “not been reviewed by the Internal Revenue Service as part of an audit” .

Wyden called this “unthinkable,” stating: “When Americans think the system is rigged, this is the kind of abuse they think about. While average Americans are regularly audited, it appears that the IRS will simply look the other way in cases involving billionaires” .

Bill Clinton: Flight Records and Congressional Testimony

Documented Flights

Flight logs show that former President Bill Clinton traveled on Epstein’s private aircraft at least 16 times between 2001 and 2004 . Destinations included domestic U.S. locations as well as Hong Kong, Singapore, Beijing, and London .

Some flights were taken with Epstein and his former girlfriend Ghislaine Maxwell . Clinton has maintained that he knew nothing of Epstein’s criminal activities and cut ties before Epstein’s 2019 arrest .

Emails in Released Documents

The Department of Justice’s January 2026 document release included emails between Clinton’s staff and Maxwell. In one 2001 exchange, Clinton aides asked Maxwell for contact information for Prince Andrew to coordinate a golf outing in Scotland .

Other emails contained crude language. In one, Maxwell told a Clinton staff member she had told a tabloid reporter about Clinton’s purported sexual prowess, adding: “Hope you don’t mind!” Clinton’s spokesperson has stated that the former president “almost never emailed” and never shared devices or accounts with anyone, though the spokesperson could not identify who actually sent the emails .

Upcoming Congressional Depositions

After months of negotiations and a threatened contempt vote, Bill and Hillary Clinton have agreed to testify before the House Oversight Committee . Hillary Clinton’s deposition is scheduled for February 26, 2026, in Chappaqua, New York, with Bill Clinton appearing on February 27 .

The depositions will cover five agreed-upon topics: mismanagement of the federal investigation into Epstein and Maxwell; circumstances of Epstein’s 2019 death; methods to combat sex-trafficking rings; how Epstein and Maxwell sought to protect their illegal activities; and potential ethics violations by elected officials .

Rep. James Comer, the committee chairman, emphasized: “No one is accusing the Clintons of any wrongdoing. We just have a lot of questions” .

Bill Clinton has never been accused by law enforcement of any wrongdoing related to Epstein .

The January 2026 Document Release

What Was Released

On January 30, 2026, the Department of Justice released more than 3 million pages of documents related to Epstein, along with approximately 180,000 images and thousands of videos . The release was mandated by legislation passed in late 2025 requiring the government to publish its Epstein files .

Controversy Over Redactions

Victims and some lawmakers have expressed frustration that many documents remain heavily redacted . NPR reported on February 24, 2026, that some documents related to allegations against President Donald Trump may have been withheld .

According to reports, the unpublished documents include FBI notes summarizing 2019 interviews with a woman who alleged she was sexually assaulted decades ago as a minor by both Epstein and Trump . Of four interviews conducted, only one summaryโ€”related to allegations against Epsteinโ€”has been made public .

Democratic lawmakers on the House Oversight Committee stated they “can confirm that the Justice Department appears to have unlawfully concealed FBI interviews” with the alleged victim .

Justice Department Response

The Justice Department responded that “NOTHING has been removed” from the public database, clarifying that only duplicate documents, those under court order not to be released, or materials part of ongoing federal investigations have not been published . The department stated it is reviewing files that may have been misclassified and will release any that meet legal criteria .

Trump, who once moved in the same social circles as Epstein, has denied any knowledge of Epstein’s criminal activity and stated he severed relations before legal proceedings began .

Epstein’s Criminal History

2008 Conviction

In 2008, Epstein pleaded guilty in Florida state court to two felony charges: soliciting prostitution and soliciting prostitution from a minor . This stemmed from a Palm Beach investigation that identified multiple underage victims . He served 13 months in county jail under a controversial work-release arrangementโ€”his only criminal conviction during his lifetime .

2019 Federal Indictment

In July 2019, federal prosecutors in the Southern District of New York charged Epstein with sex trafficking of minors and conspiracy to commit sex trafficking . The indictment alleged he recruited and paid underage girls for sexual acts in New York and Florida between 2002 and 2005 .

Prosecutors also alleged that Epstein transported minors between his properties for illegal sexual activity and maintained residences where such activity occurred . Epstein pleaded not guilty and died in custody on August 10, 2019, before trial. His death was determined to be suicide .

Ghislaine Maxwell

Epstein’s longtime associate Ghislaine Maxwell was arrested in July 2020 and later convicted on sex trafficking charges. She is serving a 20-year prison sentence .

Ongoing Investigations

Treasury Department Records

Senator Wyden’s investigation has identified 4,725 wire transfers documented in suspicious activity reports related to Epstein, totaling more than $1.5 billion . Some banks filed these reports years after the transactions occurred .

Wyden has urged the Justice Department to subpoena records from Bank of America, JPMorgan Chase, and Deutsche Bank .

DEA Investigation Questions

A 2015 memo in the DOJ files shows the Drug Enforcement Administration opened an investigation into nearly $50 million in suspicious wire transfers involving Epstein and 14 other targets, starting in December 2010โ€”two years after his non-prosecution agreement . The disposition of this investigation remains unclear.

Documented Payments and Settlements: Summary

Entity Amount Year Basis
JPMorgan Chase (victims) $290 million 2023 Class-action settlement
JPMorgan Chase (USVI) $75 million 2023 Territorial settlement
Deutsche Bank (regulatory) $150 million 2020 NYDFS fine
Deutsche Bank (victims) $75 million 2023 Victim settlement
Leon Black (to Epstein) $158 million 2012-2017 Documented payments
Leon Black (USVI) $62.5 million 2023 Territorial settlement

Sources and Methodology

This article is based on:

ยท Official court documents and settlements
ยท Regulatory enforcement actions (NYDFS)
ยท Congressional correspondence and investigations (Senate Finance Committee)
ยท Department of Justice public releases
ยท Reporting from The New York Times, CNN, BBC, and Bloomberg News
ยท Securities and Exchange Commission filings

All information presented has been verified against primary sources or authoritative news organizations. Documents referenced are in the public domain.

โ€”Reporting by the Investigative Desk



Bernd Pulch โ€” Bio

Bernd Pulch (M.A.) is a forensic expert, founder of Aristotle AI, entrepreneur, political commentator, satirist, and investigative journalist covering lawfare, media control, investment, real estate, and geopolitics. His work examines how legal systems are weaponized, how capital flows shape policy, how artificial intelligence concentrates power, and what democracy loses when courts and markets become battlefields. Active in the German and international media landscape, his analyses appear regularly on this platform.

Full bio โ†’ | Support the investigation โ†’

Biden Family Attorneys Lobbied Justice Department to Prosecute IRS Whistleblowers Instead of Hunter | The Gateway Pundit | by Cristina Laila

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