Americans need to know whether Hillary Clinton and Thomas Pickering put America’s interests first, or those of Russia and Iran.

The Clinton campaign has been complaining bitterly about Russian President Vladimir Putin’s possible ties to WikiLeaks’ daily dumps of campaign chairman John Podesta’s emails. My new investigative report, “Clinton’s Shadow Diplomat: Thomas Pickering and Russia’s Pipeline Sales to Iran and Syria, exposes Hillary Clinton’s own damaging ties to Russia and Iran while she was secretary of State. Her Foreign Affairs Policy Advisor Thomas Pickering was a paid director for the Russian company Trubnaya Metallurgicheskaya Kompaniya (TMK) from June 30, 2009 to June 26, 2012. TMK is majority-owned by Russian billionaire oligarch Dmitry Pumpyansky, a close Putin ally.

I discovered extensive proof of TMK’s business dealings in Iran and Syria while Pickering was on its board, including TMK sales of oil and gas pipelines to Iran that were specifically prohibited under U.S. laws and executive orders. Pickering was deeply involved with TMK. According to TMK records, he attended 143 of the 145 board meetings. Pickering is estimated to have been paid more than half a million dollars for his service to TMK from 2009 to 2012, based on TMK’s compensation rules. He has since claimed to have donated it all to an unnamed charity.

Clinton’s, President Obama’s, and Pickering’s interests converged during the time Pickering was on TMK’s board of directors. Clinton had announced the Russian “reset” in March 2009; Obama pleaded with Iran for a new beginning two weeks later; and Pickering joined TMK, which was publicizing its sales to Iran and Syria in numerous documents, in June of that year.

Yes, We Sell to Countries Americans Sanction

Pickering combined his commercial, nonprofit, and policy roles into a seamless whole, all with the common goal of ending economic sanctions against Iran and reversing U.S. Iran policies. He was Clinton’s foreign affairs policy advisor and email correspondent, a board member for two Iranian advocacy groups, a paid consultant to Boeing (now a $25 billion Iranian aircraft contractor, thanks to Pickering’s advocacy), a well-known “behind-the-scenes” negotiator with Iranian representatives, and a paid director for a Russian company—TMK—that was actively exporting pipelines to Iran and Syria.

TMK’s customers and sales were not secret. In marketing materials, legal documents, a tenth anniversary PowerPoint presentation, catalogs, and webpages, TMK openly stated it had “major” and “main” pipeline customers in Iran and Syria. Iranian customer websites named TMK as a vendor. Steelorbis.com, an online steel industry newsletter, published six different reports from 2009 to 2013 listing specific prices for TMK pipes delivered to an Iranian port. Here’s just one example, an excerpt from the February 18, 2011 article published when Pickering was a TMK director:

In a February 5, 2010 $412,500,000 convertible bond offering circular issued by its financing subsidiary TMK Bonds S.A, TMK even formally disclosed that it was selling to Iran and Syria, stating “As a globally operating organization, we also conduct business with customers in Iran and Syria. The U.S. Department of State designates these countries as state sponsors of terrorism and subjects them to export controls.”

TMK’s U.S. division, TMK IPSCO, has plants in Pennsylvania, Texas, Arkansas, Ohio, Iowa, Oklahoma, Nebraska, and Kentucky. TMK pledged its U.S. assets as guarantors for international financing in at least two offers. Several executive orders on Iranian economic sanctions prohibit “any approval, financing, facilitation, or guarantee by a United States person, wherever located, of a transaction by a foreign person [company].”

Were Pickering’s Iran Dealings Illegal?

The Iranian ebusiness website pipeiran.com listed the Khatam-al Anbiya as a client and TMK’s Volzhsky Pipe Plant and TMK’s Romanian Division as vendors. Khatam-al Anbiya is the engineering and construction firm of the Iranian Revolutionary Guard Corps (IRGC). On October 21, Adam Szubin, undersecretary for terrorism and financial intelligence, stated “You cannot do business with IRGC companies….If you do, and you’re doing so knowingly, you are risking the most draconian sanctions in our toolkit, and that governs not just U.S. persons but actors all around the world.”

TMK’s customers in Iran were government-owned companies, and so were the ones in Syria. TMK’s three Iranian customers during the years Pickering served on the board were all listed by the Treasury Department’s Office of Foreign Assets Control (OFAC) as “Specially Designated Nationals”: the National Iranian Oil Company (NIOC), Petropars, and Pars Oil and Gas Company. U.S. persons are generally prohibited from conducting any kind of business with “Specially Designated Nationals.”

Similarly, TMK’s three Syrian customers were listed by OFAC as “Specially Designated Nationals” in 2011, while Pickering was on the Board: the Syrian Gas Company, the Syrian Petroleum Company, and the Al Furat Petroleum Company.

Pickering apparently did not disclose his links to TMK and TMK’s sales to Iran when he testified on Iran before Sen. John Kerry’s Senate Foreign Relations Committee on March 28, 2012 while he was still a TMK director. That information might have been relevant (though it wasn’t legally required) for Kerry’s committee, since in his testimony Pickering recommended that, in return for hypothetical limits on Iran’s nuclear program:

Some freezing or easing of sanctions might be a fair quid pro quo for such steps… It would also help if we begin to consider freezing or relaxing the imposition of some sanctions in return for real progress in making their nuclear program more open and more fully inspected and in improving relations with Iran in other areas …My recommendation is that we now take the sanctions pressure and turn it into a useful diplomatic tool to begin serious diplomatic negotiations with Iran.

It Sure Pays to Work in Government

Emails released from Clinton’s private server show that Pickering was emailing, meeting, and coordinating foreign travel with Clinton and her staff from the beginning of her time as secretary of State and arguing for an end to economic sanctions on Iran all during the same years he was on TMK’s board of directors. Starting in December 2011, he also served in official capacity on Clinton’s Foreign Affairs Policy Board. Clinton appointed Pickering chairman for the Benghazi Accountability Review Board three months after he left TMK.

There’s much more in the investigative report “Clinton’s Shadow Diplomat” on these dangerous liaisons between Clinton and Pickering, and Russia’s pipeline sales to Iran and Syria. The bottom line for the American public and policymakers is this: Did Hillary Clinton and Thomas Pickering put America’s interests first, or those of Russia and Iran?

Pickering’s actions with Hillary Clinton, TMK, various Iranian groups, Boeing and all the rest were not an exception to how Washington insiders operate. Pickering’s actions were an exceptionally well-crafted version of what insiders do every day, and not just in Washington—in Moscow and Tehran, too. Some are just better at it, and Pickering is one of the best. Washington insiders don’t want to blow the whistle on Pickering. They want to be Pickering. And some of them are worse.