Few in the odd coalition of Left and Right pushing for reauthorization of the 81-year-old Export-Import Bank have been louder than Democratic presidential candidate Hillary Clinton.

“It’s wrong that candidates for president, who really should know better, are jumping on this bandwagon,” she said at a May 22 campaign stop in New Hampshire. “It’s wrong, it’s embarrassing. . . . The idea that we would remove this relatively small but vital source of funding for our businesses to compete is absolutely backwards.”


Clinton’s defense of Ex-Im may be motivated by more than mere concern for American businesses. Critics have argued that her family’s byzantine network of political and business interests benefits tremendously from the bank’s low-interest loans, and previous investigations have raised questions about the bank’s independence from the Clintons’ political pressure.

One Ex-Im deal in particular stands out in this regard, both for its sheer size and for its remarkable number of connections to Clinton friends, donors, organizations, and acolytes. From a secretive consulting stint by a top Hillary Clinton aide that’s raised conflict-of-interest concerns, to the Clintons’ close personal and business relationship with the receiving firm’s CEO, the largest loan in the bank’s 81-year history appears covered in Clinton-family fingerprints.

One Ex-Im deal in particular stands out, both for its sheer size and for its remarkable number of connections to Clinton friends, donors, organizations, and acolytes.

The story begins with an alliance between Dow Chemical, a corporation tied closely to the Clintons, and a Saudi Arabian oil company. Dow joined forces with Aramco, a firm owned by the Saudi royal family, in 2011. Together they founded Sadara, a corporate alliance seeking Ex-Im Bank financing for a $20 billion petrochemical plant in the Saudi desert.


Dow CEO Andrew Liveris is a close friend of the Clintons. He first brought his company’s money and clout to the Clinton Global Initiative (CGI) in 2007, during the charity’s early stages. Dow donated between $1 million and $5 million to the CGI in 2014 alone, making it one of the foundation’s top corporate donors, and Liveris is a perennial speaker at annual CGI meetings. When Bill Clinton flew to North Korea to negotiate the release of two captive U.S. journalists, it was Liveris who provided him with transportation.


The former president returned the favor when Liveris launched his own charity, the Hellenic Initiative, in 2012, traveling to Athens to deliver a speech praising the Dow CEO at his charity’s inaugural ball. A year earlier, he had publicly touted Liveris’s book, Make It In America, which argued for an alliance of business and government to reinvigorate American manufacturing.

Liveris’s business ethics have come under increasing scrutiny in recent years. He was accused by Dow’s internal fraud investigators of spending nearly $1 million in company money on personal expenses — including a family safari, a $218,000 Super Bowl trip, and a $300 flower arrangement for Hillary Clinton. Liveris’s family eventually paid most of that money back, but he is now under investigation by the SEC.


Dow Chemical is a client of Teneo Holdings, a powerful consulting firm founded by former Bill Clinton “body man” Doug Band and ex-Hillary Clinton envoy Declan Kelly and staffed heavily with former Clinton Foundation employees. Dow signed with Teneo for $2.8 million shortly after the consultancy set up shop in 2011, the same year that Sadara was founded.


In June 2012, Hillary Clinton’s top confidante, her deputy chief of staff Huma Abedin, quietly arranged to begin work as a “special government employee,” going part-time at Foggy Bottom in order to work simultaneously at Teneo, Dow’s consulting firm. No announcement was made, and State Department officials played along with media outlets still referring to her as Clinton’s deputy chief of staff. The New York Times finally broke the story in May 2013, three months after Abedin had left the consulting firm. (Abedin’s time at Teneo is now under investigation by the State Department, and Iowa Republican senator Chuck Grassley has asked that the department provide all e-mails related to her employment there.)

Around the same time in 2012 that Abedin — who grew up in Saudi Arabia — joined Teneo, Dow’s Saudi subsidiary Sadara began lobbying the U.S. Export-Import Bank for a taxpayer-subsidized loan.


Fred Hochberg, the chairman of the Ex-Im Bank, is a close associate of the Clintons. A long-time friend of the family, he was a political appointee during President Clinton’s tenure and a campaign bundler during Hillary Clinton’s 2008 run, and he’s been a long-time private donor to both Clintons’ political campaigns and the Clinton Foundation. He’s also frequently shared the stage and panel tables with Dow’s Liveris at Clinton Global Initiative conferences.

The Ex-Im Board voted to approve Sadara’s request for a loan on August 22, 2012. By September 27, they had decided on an amount — $4.975 billion, the largest loan in the Ex-Im Bank’s history. Heritage Foundation scholar and Ex-Im Bank expert Diane Katz is surprised by the loan’s size, particularly considering the beneficiaries. “Dow Chemical hardly needs to benefit from subsidies,” she says, “and I suspect that the House of Saud really doesn’t need U.S. taxpayer subsidies.” The Ex-Im Bank describes itself as a “lender of last resort,” providing financing only to companies that cannot fund themselves or earn private financial banking.

Hochberg recused himself on both Sadara votes, something Katz says she’s never seen before. But even so, she says his influence was likely felt in the boardroom. “He’s a player, for sure,” she says. “If he told the board that this is something they ought to do — I certainly think he has influence.”

Some months after the 2012 Ex-Im loan, Dow auditors noticed something peculiar: The company’s payments to Teneo Holdings shot up nearly 600 percent, from $2.8 million in 2011 to $16 million in 2012. Kimberly Wood, the fraud investigator who first discovered the change, said a “lack of required detail” in invoices to Teneo meant it was impossible to discern how the company money was spent. She suspected some of it was being improperly funneled through Teneo to Leveris’s charity, which listed Teneo as a sponsor in 2014. But it’s unclear whether that accounted for the sudden increase in Dow’s payments to the consulting firm.

Neither Teneo Holdings, Dow, nor the Clinton campaign had responded to requests for comment at press time. The Ex-Im Bank initially offered to provide a statement on the circumstances surrounding the loan but hadn’t done so at the time this story was published.

Ex-Im is currently facing the biggest crisis in its history. The federal credit agency’s congressional authority lapsed on June 30, felled by a strange alliance of tea-party Republicans and anti-corporate Democrats arguing relentlessly that it provides the world’s richest companies with corporate welfare and is ridden with fraud, abuse, and crony-capitalist impropriety.

Even some Ex-Im defenders admit that the optics of the Dow deal and the Clintons’ full-throated support for the bank are less than ideal.

The Clintons have faced similar criticism in recent months, amid questions raised by Peter Schweizer’s Clinton Cash about the Clinton Foundation’s extensive ties to foreign governments before, during, and after Hillary Clinton’s time as secretary of state. The scrutiny has even extended to the foundation’s apparently intimate ties with the Saudi Royal family. In light of all the media attention, even some Ex-Im defenders admit that the optics of the Dow deal and the Clintons’ full-throated support for the bank are less than ideal.

Stan Veuger, an economic scholar at the conservative American Enterprise Institute and an Ex-Im Bank supporter, isn’t convinced that the ties between the Clintons and their staff, Dow Chemical, and the Ex-Im Bank show a clear conflict of interest. “I’m not surprised that all these guys know each other,” he says, adding that many recent stories involving Clinton Foundation finances and donations have been “overplayed a bit.”


But Veuger also understands how the bank’s loan to Sadara looks particularly suspicious. “I can certainly see how you can paint a picture to make the parties involved look bad,” he says. “Even the appearance of a conflict of interest is bad in and of itself, you could argue, even if there’s no actual quid-pro-quo transactions going on.”

— Brendan Bordelon is a political reporter for National Review.