On January 17, in the final Democratic debate before the primary season begins, Bernie Sanders attacked Hillary Clinton for her close financial ties to Wall Street, something he had avoided in his campaigning up to that moment: “I don’t take money from big banks….You’ve received over $600,000 in speaking fees from Goldman Sachs in one year,” he said. Sanders’s criticisms coincided with recent reports that the FBI might be expanding its inquiry into Hillary Clinton’s emails to include her ties to big donors while serving as secretary of state. But a larger question concerns how Hillary and Bill Clinton have built their powerful donor machine, and what its existence might mean for Hillary Clinton’s future conduct as American president. The following investigation, drawing on many different sources, is intended to give a full sense of the facts about Clinton and not to endorse a particular candidate in the coming election.

It’s an axiom of Washington politics in the age of Citizens United and Super PACs that corporations and the very rich can channel almost unlimited amounts of money to candidates for high office to pave the way for later favors. According to the public service website Open Secrets, in the 2016 campaign, as of October, in addition to direct campaign contributions, Jeb Bush had at his disposal $103 million in “outside money”—groups such as PACs and Super PACs and so called “dark money” organizations that work on behalf of a particular candidate. Ted Cruz had $38 million in such funds, Marco Rubio $17 million, and Chris Christie $14 million.

Yet few have been as adept at exploiting this big-money politics as Bill and Hillary Clinton. In the 2016 campaign, as of October, Hillary Clinton had raised $20 million in “outside” money, on top of $77 million in direct campaign contributions—the highest in direct contributions of any candidate at the time. But she and her husband have other links to big donors, and they go back much further than the current election cycle. What stands out about what I will call the Clinton System is the scale and complexity of the connections involved, the length of time they have been in operation, the presence of former president Bill Clinton alongside Hillary as an equal partner in the enterprise, and the sheer magnitude of the funds involved.

Scale and complexity arise from the multiple channels that link Clinton donors to the Clintons: there is the stream of six-figure lecture fees paid to Bill and Hillary Clinton, mostly from large corporations and banks, which have earned them more than $125 million in the fifteen years since Bill Clinton left office in 2001. There are the direct payments to Hillary Clinton’s political campaigns, including for the Senate in 2000 and for the presidency in 2008 and now in 2016, which had reached a total of $712.4 million as of September 30, 2015, the most recent figures compiled by Open Secrets. Four of the top five sources of these funds are major banks: Citigroup Inc, Goldman Sachs, JPMorgan Chase & Co, and Morgan Stanley. The Clinton campaign meanwhile has set a goal of raising $1 billion for her Super PAC for the 2016 election.

Finally there is the nearly $2 billion that donors have contributed to the Clinton Foundation and its satellite organizations since Bill Clinton left office. It may seem odd to include donations to the foundation among the chief ways that corporations and the super-rich can gain access to the Clintons, earn their goodwill, and hope for future favors in return. The foundation’s funds are mostly spent on unequivocally good causes—everything from promoting forestation in Africa and helping small farmers in the Caribbean to working with local governments and businesses in the US to promote wellness and physical fitness.

Moreover, not all donors to the Clinton Foundation and its affiliated institutions are corporate. The Bill and Melinda Gates Foundation, for example, ranks among the largest contributors to the Clinton Foundation, having made grants totaling more than $25 million since its inception, and with a special focus, to quote a 2014 Clinton Foundation press release, on a partnership “to gather and analyze data about the status of women and girls’ participation around the world.”

But among the largest contributors to the foundation are many of the same donors that have supported Hillary Clinton’s political campaigns and that have paid the Clintons six-figure lecture fees. For these mainly corporate donors, access to the Clintons may be as important as the purposes for which their donations are used. According to a February 2015 analysis of Clinton Foundation funding by The Washington Post, the financial services industry has accounted for the largest single share of the foundation’s corporate donors. Other major donors to the foundation have included US defense and energy corporations and their overseas government clients.

Former US presidents have long used charitable foundations as a way to perpetuate their influence and to attract speaking fees as a lucrative source of income. But the Clintons are unique in being able to rely on the worldwide drawing power of former president Bill Clinton to help finance the political career of Hillary Clinton—with the expectation among donors that as a senator, secretary of state, and possible future president Hillary Clinton might be well placed to return their favors. The annual meetings of the Clinton Global Initiative have provided a prime setting for transactions between the Clintons and their benefactors. Among the corporate sponsors of the 2014 and 2015 CGI conferences in New York City, for example, were HSBC, Coca Cola, Monsanto, Proctor and Gamble, Cisco, PricewaterhouseCoopers, the Blackstone Group, Goldman Sachs, Exxon Mobile, Microsoft, and Hewlett Packard. For sponsorship of $250,000 or more, corporate executives attending the CGI meetings can enjoy special privileges up to and including direct access to the Clintons.

In a 2013 investigative article for The New Republic, Alec MacGillis described the annual CGI meeting as a complicated give and take in which CEOs provide cash for CGI projects in exchange for access to Bill Clinton. MacGillis focused on the activities of Douglas Band, a former low-level aide in the Clinton White House, who at the CGI meetings arranged favors for selected CEOs such as “getting them on the stage with Clinton, relaxing the background checks for credentials, or providing slots in the photo line.” At the CGI’s 2012 meeting it was Muhtar Kent, then CEO of Coca Cola, who, The New York Times reported, “won a coveted spot on the dais with Mr. Clinton.”

Along with the Clinton Foundation, lecture fees have offered another way for interested parties such as Citicorp and Goldman Sachs to support the Clintons beyond direct campaign donations. Data drawn from the Clintons’ annual financial statements, the Clinton Foundation, and the banks themselves show that between 2001 and 2014 Bill Clinton earned $1.52 million in fees from UBS, $1.35 million from Goldman Sachs, $900,000 from the Bank of America, $770,000 from Deutsche Bank, and $650,000 from Barclays Capital. Since she stepped down as secretary of state in February 2013, Hillary Clinton has been earning comparable fees from the same sources. Of the nearly $10 million she earned in lecture fees in 2013 alone, nearly $1.6 million from major Wall Street banks, including $675,000 from Goldman Sachs (the payments referred to by Bernie Sanders in the January 17 2016 debate), and $225,000 each from UBS, Bank of America, Morgan Stanley, and Deutsche Bank.

Among the most striking and troubling aspects of the Clinton System are the large contributions corporations and foreign governments have made to the Clinton Foundation, along with Bill Clinton’s readiness to accept six-figure speaking fees from some of them, at times when the donors themselves had a potential financial interest in decisions being made at Hillary Clinton’s State Department. An investigation published in April 2015 by Andrew Perez, David Sirota and Matthew Cunningham-Cook at International Business Times shows that during the three-year period from October 2009 through December 2012, when Hillary Clinton was secretary of state, there were at least thirteen occasions—collectively worth $2.5 million—when Bill Clinton received a six-figure speaking fee from corporations or trade groups that, according to Federal Government records, were at the time engaged in lobbying at the State Department.

These payments to Bill Clinton in 2010 included: $175,000 from VeriSign Corporation, which was engaged in lobbying at the State Department on cybersecurity and Internet taxation; $175,000 from Microsoft, which was lobbying the government on the issuance of immigrant work visas; $200,000 from SalesForce, a firm that lobbied the government on digital security issues, among other things. In 2011, these payments included: $200,000 from Goldman Sachs, which was lobbying on the Budget Control Act; and $200,000 from PhRMA, the trade association representing drug companies, which was seeking special trade protections for US-innovated drugs in the Trans-Pacific Partnership then being negotiated.

And in 2012, payments included: $200,000 from the National Retail Federation, which was lobbying at the State Department on legislation to fight Chinese currency manipulation; $175,000 from BHP Billiton, which wanted the government to protect its mining interests in Gabon; $200,000 from Oracle, which, like Microsoft, was seeking the government to issue work visas and measures dealing with cyber-espionage; and $300,000 from Dell Corporation, which was lobbying the State Department to protest tariffs imposed by European countries on its computers.

During Hillary Clinton’s tenure as secretary of state, US defense corporations and their overseas clients also contributed between $54 and $141 million to the Clinton Foundation. (Because the foundation discloses a range of values within which the contributions of particular donors might fall, only minimum and maximum estimates can be given.) In the same period, these US defense corporations and their overseas government clients also paid a total of $625,000 to Bill Clinton in speaking fees.

In March 2011, for example, Bill Clinton was paid $175,000 by the Kuwait America Foundation to be the guest of honor and keynote speaker at its annual Washington gala. Among the sponsors were Boeing and the government of Kuwait, through its Washington embassy. Shortly before, the State Department, under Hillary Clinton, had authorized a $693 million deal to provide Kuwait with Boeing’s Globemaster military transport aircraft. As secretary of state, Hillary Clinton had the statutory duty to rule on whether proposed arms deals with foreign governments were in the US’s national interest.

Further research done by Sirota and Perez of International Business Times and based on US government and Clinton Foundation data shows that during her term the State Department authorized $165 billion in commercial arms sales to twenty nations that had given money to the Clinton Foundation. These include the governments of Saudi Arabia, Oman, Qatar, Algeria, Kuwait and the United Arab Emirates, all of whose records on human rights had been criticized by the State Department itself. During Hillary Clinton’s years as secretary of state, arms sales to the countries that donated to the Clinton Foundation ran at nearly double the value of sales to the same nations during George W. Bush’s second term. There was also an additional $151 billion worth of armaments sold to sixteen nations that had donated funds to the Clinton Foundation; these were deals organized by the Pentagon but which could only be completed with Hillary Clinton’s authorization as secretary of state. They were worth nearly one and a half times the value of equivalent sales during Bush’s second term.

Among the most important, and lucrative, business friendships the Clintons have formed through the Clinton Foundation and the Clinton Global Initiatives has been that with Canadian energy billionaire Frank Giustra. A major donor to the foundation for many years, Giustra became a member of its board and since 2007 has been co-sponsor of the Clinton Giustra Sustainable Growth Initiative, or CGGI. In turn, Bill Clinton’s political influence and personal contacts with foreign heads of state have been crucial to Giustra’s international business interests.

In September 2005, Bill Clinton and Giustra travelled to Almaty, in southeast Kazakhstan, to meet with Kazakh President Nursultan Nazarbayev. At their meeting Clinton told Nazarbayev that he would support Kazakhstan’s bid to become chair of the Organization for Security and Cooperation in Europe (OSCE). The OSCE is a body with the responsibility for verifying, among other things, the fairness of elections among member states. According to multiple sources, including the BBC, The Washington Post, and The New York Times, Nazarbayev coveted this position for Kazakhstan, primarily as a mark of European diplomatic respectability for his country and himself.

Clinton’s endorsement of the Kazakh bid was truly bizarre in view of Kazakhstan’s ranking by Transparency International as among the most corrupt countries in the world—126th, on a par with Pakistan, Belarus, and Honduras. Freedom House in New York judges Kazakhstan to be “not free,” with Nazarbayev clocking up Soviet-era margins of victory of 90 percent or more in Kazakh presidential elections. Yet in a December 2005 letter to Nazarbayev following one of his landslide victories, Bill Clinton wrote: “Recognizing that your work has received an excellent grade is one of the most important rewards in life.” It is unclear what influence, if any, Bill Clinton’s support for Nazarbayev may have had in Kazakhstan’s efforts to lead the OSCE, but in 2007, after the United States gave its backing to the bid, Kazakhstan was chosen as the next chair of the OSCE, a position it assumed in 2010.

Possible reasons for Clinton’s support become clearer when we scrutinize the activities of Frank Giustra. In a January 31, 2008 article in The New York Times, Jo Becker and Don Van Natta, Jr., provided detailed evidence that Nazarbayev brought his influence to bear to enable Giustra to beat out better-qualified competitors for a stake in Kazakhstan’s uranium mines worth $350 million. In an interview with the Times, Moukhtar Dzakishev, then chair of the state-owned nuclear holding company Kazatomprom, confirmed that Giustra had met with Nazarbayev in Almaty, that Giustra had told the dictator he was trying to do business with Kazatomprom, and that he was told in return, “Very good, go to it.”

The deal was closed within forty-eight hours of Clinton’s departure from Almaty. Following this successful visit to Central Asia, Giustra donated $31 million to the Clinton Foundation. He then made a further donation of $100 million to the foundation in June 2008.

In an interview with David Remnick for a September 2006 New Yorker profile on Clinton’s post-presidency, Giustra described how his ties to Clinton could work for him and his interests. With Bill Clinton at that moment riding aboard his private executive jet for a journey across Africa (“complete with leather furniture and a stateroom,” according to The New Yorker), Giustra told Remnick that “all of my chips, almost, are on Bill Clinton. He’s a brand, a worldwide brand, and he can do things and ask for things that no one else can.”

The Clinton-Giustra connection became even more important in Colombia, where from 2005 onward Bill Clinton arranged a series of meetings between Giustra and then-president Álvaro Uribe, during which Clinton was frequently present. Giustra was already known in Colombia as the founder and backer of Pacific Rubiales, a Colombian oil company formed in 2003. In 2007, according to The Wall Street Journal, Bill Clinton had invited Uribe and Giustra to meet with him at the Clintons’ home in Chappaqua, New York.

The meetings provided a way for Giustra to lobby Uribe and his administration on behalf of Pacific Rubiales at a time when the Uribe administration was seeking to end the dominance of the national oil company, Ecopetrol, and open up the sector to foreign investors. These contacts appear to have born fruit for Giustra. In 2007 Pacific Rubiales signed a $300 million deal with Ecopetrol to build a 250 kilometer pipeline between Meta and Casanare provinces in Central Colombia. In the same year, Pacific Rubiales gained control of the Rubiales oilfield, Colombia’s largest.

Uribe was a singular interlocutor for Clinton and Giustra. The Colombian leader had been viewed by the George W. Bush administration as a crucial ally in the War on Drugs, in which Colombia was often held up as a success story. Yet Uribe and his political allies had longstanding connections to the Colombian drug cartels. In a 1991 intelligence report from the US Defense Intelligence Agency (DIA), declassified in August 2004, described Uribe as “a Colombian politician and senator dedicated to collaboration with the Medellin Cartel at high government levels…. Uribe was linked to a business involved in narcotics activities in the United States. [He] has worked for the Medellín cartel” and is “a close personal friend of Pablo Escobar Gaviria,” the longtime drug kingpin.

A 2011 report on events of 2010 by Human Rights Watch provides detailed evidence that Uribe was not free of this poisonous legacy when he was dealing with Clinton and Giustra. The report described President Uribe’s administration as “racked by scandals over extrajudicial killings by the army, a highly questioned paramilitary demobilization process, and abuses by the national intelligence service,” which participated in illegal surveillance of human rights defenders, journalists, opposition politicians, and Supreme Court justices. Hillary Clinton was warned about these human rights violations when, as secretary of state, she met with Bill Clinton, Giustra, and Uribe during a trip to Bogota, the Colombian capital, in June 2010. In an email message relayed to Secretary Clinton by the US Embassy in Bogota, Rep. Jim McGovern of Massachusetts warned that “while in Colombia, the most important thing the Secretary can do is to avoid effusive praise for President Álvaro Uribe.”

Hillary Clinton chose to ignore the warning. Addressing Uribe in the visit’s keynote speech, Clinton described him as an “essential partner to the United States” whose “commitment to building strong democratic institutions here in Colombia” would “leave a legacy of great progress that will be viewed in historic terms.” During her visit Clinton also affirmed her support for a US-Columbia free trade agreement, from which Giustra and other wealthy investors stood to benefit. This reversed her previous opposition to the agreement during her campaign for president in 2008, on grounds of Colombia’s poor human rights record, especially concerning the rights of labor unions.

Since the Giustra deal, there have also been complaints about the treatment of workers at Pacific Rubiales’s Colombian oil fields, which has been the target of numerous strikes and lawsuits by pro-labor groups. In an August 2011 speech to the Colombian Senate, Jorge Robledo, leader of the Polo Democrático Alternativo (Social Democratic) Party in the Colombian Senate, described the living quarters for Pacific Rubiales employees as “concentration camp-like,” with work shifts that sometimes exceeded sixteen hours a day for weeks on end, inadequate sanitary facilities and shared beds, and with the company relying on third-party hiring halls to avoid unionization and the payment of pension and healthcare benefits. (In April 2015, Peter Volk, general counsel for Pacific Rubiales, denied these allegations, saying that the corporation “fully respects the rights of its workers and demands from companies that provide services to it to also do so.”)

The record of the Clinton System raises deep questions about whether a Hillary Clinton presidency would take on the growing political influence of large corporate interests and Wall Street banks. The next president will need to address critical economic and social issues, including the stagnating incomes of the middle class, the tax loopholes that allow hedge-funders and other members of the super-rich to be taxed at lower rates than many average Americans, and the runaway costs of higher education. Above all is the question of further reform of Wall Street and the banking system to prevent a recurrence of the behavior that brought about the Great Recession of 2007-2008.

So far, Hillary Clinton has refused to commit herself to a reintroduction of the Depression-era Glass-Steagall Act, which Bill Clinton allowed to be repealed in 1999 on the advice of Democrats with close ties to Wall Street, including Robert Rubin and Larry Summers. The reintroduction of Glass-Steagall, favored by Bernie Sanders, would prevent banks from speculating in financial derivatives, a leading cause of the 2007-2008 crash. With leading Wall Street banks so prominent in the Clintons’ fundraising streams, can Hillary Clinton be relied upon to reform the banks beyond the modest achievements of the Dodd-Frank bill of 2010?