President Donald Trump has repeatedly accused Hunter Biden, without evidence, of making millions of dollars in a “payoff” from China, after accompanying his father, then-Vice President Joe Biden, on a 2013 diplomatic trip to Beijing.

The claim involves a cross-border private equity fund involving some state-owned financial companies in China. Biden served on the management company’s board while his father was vice president, but his attorney says that was an unpaid position, that he did not create the company and has not yet received any money, let alone millions. The attorney says Hunter Biden only acquired a minority stake in the investment management company after his father left office.

We have found no evidence to contradict that, and Trump hasn’t provided any. We also found no evidence that Joe Biden used his position as vice president to enrich his son.

Trump has made numerous comments calling for the investigation of Hunter Biden’s business dealings in Ukraine and China, which the president suggests involved Joe Biden. We have written about how the president has twisted the facts on the Bidens and Ukraine, and here we will address claims related to China.

Trump has repeatedly claimed that Hunter Biden “made millions of dollars” from China “very rapidly” while his father was vice president. Trump and his personal attorney, Rudy Giuliani, have both claimed that Hunter Biden got “$1.5 billion” from China for a private equity fund.

“When Biden’s son walks out of China with $1.5 billion in a fund — and the biggest funds in the world can’t get money out of China — and he’s there for one quick meeting, and he flies in on Air Force Two, I think that’s a horrible thing. I think it’s a horrible thing,” Trump said during a joint press conference with Ukrainian President Volodymyr Zelensky on Sept. 25.

During an Oct. 3 press conference, Trump called on China to “start an investigation into the Bidens.” Trump said China probably has enjoyed “a sweetheart deal” with the U.S. on trade, “because they deal like people with Biden, where they give their son a billion and a half dollars.” He called it a “payoff.”

China has since rejected Trump’s call to investigate the Bidens.

On ABC’s “This Week” on Sept. 29, Giuliani rattled off various claims, including saying that Hunter Biden got “$1.5 billion from China while [Vice President Biden was] negotiating with China.”

Giuliani, Sept. 29 : And there are three partners, Rosemont Seneca. That’s Hunter Biden and [Christopher Heinz] the stepson of the — of the secretary of state [John Kerry]. The second partner is the Bank of China. And the third partner is a company called Thornton Group. … The $1.5 billion was in a company that was specially established called Bohai Harvest Rosemont Seneca or some crazy name like that. The partners were Joe Biden’s son, John Kerry’s stepson, the Bank of China, one-third partner at least, and the Thornton Group. That was owned by Whitey Bulger’s nephew. Now, that’s all out there. You can go and look at it. If I’m wrong, I’m wrong. It should be investigated.

Hunter Biden was involved with the cross-border equity consortium in question, but the $1.5 billion was what the fund hoped to raise in 2014 for investments. It is not the value of the management company in which Hunter Biden now holds a minority share. It’s unclear if that $1.5 billion goal was reached in its first year, as the investment fund had forecast, but the company website says it now manages assets worth the equivalent of over $2.1 billion in U.S. dollars.

Giuliani’s mention of the three partners in Rosemont Seneca is a good place to start.

The same year that Barack Obama and Joe Biden took over the White House in 2009, a general partnership formed that brought together Hunter Biden, son of then-Vice President Joe Biden, Christopher Heinz, stepson of then-Sen. John Kerry, and Devon Archer, a classmate of Heinz’s from Yale.

But all three did not participate in all of the deals undertaken under the Rosemont Seneca umbrella, with separate corporations formed for some deals.

Such was the case with Biden and Archer’s foray into China. Heinz’s attorney told The Hill that Heinz had “no operating role” in Rosemont Seneca and had nothing to do with any of the deals in question in China.

Hunter Biden’s role is also not as straightforward as the president and Giuliani say, according to Hunter Biden’s attorney. But it is true that Hunter Biden and Archer made business overtures to high-ranking Chinese fund leaders as early as 2010.

As conservative author Peter Schweizer details in his book “Secret Empires,” Biden and Archer, along with James Bulger of the consultancy firm the Thornton Group, took several meetings in 2010 with high-profile business and government interests in China. (As Giuliani said, James Bulger is the nephew of mobster Whitey Bulger, but he’s also the son of former Massachusetts state Sen. Billy Bulger.)

Schweizer came across an account of the meetings posted by the Thornton Group — in Chinese — in which Chinese executives expressed their “warm welcome” to the “Thornton Group, with its US partner Rosemont Seneca chairman Hunter Biden (second son of the now Vice President Joe Biden).” According to the Thornton Group’s account — a copy of which Schweizer emailed to us — the purpose of the meetings was to “explore the possibility of commercial cooperation and opportunity.”

Flash forward three years to June 2013, and according to the New Yorker, Archer, Jonathan Li — who ran a Chinese private equity fund, Bohai Capital — and other partners “signed a memorandum of understanding to create” a cross-border private equity fund “which they named BHR Partners, and, in November, they signed contracts related to the deal.” (Some of those entities that met in China with Archer and Biden back in 2010, including representatives from the National Council of Social Security Fund and the Postal Savings Bank of China, ended up investing in the fund managed by BHR.)

In December 2013, Hunter Biden and one of his daughters flew on Air Force Two with Joe Biden to China, where the elder Biden was on a diplomatic mission. Hunter Biden’s attorney, George Mesires, told the New York Times that Hunter Biden went along because his daughter had been invited and needed a chaperone.

Although Hunter Biden told the New Yorker he conducted no business while in China, he did arrange for a photo op with Li and his father, Joe Biden, in a hotel lobby. Hunter Biden told the New Yorker that the meeting with Li, who would soon after become CEO of BHR, was purely social, and that he did not meet with any Chinese government officials about the fund on that trip. Mesires told NBC Hunter Biden he did not conduct any business on the trip.

Mesires also told NBC News that BHR’s initial formation documents were filed in November 2013 — the month before the China trip — but that the business was officially launched with a business license issued 10 days after the visit. Hunter Biden was named to its board of directors. Archer was a vice chairman of the company and sat on its investment committee.

According to a July 10, 2014, Wall Street Journal article, “A consortium of foreign and Chinese private-equity firms is aiming to raise about $1.5 billion to invest abroad, with the yuan-denominated portion of the fund to be converted to U.S. dollars through Shanghai’s free-trade zone.”

Wall Street Journal, July 10, 2014: The fund — launched by Chinese asset managers Bohai Industrial Investment Fund Management Co. and Harvest Fund Management Co. alongside U.S. investment and advisory firms Rosemont Seneca Partners and Thornton Group LLC — started fundraising in the second quarter, and has raised its target to $1.5 billion from an original $1 billion plan, a spokesman at Bank of China International Holdings Ltd. said. BOCI is one of the largest stakeholders in Bohai. The Bohai-Harvest fund is likely one of the biggest Sino-foreign collaborations [between Chinese partners and foreign ones] in private equity to take advantage of the free-trade zone’s benefits in converting yuan to dollars that can then be invested in foreign companies. The funds are raising a combination of yuan and U.S. dollars. The effort is the latest example private equity pushing boundaries in an area that China hopes will help drive the country’s economic transformation. Normally, China restricts free conversion of its currency. Bohai and its partners are expected to finish fundraising by the end of this year, according to BOCI’s spokesman and Lindsay Wright, co-chief executive officer of Harvest Capital Management Co., the subsidiary under Harvest that will hold a direct stake in the joint fund.

According to the article, BOCI and Harvest both declined to say how much had been raised at that time. We don’t know whether the $1.5 billion goal was ever reached. Nonetheless, that’s the origin of the figure cited by Trump and Giuliani. (BHR’s website says the assets it now manages are worth over $2.1 billion.)

Hunter Biden’s Role

Hunter Biden’s attorney says Hunter Biden neither created the management company nor had an ownership stake until well after his father left office.

“BHR (Shanghai) Equity Investment Fund Management Company (‘BHR’) is an investment management company that was formed in 2013,” George Mesires told us via email. “Hunter did not form BHR, was not an initial owner of BHR, and did not own any interest in BHR until October 2017, after his father had left government service. BHR was capitalized with approximately $4.2 million USD from various sources, not $1.5 billion. Hunter did not acquire any interest in BHR until October 2017 when he acquired a 10% interest, which has a $420,000 capital commitment.”

Trump and Hunter Biden’s attorney are talking past each other a bit. Trump says Hunter Biden “walk[ed] out of China with $1.5 billion in a fund.” Biden’s attorney dismissed that figure, saying “BHR was capitalized with approximately $4.2 million USD from various sources, not $1.5 billion.” The $1.5 billion figure refers to the size of the funds raised for investments.

Hunter Biden did serve on BHR’s original board of directors while his father was vice president, but Mesires told the Washington Post that Biden was on the board of the advisory firm that did not directly invest, but instead advised those who did.

Mesires told us, “Hunter has not received any return on his investment or compensation on account of his position on the board of directors.”

A BHR representative told the New Yorker in July that although Hunter Biden served on the board, he was not a signatory to the BHR deal, and that the deal wasn’t with Rosemont Seneca Partners, but rather with a holding company, established solely by Archer.

Corporate registration records in China — captured by Schweizer in May — show that “Rosemont Seneca Thornton LLC” owned a 30% stake in BHR. We could not confirm if that was the holding company to which the BHR representatives referred. And Biden’s attorney did not respond to our inquiries seeking details about that.

Schweizer points to a screen grab from a 2016 version of the BHR website that lists Rosemont Seneca Partners as a “sponsor” of BHR.

BHR website, Sept. 7, 2016: Formed in the Shanghai Free Trade Zone in December 2013 as its first cross-border investment private equity firm, BHR is the cross-border investment arm of Bohai Industrial Investment Fund Management Co., Ltd. (“Bohai Capital”). Our other sponsors include Harvest Fund Management Co., Ltd (‘Harvest”), Rosemont Seneca Partners (“RSP”), Thornton Group LLC (“Thornton”) and our management team. We also enjoy the support of Bank of China, China Development Bank Capital, National Council of Social Security Fund, China Life, Postal Savings Bank of China, among others, as our suite of legacy shareholders through Bohai Capital.

But according to Hunter Biden’s attorney, Hunter Biden derived no financial benefit from the deal at that time. He was acting as an unpaid director advising investors in the fund.

Mesires told the New York Times that while Hunter Biden now has a 10% stake in BHR, which he acquired through a company he created named Skaneateles LLC, “there have been no distributions to the shareholders since Hunter has been an equity owner.”

But that doesn’t mean Biden won’t eventually make millions from the deal. Steven Kaplan, who conducts research on issues in private equity, venture capital, entrepreneurial finance, corporate governance and corporate finance at the University of Chicago Booth School of Business, told us that a private equity fund with $2 billion under management will typically generate fees over its life of hundreds of millions of dollars.

“It is difficult to imagine, if not incomprehensible, that a 10% stake in those economics is worth only $420K,” Kaplan told us via email. “The distinction they appear to be making is they capitalized the management company with $4.2 M even if the fund manages $2 B. The value of that management company is likely far in excess of $4.2 M if they are managing $2 B.”

Kaplan pointed to two large publicly traded private equity firms for reference, both of which have a market value of about 10% of the assets under their management. Using that as a rough guide, that would put the value of Hunter Biden’s share closer to $20 million, he said.

There are still some unanswered questions about Hunter Biden and his role in the BHR deal, and his attorney did not get back to us when we had follow-up questions. We don’t know details, for example, about the BHR representative’s claim to the New Yorker about Archer alone setting up a separate holding company apart from Rosemont Seneca Partners to make the initial BHR deal, though the fact that Hunter Biden used a separate corporation to acquire a 10% stake in BHR in 2017 may suggest he did not have any ownership stake prior to that.

Although some may speculate about Hunter Biden’s activities while on a diplomatic trip with his father in China, Hunter Biden told the Washington Post earlier this year, “At no time have I discussed with my father the company’s business or my board service.” And Joe Biden in Iowa recently said, “I have never spoken to my son about his overseas business dealings.”

In an op-ed for the New York Times published on Oct. 9, Schweizer said Hunter Biden didn’t do anything illegal in the China deal. While the Foreign Corrupt Practices Act prohibits a U.S.-owned company from hiring the children of foreign government officials “in the hopes of currying favor with their powerful parents,” Schweizer wrote, it is not a violation if a foreign company hires or does business with the family members of American politicians. Schweizer argues, however, that such “cronyism” should be illegal.

“It gives the politically connected class enormously tempting opportunities for self-dealing, the sort of thing that is blatantly illegal in almost any other context,” Schweizer wrote, adding that Biden landed a deal in China that “he was apparently unqualified to score save for one thing: his father.”

Hunter Biden is not the first child of a prominent politician to be accused of having ties to a company doing business with a foreign country. Indeed, similar questions have been raised about Trump’s own family members.

The president is free to question whether Hunter Biden capitalized on his father’s name to insert himself into a deal that involves investments by the Chinese government. But he goes beyond that to make unsubstantiated claims that Hunter Biden made “millions and millions” from China while his father was vice president and that he hitched a ride on Air Force Two to secure a $1.5 billion investment deal.

Biden’s attorney claims that Hunter Biden made no money off the deal while his father served as vice president, and has yet to see any return on his investment. We cannot verify either statement, and we can’t say how much Hunter Biden might ultimately make from his 10% stake in BHR. But while Trump has called on China to open an investigation, there has been no evidence presented to date that suggests either Biden did anything illegal.