Last week, WikiLeaks dropped a 2011 memo by top Bill Clinton William (Bill) Jefferson ClintonChelsea Clinton: Trump isn't building public confidence in a vaccine Hillary Clinton launching podcast this month GOP brushes back charges of hypocrisy in Supreme Court fight MORE aide Doug Band that lays bare Team Clinton’s sordid financial dealings when Hillary Clinton Hillary Diane Rodham ClintonButtigieg stands in as Pence for Harris's debate practice Senate GOP sees early Supreme Court vote as political booster shot Poll: 51 percent of voters want to abolish the electoral college MORE was secretary of State.

ADVERTISEMENT

Band describes how the Clinton Foundation served as a conduit for what he called “Bill Clinton Inc.” — the former president’s for-profit arm. Other documents show State Department involvement.

The result is an unsavory mix of charity work, profiteering, and pay-to-play politics that potentially reaches the highest levels of US foreign policy and screams for IRS and Department of Justice reviews.

At center is Band and his consulting firm Teneo. Band served as gatekeeper to all things Bill Clinton. Those wanting a former president as golf partner ponied up. Requests for Foundation dough followed. Next came Clinton Inc. — the steady stream of speeches, books, and honorary titles that enriched Bill Clinton. Teneo managed it all.

Huge corporations and others seeking Clinton’s orbit lined up. Teneo’s clients included major U.S. corporations Coca-Cola and Dow Chemical, which donated huge sums.

Foreign firms like UBS donated and greased Clinton Inc.

For-profit Laureate International Universities went further, buying Clinton “advice” and rights to his prestige for $3.5 million annually. In all, Band states Teneo’s management yielded the former president $50 million — including a $2 million upfront slice of Band’s firm — with another $66 million queued. Band also facilitated political activity including securing campaign donors and managing Clinton’s political schedule.

Before daughter Chelsea Clinton intervened and ordered a compliance review, no one separated charity from profit-making time. Blurred lines were most blatant at the Clinton Global Initiative (CGI) — the annual confab where the world’s elite fete the former president and discuss world events.

Doug Band on his Bill Clinton Inc. memo: "I'm also starting to worry that if this story gets out, we are screwed." https://t.co/lx5Sczbtk7 pic.twitter.com/zWo8JSOOE6 — Lachlan Markay (@lachlan) October 30, 2016

According to the memo Teneo embedded at the conference’s hotel, hustled business, comped $20,000 CGI memberships to potential clients, and burnished its Clinton-gatekeeper role.

At one point Band even had Clinton staff calling British lawmakers for Dow Chemical “on behalf of President Clinton.” Band justified the set up arguing, “I believed, rightly or wrongly, that Teneo’s further development of its clients to be bigger donors to the Foundation and CGI was an important priority.”

Nice foundation you got there — be a shame if my clients weren’t funding it.

Doug Band really does not seem to like Chelsea interfering w/ Clinton Foundation business #wikileaks https://t.co/kmlsSu4OWu pic.twitter.com/4TvoCePaqO — Charlie Hoffmann (@choffmann10) October 28, 2016

From an IRS standpoint, red flags should abound. Charities must detail how they separate nonprofit from for-profit business. Those benefiting private interests or inure “insider” private gain lose their tax-deductible status because Treasury is cheated.

One IRS concern is, “Establishing exclusive business dealings with a particular for-profit business.” Band was clearly jeopardizing the Foundation’s status. Clinton eventually resigned as Teneo’s honorary chairman and kept only $100,000.

More disturbing was the unseemly mix of Band and Teneo clients with the State Department during Ms. Clinton’s tenure.

Clintons have over ‘500 Different’ conflicts of interest -- Clinton Foundation Executive Doug Band #PodestaEmails

https://t.co/8uMiBzNvsv pic.twitter.com/GtmdEo55sm — WikiLeaks (@wikileaks) October 21, 2016

The Daily Beast reviewed lobbying records and found Teneo clients Alibaba, Coca-Cola, and Dow received State Department munificence.

Alibaba — criticized for helping the Chinese government crackdown on internet freedom — lobbied State on intellectual property rights.

Coca-Cola double dipped by receiving excise-tax help with Pakistan and Thailand.

Dow avoided liability in India for a predecessor company’s accident that killed thousands because the Obama administration helped it avoid Indian courts.

Maybe it’s all coincidence.

But Band also influenced State in other ways. He procured jobs at the prestigious agency. When he said one person was “important to take care of,” Hillary Clinton aide Huma Abedin responded, “(State Department) personnel is sending him options.”

MORE STORIES FROM THE HILL:

Hillary Clinton: Uncontested and untested

Clinton, cadre of Dem enablers can't play victim in FBI probe

FBI should've investigated Weiner's computer much, much earlier

He got Dow executives invited to State functions with Secretary Clinton in Japan. And Abedin consulted him to ensure people requesting a meeting on a foreign trip were “legit cgi people.”

This is serious. Federal regulations bar government employees from using “public office for . . . private gain . . . or for the private gain of friends, relatives, or persons with whom the employee is affiliated in a nongovernmental capacity, including nonprofit organizations . . .” Bribery laws are also potentially relevant.

The Clinton attitude toward rules is well known. When asked about the Clinton Global Initiative last year, Carly Fiorina stated, “What don’t we know about (Clinton Foundation) donors? What don’t we know about the conflicts of interest that those donors represent when Mrs. Clinton is serving as Secretary of State?”

Wiki Leaks is showing us what we didn’t know and it may be criminal.

Jossey is a campaign finance attorney in Alexandria, Virginia. Please follow him on Twitter at @paulhjossey.