Prior to Halloween, The Wall Street Journal asked a very good question: why isn’t the IRS investigating the Clinton Foundation? Leaving out the obvious political stains from their scandal, in which they targeted conservative organizations seeking tax-exempt status, it’s a legitimate inquiry. Wikileaks was able to shed light on what top Bill Clinton aide Doug Band, who helped start the Clinton Foundation and went on to co-found his own consulting firm, Teneo, called Bill Clinton, Inc. The 13-page memo described how money could be obtained to go to both the Clinton Foundation and to the Clintons personally. That strategy centered on using the Foundation’s top tier donor base (Dow Chemical, Coca-Cola, etc.) to also forge paid speaking engagements and consulting deals. The amount that Bill could personally reap with this strategy could be as much as $66 million if everything remained in place.

…Mr. Band went ahead and described the “unorthodox nature” of his work while emphasizing his determination to help “protect the 501(c)3 status of the Foundation.” That’s the part of the tax code that has allowed the Clinton Foundation to remain tax-exempt on the premise that it is dedicated to serving humanity. Mr. Band graciously copied John Podesta, then adviser to the board, who would eventually become Hillary’s campaign chief. His helpful reply was to suggest that Mr. Band “strip the defensive stuff out” and later “go through the details and how they have helped WJC” [ William Jefferson Clinton]. The Band memo reveals exactly what critics of the Clintons have long said: They make little distinction between the private and public aspects of their lives, between the pursuit of personal enrichment, the operation of a nonprofit, and participation in U.S. politics. Mr. Band writes that he and his colleague Justin Cooper “have, for the past ten years, served as the primary contact and point of management for President Clinton’s activities—which span from political activity (e.g., campaigning on behalf of candidates for elected office), to business activity (e.g., providing advisory services to business entities with which he has a consulting arrangement), to Foundation activity.” […] Mr. Band’s memo confirms that donors were not seeking merely to help the sick and the poor. He explains that the Clinton Foundation had “engaged an array of fundraising consultants” over the past decade but “these engagements have not resulted in significant new dollars for the Foundation.” In other words, it wasn’t working as a conventional charity. Mr. Band then explains how he and his Teneo partner Declan Kelly had to carry the fundraising load, and did so by packaging foundation solicitations with other services such as a meeting with Bill Clinton, $450,000 speeches or strategic advice. Many of the donations, from U.S. companies like Coca-Cola and Dow Chemical and foreign firms like UBS and Barclays, occurred while Hillary Clinton was Secretary of State.

MSNBC’s Joe Scarborough described the whole matter as a “shakedown.” Mediaite noted that co-host Mika Brzezinski said the whole affair put the Clinton Foundation in a scandalous light in a “kind of morally deficit kind of way, a sleazy way.” The ironic thing here is that none of this would have come to light if Chelsea Clinton weren’t worried about aides hustling business (via Politico):

Chelsea Clinton sent a fiery email to a group of top Clinton advisers, detailing allegations about aides she said were undermining the family, including by possibly misrepresenting their expenses and blurring the line between a family-linked consulting firm and the Clinton Foundation. […] In the email, Chelsea Clinton says the allegations made her “very sad,” though she acknowledges that she cannot attest to the veracity of all of them and that there are likely other “sides” to the claims. Still, she says she raised the concerns with her parents. And, as part of her efforts to “professionalize the Foundation,” she wrote, she was passing along the allegations to the recipients of the email — Podesta, longtime Hillary Clinton confidante Cheryl Mills and two officials from Simpson Thacher, a law firm that had been commissioned to audit the Clinton Foundation. At the time of the email, Chelsea Clinton was pushing to enact tougher internal rules at the Clinton Foundation regarding conflicts of interest and outside income.

This brought her into conflict with Mr. Band, but that’s a tale for another time.