Earlier this week, CREW released a report documenting Donald Trump’s $13.6 million in foreign emoluments in office—the most comprehensive analysis to date of Trump’s worst conflicts of interest. While $13.6 million is a huge figure, there are significant challenges in tracking and quantifying just how much Trump was paid by foreign governments, even in instances where the available evidence strongly suggests Trump benefited financially from foreign emoluments.

There is, perhaps, no better example of this than a nearly $20 million loan balance Trump owed for years to a South Korean company that was controlled by the state-owned Korea Development Bank. Just months after Trump took office, the loan balance appears to have dropped by $15.5 million, and the Trump Organization seems to have quietly paid off the remainder, never reporting any of this on his financial disclosures—either as a candidate or as president. It’s not clear what exactly brought about the changes in the loan total, after remaining unchanged for years, but the timing and available information raises questions about whether Trump got more than $15 million in debt relief from a longtime partner tied to the South Korean government.

Trump’s long relationship with Daewoo Engineering & Construction

Since the late 1990s, Trump has had a foothold in South Korea by way of Trump World, which his company describes as “six condominium properties developed throughout Seoul, and two neighboring cities in South Korea.” The properties are all ostensibly still open, but Trump has never reported any significant income from them on his financial disclosures or the tax returns that have been made public. 

Potentially more important is a debt that came to light in 2022 showing Trump owed nearly $20 million to a South Korean firm, Daewoo, which appears to be the company that built Trump World and at least two other major Trump projects. The loan was never reported on Trump’s financial disclosures, but the requirement to do so hinges on whether Trump personally guaranteed the loan, and it’s not clear one way or the other if he did. 

Trump World was Trump’s first ever such foreign branding partnership and began a long history with the company’s construction arm, Daewoo Engineering & Construction. In the late 1990s, Daewoo was at the center of one of the largest fraud scandals in Korean history, and soon after that, it was broken up, with Daewoo E&C being one of the three resulting companies. 

Trump continued doing business with Daewoo E&C throughout its travails, and in the years after. A 2007 annual report from the company touts its work with Trump: the construction, from 1998 to 2001, of the Trump World Tower in New York andTrump’s Korea project Daewoo Trump World, as well as the 2004 to 2007 construction of the Daegu Trumpworld Soosung complex. In the same annual report, the address for Daewoo E&C’s U.S. headquarters is listed at 40 Wall Street, a building owned by the Trump Organization, which is the address the company still lists in paperwork filed with New York authorities. 

Throughout Trump’s time as president, Daewoo E&C’s majority stakeholder was the Korea Development Bank, a state-owned bank that bought a controlling stake in the company in 2010 and held it through 2022. Each of the financial disclosures that Trump has filed, both as a candidate and as president, listed one of two Daewoo E&C subsidiaries as licensees or owners on his Korea projects, and the subsidiaries themselves list Trump properties as their offices—one at 40 Wall Street  and one at Trump Tower. 

The buried loan

Despite Trump’s long history with the company, the nearly $20 million loan bearing the name “Daewoo” did not come to light during Trump’s presidency. First reported by Forbes in 2022, the loan was uncovered in a trove of documents obtained in New York Attorney General Letitia James’ successful fraud prosecution of Trump, which concluded earlier this year. They show that in financial documents prepared by The Trump Organization dating as far back as 2011, Trump owed “Daewoo” nearly $19.8 million. The loan is described in the filings as an original $25 million allocation to nine different Trump businesses across the Americas.

Shortly after Trump became president, the outstanding balance of the loan listed in the Trump Organization documents suddenly dropped to $4.3 million, and Daewoo was “bought out of its position on July 5, 2017.” Another internal Trump Organization document identified by CREW in Trump’s fraud trial exhibits appears to show the Trump Organization as the source of the buyout funds, listing the “Daewoo Buyout” payment alongside other known expenditures like his $25 million Trump University fraud settlement. However, the buyout is listed in Trump’s statement of financial condition as an even $4.3 million, while the corporate cash flow projection, pictured below, lists it as a slightly smaller $4.25 million.

A note underneath the net cash flow reads: “Included in the Net Cash Flow reflected above is approximately $15 million of debt reduction,” but it’s not clear if that is referring specifically to the Daewoo buyout. 

Earlier this year, the House Oversight Committee put out a report on Trump’s foreign emoluments, which makes reference to the Daewoo loan. However, the report doesn’t count any of the $20 million in its overall tally. Rather, it raises it primarily to note the loan’s absence from the documents provided by Trump’s accountant, Mazars USA, despite its presence in the internal Trump Organization documents obtained by the New York AG. 

There are, however, several details of the loan and repayment that suggest it resulted in a large windfall for Trump from a company controlled by the Korea Development Bank. First, the Oversight report notes that the loan existed at least as early as 2015, but as noted above, it had been on the books since at least 2011, always with a total just over $19,760,000. Second, the Forbes report the committee staff was relying on—which was the first to report the previously unknown loan—noted that the 2017 buyout happened, but states that “who exactly paid off the loan” was never specified. Yet, other documents cited above do appear to show pretty clearly that the buyer was Trump. Lastly, neither mention the fact that, at the time the loan was lowered and ultimately bought out, Daewoo’s construction arm, which Trump had repeatedly done business with, was owned by the Korea Development Bank, a state-owned bank, until it sold its majority stake in 2022. All of this together suggests that just five months after Trump took office, a longstanding loan from a company owned by a state-owned bank in South Korea was suddenly cut to a fourth of its original value, and Trump paid the remainder off. 

The congressional report notes that Mazars told investigators it had “no records to produce regarding the Daewoo loan,” so there may never be a full reckoning of exactly what happened here. But taken together, the above facts strongly suggest, but do not conclusively prove, that Trump benefited from more than $15 million in debt relief that came, in whole or in part, from the South Korean government. 

The questions that remain

Despite all of the evidence supporting this interpretation, there are still holes. First, “Daewoo” isn’t the name of any single company, but a former conglomerate that has been broken apart and restructured over the course of more than two decades. As noted above, though, Trump’s main partner for decades on multiple marquee projects has been Daewoo E&C, whose U.S. headquarters is even located in a Trump building in New York City. That does not conclusively rule out the possibility that some other vestige of the old Daewoo empire is the source of the funds, but even if that were the case, it could raise the same questions. For example, Daewoo Shipbuilding & Marine Engineering—one of the largest shipping companies in the world—was also controlled by the Korea Development Bank until 2022. Second, the fact that the Trump Organization bought out the loan—if that is indeed the correct reading of the internal documents — doesn’t prove that the seemingly unaccounted for $15.5 million wasn’t dealt with in a way that, if all of the facts were laid out, would look more innocuous than the scenario that has been laid out here. 

These questions are exactly what our longstanding rules governing ethical conduct in office are meant to address, and the fact that they linger more than seven years after Trump first entered the White House is evidence of the unprecedented nature of the conflicts of interest he carried throughout his time in office. And the fact that Trump never reported—and, indeed, may not have been required to report—the loan on his financial disclosures, either as a candidate or as president, is a stark reminder of the need for Congress to strengthen the ethics regime that governs what information presidents and vice-presidents need to disclose.

Illustration by Caleb Chen/CREW | Photo by Alan Miles under a Creative Commons license