Small point in the rapidly unfolding batches of information about the Trump campaign’s dealing with Russia in the summer of 2016. There’s this thing called the Foreign Corrupt Practices Act (FCPA). The gist of it is that American business people can’t bribe people abroad to do business overseas. There are some questions on the margins about what entails bribery or related corrupt practices. But offering a $50 million penthouse to the strongman of the state where you’re trying to build a luxury real estate development is definitely not legit.

As you probably saw yesterday, Michael Cohen and Felix Sater planned to do just that. They may even have made the offer. It clearly wasn’t finalized since the building was never built. But this suggests a line of criminal activity entirely separate from all the issues tied to conspiracy, collusion and the more outlandish activities we’re focused on.

There may be no criminal vulnerability on this front because they didn’t actually give Putin the Penthouse. Perhaps it was just Felix and Michael brainstorming between themselves. But the crime doesn’t need to be completed to be a crime. So it’s worth keeping an eye on this part of the equation.

For a run-down and analysis of everything we’ve learned so far this week, listen to this conversation with me, David Taintor, Tierney Sneed and Josh Kovensky.

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