Freezing Order
by Bill Browder


West Maui Book Club Discussion Questions

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Freezing Order definition: a legal procedure that prevents a defendant from moving their assets beyond the reach of court.

1. As a follow up to “Red Notice,” what is your assessment of the author’s account in Freezing Order?

2. Sometimes even the smallest event had the biggest impact, such as the “little-known feature of the international banking system: whenever money is transferred in dollars—even between two banks in Russia—it touches a US clearing bank for a fraction of a second, leaving a permanent record. Those clearing banks are headquartered in Manhattan and under the jurisdiction of US courts.” (pg 26) How did this IBS (International Banking System) come into existence?

3. And, in this account, how many other small incidents paid large rewards? I can think of several, including the only police officer who volunteered to check Interpol’s data base for Browder’s ESTA (US Global Entry) status, thereby giving him the opportunity to clear it before leaving on his trip to Canada. (Pg 268)
Another might be the NGO (nongovernmental organization) called the OCCRP--Organized Crime and Corruption Reporting Project-- “a loose confederation of investigative journalists focusing on corruption in Eastern Europe and Russia,” running a story that a single compliance officer at UBS (Union Bank of Switzerland) in Zurich saw and filed a “suspicious activity report (SAR) with Swiss law enforcement. (Pg 82)
And a few others involve his wife, Elena, exacting the voice of reason on how to handle a particular situation. For example: telling him to post on Twitter whenever he needed help. (Pg 3) Or while in Aspen and his location was posted during an interview, his wife insisted he continue with the rollout of his Red Notice book’s tour, saying “no, the book is too important. You need to go.” (Pg 111) And again, after Trump agreed to trade political persons with Putin for Browder. Her response was, “…it won’t happen overnight. At this moment, the whole world wants to know, ‘Who’s Bill Browder?’ I think you should tell them.” (Pg 280)

4. The Magnitsky Act bans US visas and freezes US assets against persons guilty of human rights violations. It was passed into law by Obama on Dec. 14, 2012. (pg 89) The Global Magnitsky Human Rights Accountability Act authorizes the president to block or revoke the visas of certain “foreign persons” (both individuals and entities) or to impose property sanctions on them. People can be sanctioned (a) if they are responsible for or acted as an agent for someone responsible for “extrajudicial killings, torture, or other gross violations of internationally recognized human rights,” or (b) if they are government officials or senior associates of government officials complicit in “acts of significant corruption.” It passed as part of the National Defense Authorization Act for Fiscal Year 2017, after being signed into law on Dec. 23, 2016 by outgoing President Obama. From there it escalated through The Canadian House of Commons, The EU, etc. See full list in WMBC discussion point #6.

5. Discuss this book’s account of President Trumps involvements with Russia, Browder, and the Magnitsky Acts. Do you have anything to add?

6. Discuss Browder’s journey as “a single person in Russia, (who) didn’t speak the language, and had never run an investment fund” (pg 43) ends up being responsible for $4.5 billion invested in Russian equities (pg 18) and then goes on to have Russia levy a collected prison sentence of 38 years in absentia (pg. 292) and being responsible for 34 different countries passing the Magnitsky Act. (Pgs 294-295): “the United States, Canada, the United Kingdom, Australia, the 27 countries of the European Union, Norway, Montenegro, and Kosovo. Plus, the British Overseas Territories and crown Protectorates of Gibraltar, Jersey, Guernsey, the British Virgin Islands, and the Cayman Islands. New Zealand and Japan are on deck.” What does that say about his or any of the other “targets'” ability to overcome obstacles, lawsuits, prison, and death threats?

7. The first freezing order happened on April 23 2011 when the Swiss froze the $11 million the Stepanovs held at Credit Suisse. (Pg 61)
The second happened in July 2012 when “Swiss law enforcement had taken it upon themselves to freeze (Dmitry) Klyuev’s Swiss bank accounts. (Pg 78)
The third occurred after “Swiss authorities placed freezing orders over Prevezon’s $7 million at UBS.” (Pg. 83)
The fourth was issued over Prevezon’s “approximately $20 million of real estate and cash in New York, along with 3 million (approximately $3.5 million) of assets held in the Netherlands.”(Pg 97)
The fifth freezing order was issued against a Russian woman who laundered money and her $9 million in accounts in France, Luxembourg, and Monaco. (Pg 188)
Are you aware of any since the Spring of 2016?

8. July 5, 2012 - Annual meeting of the Parliamentary Assembly of the Organization for Security and Cooperation in Europe (OSCE PA0-57 countries to discuss human rights, democracy and security) passed the Magnitsky resolution 291-18. (pg 78)

9. Browder writes, “…one of the most powerful law enforcement bodies in the world” is the SDNY—The United State District Court for the Southern District of New York since 1789—a federal trial court whose geographic jurisdiction encompasses eight counties of NY State. Browder doesn’t explain why they are one of the most powerful, so do you?

10. Discuss the importance of the Panama Papers that were assembled by 370 journalists from 80 countries. (Pg 191) What are The Panama Papers? GOOGLE, Dec. 22, 2021-The documents that were published in 2016 are 11/5 million leaked financial and attorney-client- details of over 214,488 offshore entities which were created by Panamanian law firm Mossack Fonseca in order to evade taxes and other money fraud.

11. Europe’s third largest money laundering scandal in history was revealed by two Denmark journalists at the Berlingske newspaper--Eva Jung and Michael Lund. (Pg 273) In a July 3, 2018 Berlingske article they reported that including the $200 million Browder’s team had identified, they had found another “$8.3 billion flowing from Russia and other former Soviet states through 20 companies between 2007-2015” (Pg 274)

12. The greater issues in this book are still unfolding. How well are you versed on the subject, or has this book influenced you enough to become more educated or continue to follow them?

WMBC Questions compiled by: Elaine Gallant
West Maui Book Club
May, 2022