The identification policy could not comprehensively identify foreign-government patronage, leaving the announced donation promise unauditable against the full customer base.
The cited records document how the action led to the outcome.
At Trump's January 2017 press conference, counsel for the Trump Organization said the arrangement would isolate him from the business, bar new foreign deals and donate foreign-government hotel profits to the Treasury.
The company's internal policy said it would not require every guest to identify a foreign-government relationship and generally relied on self-identification.
Later Mazars records documented foreign-government-linked payments beyond what the public donation disclosures could independently reconcile.
Available records do not permit a transaction-by-transaction comparison of all foreign receipts, expenses, profit and Treasury donations.
Available records do not permit a transaction-by-transaction comparison of all foreign receipts, expenses, profit and Treasury donations.