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Hiring of Former Senior Government Officials In other countries (such as Australia, UK,
France, and Germany), former senior government officials routinely take positions with
Chinese companies. This pattern appears less pronounced in the United States. A prominent
exception is the law firm Dentons, which merged with the Chinese law firm Dacheng in
201530 and employs numerous former government officials, including former ambassadors,
members of Congress, mayors, and generals.31

Earlier in 2018, Bloomberg News reported on the Imperial Pacific casino, a Chinese-owned
company operating in the American territory of Saipan. Its large transaction volumes have
raised concerns about potential money laundering. It has also made millions of payments to
family members of the territory’s governor and, at one time, counted the former governors
of three states as well as the former directors of the CIA and FBI as members of its board or
advisors.32

State and Local Politics Many states do not have prohibitions against foreign contributions
in local races.33 One of the most notable examples of an individual contributor comes
from Virginia, where in 2013 and 2014, Wang Wenliang, a Chinese industrialist who was
expelled from China’s national legislature in 2016, contributed $120,000 to Governor Terry
McAuliffe’s campaign.34

Chinese firms are also involved in lobbying at the state and local level, another means
of acquiring legitimate influence. While the quality of data reporting and aggregation
for local and state-level lobbying is not always as robust as that at the federal level, this
project was able to identify more than $1 million in state-level lobbying expenses over the
past decade by Chinese firms. BYD Motors, which produces buses for public transit in the
United States, Huawei, and Wanda America Group were among the biggest spenders on
lobbying.

A 2017 complaint with the Federal Election Commission against the California subsidiary
of Dalian Wanda is illustrative of the potential for exploitation granted by the US-
subsidiary exception. The FEC found that Lakeshore, a Chicago real estate company
whose principals are US citizens, was the source of the money that funded a local ballot
initiative in California that would have blocked a Wanda competitor from expanding.
Wanda acknowledged that the money for the measure had come from Lakeshore, with
which Wanda does business, in the form of a $1.2 million loan. In its conclusion, the
FEC did not rule on whether foreign restrictions applied to ballot measure activity.
Further, it argued that even if those restrictions did apply, because “none of the funds
at issue appear to originate with a foreign national” (i.e., they came from Lakeshore);
that because the Wanda deputy manager who was listed as the principal officer of the
Ballot Measure Committee was an American citizen (the general manager is a Chinese
national); and that the funds originated in and would be paid back by revenues generated

Corporations

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