Thread by @BBuchman_CNS

#ManafortTrial Closing Arguments Thread -
Prosecutor Andres emphasized to jurors: “If you have any doubt that he’s guilty of bank fraud or conspiracy to commit bank fraud at the Federal Savings Bank, then...

all you need to remember is that he sent a fake profit and loss sheet to Federal Savings Bank. And you will recall from testimony by his tax preparer Heather Washkuhn that Davis Manafort Partners had no income at this time [but it was not reflected this way].”

“Remember, he lied about where he lived and liens on his property. He altered some documents and backdated others,” Andres said.

Should jurors have any doubt or question who actually held the foreign entities discussed at trial, like Yiakora Ventures, Andres said jurors need only look to emails on the record.

“He refers to the account as ‘my Yiakora account,’” Andres said. “He didn’t say Davis Manafort Partners account or Rick Gates’ account. Mr. Manafort owned and controlled that account and all of the other Cyprus accounts.”

Then, when it came to his tax forms, Andres reminded jurors Manafort put his signature on each form in question from 2010 to 2014 & above each one of his signatures, there's a disclaimer warning him: “under penalty of perjury the information he provided is correct and complete.”

All told, Andres continued, Manafort had 31 overseas bank accounts from 2010 to 2014.
“And they had more than $60 million that flowed through them,” Andres said before pausing for just a moment. “He owned them and he controlled them.”

“Mr. Manafort hid his offshore accounts. He hid them from his tax preparers. He lied about them. He never disclosed to his bookkeepers that they existed.”
Andres also asked jurors to recall testimony from IRS revenue agent Mike Welch.

“Mr. Welch testified that he tracked the money coming from Cypriot accounts to pay vendors was income,” Andres said, noting that all told, Manafort paid $15M to vendors alone from his overseas accounts.
But why would Manafort lie, Andres asked.
The answer is simple, he said.

“Mr. Manafort wanted to hide the money and evade taxes on the clothes, the cars, the condos and the construction. And remember, this trial is not about his wealth. We’re not here because he’s wealthy but because he filed false tax returns and failed to file FBARs,” Andres said.

“And the clothes, the cars, condos and construction, all of this is evidence of his unreported income.” - Andres

Andres also recalled statements made by Manafort’s defense attorneys at the start of trial who claimed that Manafort simply forgot to check the a box on his tax forms where it asked him whether he had signatory authority over any foreign accounts.

“It wasn’t a clerical error. It wasn’t failure to check a box. Manafort answered no to each question on the form,” Andres said.
From 2011 to 2014, the “total aggregate” amount of money Manafort held in foreign bank accounts exceeded $5 billion he said.

Andres also deflected arguments from defense from an earlier point in the trial. Andres asked jurors to recall testimony from FBI analyst Morgan Magiones on cross examination by defense attorney Richard Westling.

“On cross she was shown two of Paul Manafort’s signatures and asked if they were from the same person. She said she knew they were – though she is not a handwriting expert – because while they looked different, all of the money transferred [as a result of his signing] were...

...at the benefit of Mr. Manafort.”

“Is it possible that Rick Gates or somebody else signed the accounts? Is it possible that someone put $60 million in those accounts?” Andres said. “We should all be so lucky.”

Andres also reminded jurors there is a difference between willfulness and intent. The requirement to fulfill willfulness comes from being aware of the obligations under law and then violating them anyway.

“Mr. Manafort was willfull in not reporting his income or identifiying foreign bank accounts and in not filing his FBAR,” Andres said. “He knew the law and he violated it anyway.”

Manafort is “conversant” in tax law, he added, saying Manafort was “capable and bright” and “trained as a lawyer.” Pointing to emails between Manafort and his tax preparer, Philip Ayliff, Andres said Manafort knew the law because his correspondence were rife with tax terms.