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" ... The lack of adequate procedures at the Foundation was particularly problematic because various entities throughout the Trump Organization issued requests for payment to the accounting staff and these requests were not always accompanied by an instruction as to which entity in the Trump Organization should make a payment. In such circumstances, the sole criteria that the accounting staff used to determine whether to issue a check from the Foundation, rather than another entity in the Trump Organization or Mr. Trump personally, was the taxexempt status of the intended recipient; no one made any inquiry into the purpose of the payment. ... "