Trump Family Money: Businesses, Foreign Deals and Public Policy

The SEC found that Wesley and Joesley Batista concealed the bribery arrangements from Pilgrim’s Pride’s accountants and auditors, knowingly caused inaccurate books and records, and violated Exchange Act Section 13(b)(5) and Rules 13b2-1 and 13b2-2. J&F and JBS also caused Pilgrim’s accounting and internal-control violations. In the settled administrative proceeding, JBS agreed to approximately $26.9 million in disgorgement and interest, and each brother agreed to a $550,000 civil penalty. The resolution required compliance improvements and three years of reporting.^{37, 39}

No person shall knowingly circumvent or knowingly fail to implement a system of internal accounting controls or knowingly falsify any book, record, or account described in paragraph (2).

15 U.S.C. § 78m(b)(5) — Exchange Act § 13(b)(5) · Applicable during the conduct; SEC order dated October 14, 2020^{37, 40}

SEC filings identify Joesley and Wesley Batista as the ultimate controlling shareholders of JBS and report JBS’s approximately 82% ownership of Pilgrim’s Pride. Pilgrim’s Pride donated $5 million to the Trump–Vance Inaugural Committee on January 2, 2025. Senator Elizabeth Warren’s May 19, 2025 letter asked JBS USA and Pilgrim’s Pride executives who chose the donation, whether their boards approved it, and what communications occurred with Trump’s transition team.^12–15

A foreign national shall not, directly or indirectly, make a donation to an inaugural committee, as defined in 11 CFR 104.21(a)(1). No person shall knowingly accept from a foreign national any donation to an inaugural committee.

11 CFR 110.20(j) · In force for the January 2, 2025 donation; paragraph (j) adopted in 2004¹⁹

The Trump–Vance Inaugural Committee’s filing lists Pilgrim’s Pride Corporation as the donor of $5 million received January 2, 2025, and Donald Trump and J.D. Vance as honorees. JBS holds approximately 82% of Pilgrim’s Pride; Joesley and Wesley Batista are JBS’s ultimate controlling shareholders.^12–15

A foreign national shall not, directly or indirectly, make a donation to an inaugural committee, as defined in 11 CFR 104.21(a)(1). No person shall knowingly accept from a foreign national any donation to an inaugural committee.

11 CFR 110.20(j) · In force for the January 2, 2025 donation; paragraph (j) adopted in 2004¹⁹

The proclamation instructed the Agriculture Secretary and U.S. Trade Representative to monitor whether imported lean beef trimmings were sold at 25% below the market price for those trimmings. If they determined the condition was not met, they were to notify Trump, who could eliminate the remaining added quota. The White House described the discount relative to the going import price; Trump’s original post, as reported by the article, described it relative to current market prices.^{20, 97}

The Secretary of Agriculture and the Trade Representative, in consultation with any other senior executive branch official they deem appropriate, shall monitor whether the imports of lean beef trimmings entered under the increased in-quota quantity established in this proclamation are being sold at a price 25 percent below the market price for lean beef trimmings.

August 26, 2026 beef proclamation, clause 6(b) · August 26, 2026⁹⁸

CBS reported Corte Argentino recalled Argentine beef distributed in Florida and Texas after the products entered without required import reinspection.⁹⁹

Except as provided in §§ 327.16 and 327.17, all products offered for entry from any foreign country shall be reinspected by a Program inspector before they shall be allowed entry into the United States.

9 CFR 327.6(a)(1) · In force for the August 2026 recall; paragraph (a) revised in 2014¹⁰⁰

On October 14, 2020, J&F Investimentos pleaded guilty in federal court in Brooklyn to conspiring to violate the U.S. Foreign Corrupt Practices Act. Its admitted scheme ran from 2005 through 2017. J&F agreed to a $256.5 million criminal penalty; U.S. authorities allowed credit of up to half that amount for qualifying payments under the Brazilian resolution.³⁸

If two or more persons conspire either to commit any offense against the United States, or to defraud the United States, or any agency thereof in any manner or for any purpose, and one or more of such persons do any act to effect the object of the conspiracy, each shall be fined under this title or imprisoned not more than five years, or both.

18 U.S.C. § 371 — conspiracy; charged object: FCPA, 15 U.S.C. § 78dd-3 · Applicable to the October 14, 2020 corporate guilty plea^101–102