Fighting Global Kleptocracy with Snake Oil: Decoding/Deconstructing and Fact-Checking USAID Administrator Samantha Power’s “Major Foreign Policy Address” of June 7, 2022 (Part III)

While Part III of the commentary below stands on its own merits, I recommend first reading Part I and then Part II to gain a comprehensive understanding of my analysis and arguments

Fighting global corruption and kleptocracy 

Samantha Power’s “major foreign policy speech” has two principal objectives.

The first is to spread American liberal democracy throughout the “illiberal” world through a “Revolution of Dignity.”

The second is to fight corruption through a campaign of “dekleptification.”

After unleashing a “Revolution of Dignity” upon the dark world of autocrats, authoritarians, and illiberal forces, Samantha Power plans to sharp-shoot them off one by one in a campaign of “dekleptification” (legally stripping kleptocrats [thieves masquerading as political leaders] of their stolen loot in the US).

In her “major foreign policy speech”, Power presents herself as the dame in shining armor who will plunge a lance into the heart of global corruption.

Power rouses the troops, “We must shine a light on the dark corners where corruption thrives and oligarchs hide their stolen wealth.”

She admonishes the crooks are getting sophisticated. “They seek out weaknesses in the global financial and regulatory systems to launder wealth and hide ill-gotten gains.”

To deal with the global crooks, Power proposes a “dekleptification” program using the Justice/Treasury Departments’ “Kleptocracy Asset Recovery Initiative” (KARI) to “transition countries from kleptocracy to democracy.”

On November 7, 2009, Attorney General Eric Holder, at the Opening Plenary of the VI Ministerial Global Forum on Fighting Corruption and Safeguarding Integrity in Doha, Qatar, quoted President Barack Obama to deliver the message of the age: “The struggle against corruption is one of the great struggles of our time.”

Holder talked about the “cancer of corruption” at the Forum.

To deal with global corruption, Holder made four recommendations: First, “we must renew our efforts for ratification and full implementation of the UN Convention Against Corruption.” Second, “we must work together to ensure that corrupt officials do not retain the illicit proceeds of their corruption.” Third, “countries must end official impunity with regard to corruption.” Fourth, “swift and effective prosecution of corrupt public officials must be at the core of our broader effort to end corruption.”

On July 25, 2010, Attorney General Holder showed up at the African Union Summit in Kampala, Uganda and announced

The U.S. Department of Justice is launching a new Kleptocracy Asset Recovery Initiative aimed at combating large-scale foreign official corruption and recovering public funds for their intended – and proper – use: for the people of our nations. We’re assembling a team of prosecutors who will focus exclusively on this work and build upon efforts already underway to deter corruption, hold offenders accountable, and protect public resources.

Why Holder would choose to make his announcement at the Uganda AU Summit is telling.

Could it be because the Kings of Corruption were gathered there, and he was trying to give them a warning in person?

At the time, I was convinced Obama/Holder had finally found the silver bullet to deal a fatal blow to Africa’s kleptocrats and begin a new chapter of “No more cash and KARI.”

In my November 23, 2009 commentary “Africorruption, Inc.”, I argued that the business of African governments is corruption.

In other words, the majority of African “leaders” seize political power to operate sophisticated criminal enterprises to loot their national treasuries and resources. I pleaded they be treated as transnational organized criminal enterprises.

In 2013, I did a series of commentaries (on seven sectors, e.g. justice, land, construction, education, etc.) on corruption in Ethiopia based on the 448-page World Bank (WB) report, “Diagnosing Corruption in Ethiopia”

Incredibly, thirteen years later, Power seeks to reinvent and launch Holder’s anti-corruption crusade with her own silly “dekleptification” campaign deploying KARI.

KARI is “led by a team of Department of Justice prosecutors working in tandem with the FBI and other federal law enforcement agencies seek to forfeit the proceeds of corruption by foreign officials.”

KARI will be used aggressively to trace, identify, recover and return money stolen by corrupt thug leaders in places like Africa and deposited, invested or held in some form in the US.

Power even egged on foreign journalists to investigate corruption in their own countries and report on corruptly transferred assets into the US. She promised to establish a legal defense insurance fund for them should they be sued.

Power makes this promise in reckless disregard of the personal safety and liberty of journalists who face extraordinary threats and pressures in many African counties.

Power’s journalists’ defense fund will expose journalists in countries like Nigeria and pretty much all over Africa to perilous criminal liability and long jail time for merely reporting on corruption.

For instance, Section 375 of the Nigerian Criminal Code provides, “any person who publishes any defamatory matter is guilty of a misdemeanor and is liable to imprisonment for one year.” If the defamatory material is published with “knowledge of its falsity,” the imprisonment is for two years.”

In fact, 4 Nigerian journalists were criminally prosecuted in 2019 for criminal libel for an investigative report implicating a businessman allegedly involved in oil revenue corruption.

Power’s thoughtless proposal shocks the conscience as she plays dice with the lives of struggling African journalists.

Selling “Power Snake Oil!

Power’s proposal to deal with global corruption and kleptocracies by KARI and a “dekleptification campaign” shows her abysmal lack of knowledge and willful ignorance of KARI and its insurmountable limitations.
Her proposal is tantamount to curing cancer  (of corruption) by prescribing aspirin.

Power is selling snake oil!

I have followed KARI from its inception in 2010.

Back then, I was hopeful KARI could put a dent in the African pandemic of capital flight, money laundering and plunder of national treasuries.

I was so giddy with the prospect of divesting African dictators who have stored their loot in American banks and laundered it into businesses that in my August 9, 2010 commentary, I warned African “dictators who survive by pickpocketing the American taxpayer to beware of the arrival of a “new sheriff” in town.

That “new sheriff” was then-Attorney General Eric Holder.

One of the first cases, if not the very first one, under KARI was against Teodoro Nguema Obiang Mangue (“Mangue”), then 43-year-old son of President Teodoro Obiang Nguema Mbasogo (“Mbasogo”) of Equatorial Guinea (the 2nd President of Equatorial Guinea whose corrupt-to-the-core father has been in power since 1979).

The father and son kleptocrats (thieves) had stolen hundreds of millions of dollars from the people of Equatorial Guinea.

The US first brought a 44-page in rem complaint (basically sued the property, not the person, for seizure as proceeds of corruption) against Mangue to seize Michael Jackson’s white crystal-covered gloves along with a $35 million home in Malibu, CA, a Gulfstream jet and dozens of supercars like Ferraris on April 28, 2011.

I examined the Mangue case in my November 7, 2011 commentary, “To Catch Africa’s Biggest Thieves Hiding in America!”

A second amended 118-page in rem complaint was filed on June 11, 2012.

A settlement was reached in the Mangue case resulting in forfeiture of the foregoing assets in October 2014, 4 years later.

During the Mangue investigation, I came upon evidence in a Wikileaks cablegram which confirmed long held suspicions about massive corruption in the ruling regime at the time, the now declared terrorist Tigrayan People’s Liberation Front (TPLF).

According to the World Bank, “roughly half of the Ethiopian national economy is accounted for by companies held by an EPRDF-affiliated business group called the Endowment Fund for the Rehabilitation of Tigray (EFFORT)… EFFORT’s freight transport, construction, pharmaceutical, and cement firms receive lucrative foreign aid contracts and highly favorable terms on loans from government banks.”

In December 2011, Global Financial Integrity (GFI) reported Ethiopia “lost US$11.7 billion in illegal capital flight from 2000 through 2009” and “corruption, kickbacks and bribery are on the rise in Ethiopia.”

Moreover, “illicit financial flows from Ethiopia nearly doubled to US$3.26 Billion in 2009 over the previous year, with corruption, kickbacks and bribery accounting for the vast majority of that increase.”

GFI concluded, “The people of Ethiopia are being bled dry. No matter how hard they try to fight their way out of absolute destitution and poverty, they will be swimming upstream against the current of illicit capital leakage.”

I examined the GFI study in my December 12, 2011 commentary, “The Art of Bleeding a Country Dry.”

I tried to interest the KARI team to look into the billions the terrorist TPLF had stashed in the US without much success.

A cursory examination of a KARI case, US v. Viceroy Hotel Group,  shows Power’s lack of elementary understanding of the enormous difficulty in using KARI as a weapon of choice against foreign officials and entities who have secreted their ill-gotten wealth in the US.

The Viceroy case involved the Malaysian Sovereign Wealth Fund established to aid that country’s “development and enhance its ability to direct foreign investment.”

High level Malaysian official crooks and their cronies managed to siphon off  more than $4.5 billion from the Fund between 2009-2015.

The complaint in the Viceroy Hotel case was filed under the Kleptocracy Recovery program on June 17, 2017 (specifically under 18 U.S.C. § 981(a)(1)(C), 18 U.S.C. § 981(a)(1)(A) and 18 U.S.C. §§ 1956 and/or 1957).

In October 2019, US prosecutors reached a Settlement to recover more than $700 million in assets traceable to corruption involving the Malaysian Sovereign Wealth Fund.

The final judgement of forfeiture was entered on May 31, 2022, just three weeks ago.

It took 5 full years to litigate and bring a resolution to the Viceroy case! Indeed, there may be residual matters (e.g. arising out of complications from settlement implementation) that could prolong final disposition of the case.

In another case, on May 4, 2020, the US Department of Justice announced transferring over $311 million to the government of the Federal Republic of Nigeria that were traceable to stolen loot of the late Nigerian dictator Sani Abacha and his co-conspirators.

The forfeiture judgment was entered in 2014. It took 6 years to go through the appeal process and dispose of the matter.

It also appears Power has never heard of the Pandora Papers journalistic investigation which unmasked massive global corruption involving hidden ownership of offshore companies, secret bank accounts, private jets, yachts, mansions and artworks by Picasso, etc.

The release of 12 million leaked financial records in the Pandora Papers investigation exposed the extent to which the world’s wealthiest and powerful use legal loopholes to launder money, avoid paying taxes and hide assets.

More than 330 public officials in more than 90 countries, including 14 current world leaders, have been implicated in corruption and/or highly questionable and suspicious financial and banking activities.

The Panama Papers release provided a treasure trove of information on the global cost of corruption to the tune of nearly $1 trillion annually (more than $20 to 40 billion of that loss from developing countries).

Power is clueless about the limitations of KARI and is ignorantly (maliciously?) selling the world the KARI snake oil to cure the cancer of corruption.

Here are 18 reasons Power’s proposed use of KARI to deal with global corruption and money laundering with a tiny team of KARI investigators and prosecutors is laughable and at best quixotic.

In a KARI investigation/civil litigation,

1) a victim country must succeed in tracing the stolen assets, an enormous and expensive task. Lacking victim country tracing of stolen assets, the US will pay a maximum of $5 million for (whistle blower) information leading to the seizure, forfeiture or repatriation of stolen assets in an account at a U.S. financial institution.

2) the victim country must request and gain the cooperation of US authorities  to seize the assets, which could take considerable time. Usually, this requires  requests in the form of a Mutual Legal Assistance or a letter rogatory.

3) there are multiple challenging steps that must be overcome: tracing, freezing, confiscation and repatriation, all time-consuming and expensive to undertake.

4) determining the existence of assets is the primary and decisive step and requires exhaustive financial investigation, which requires deployment of a small army of foreign accounting/financial investigators at great expense.

5) once assets have been identified as suspected proceeds of crime/corruption, freezing those assets becomes critical requiring litigation and a judicial order.

6) a court judgement is necessary to transfer legal ownership of frozen assets back to the requesting/victim country, which often takes years.

7) repatriation of illicitly acquired assets could vary case by case based on terms of settlement or court judgment, and  further litigation if implementation of settlement is disputed.

8) there are often complex issues around third-party claims in which illicit  proceeds are mixed with legitimate income.

9) shell companies and exotic forms of international investment (e.g. cryptocurrency) are used to launder the stolen loot of kleptocrats making it even more difficult to trace, freeze and repatriate corruptly stashed assets.

10) the corrupt crooks who have stolen millions hire top American law firms, public-relations agents and lobbyists to defend them in court and to rehabilitate their image as globally respected businesspeople and philanthropic donors. For instance, Angola’s Isabel dos Santos (whose corrupt father ruled Angola from 1979-2017), Africa’s “richest woman, hired a US lobbying firm with close ties to the Trump administration to stall investigation into her assets in the US.

11) asset recovery is a complex and time-consuming effort requiring enormous resources, high-level and multidisciplinary expertise, and unflagging political will.

12) the proceeding is against corruptly obtained specific property with virtually no criminal liability (except for drug cartel and related money launderers) for those who committed the corruption. In other words, it is not the corrupt crook that is sued but the property (e.g. car, house) anticipation the owner will show up and defend. A crook could simply walk away, and nothing will happen to him/her, only forfeiture of the assets. Why should s/he defend? There is more what that came from!

13) the corrupt thieves have enough money to hire the best lawyers, lobbyists, PR firms, etc., in America to fight a KARI case and settle it for a fraction of what the case is truly worth.

14) the corrupt thieves can prolong a KARI case through appellate review for years.

15) the KARI team is infinitesimally small compared to the global size of the problem. The team may showcase a few big cases but will not make a dent in the global scale of the problem.

16) the KARI team will not be able to play a cat and mouse game with the sophisticated global crooks who will simply go deeper underground to hide their stolen loot.

17) it is all an exercise in futility. The money recovered in a KARI action is returned to the government from which it was stolen. That is like taking the stolen money from the son and giving it to the father who is also a thief. For instance, the money stolen by Abacha was returned to the “Federal Republic of Nigeria to support three critical infrastructure projects previously authorized by the Nigerian government.”

18) the assets of Americans who engage, promote or collude in global corruption are immune to KARI forfeiture since the law applies only to foreign officials. During his July 2015 visit to Ethiopia Obama said, “Nothing will unlock Africa’s economic potential more than ending the cancer of corruption.  (Applause.)  And you are right that it is not just a problem of Africa, it is a problem of those who do business with Africa.” (Italics added.)

In 2021, Nigeria ranked 154/180 countries on the Corruption Index. In the same year, 44% of public service users in Nigeria paid a bribe in the previous 12 months.

Nigeria is described as “West Africa’s second most corrupt country.”

What is the probability that the recovered assets will be used for “three critical infrastructure projects in Nigeria?”

So much for Power’s silly and muddleheaded “dekleptification” program!

What Power should do if she really wants to make a difference and become a global heroine anti-corruption fighter of all time

If there is a political will in the US, there are many ways to deal a fatal blow to the scourge of corruption globally.

I. Amend the Alien Tort Statute to allow criminal prosecutions

To deal effectively with the problem of global crooks, oligarchs and such who have perfected the art of corruption, Congress can amend the Alien Tort Statute (ATS) (a/k/a  Alien Tort Claims Act) codified at 28 U.S.C. § 1350, granting jurisdiction to federal district courts “of all causes where an alien sues for a tort only in violation of the law of nation or of a treaty of the United States.”

A “tort” is a civil wrong (not criminal wrong for which a person can go to jail) for which a court can award injured parties monetary compensation (or an injunction which stops a certain conduct) for their losses.

In an ATS action, injured parties may bring suit to recover damages in the form of monetary compensation or for an injunction, which compels a party to cease an activity.

To learn more about the ATS, click here.

The ATS provides a legal instrument for US courts to gain universal jurisdiction over violations of international law.

Article VI of the US Constitution provides, “This Constitution, and the Laws of the United States … and all Treaties made…  shall be the supreme Law of the Land.

“The United Nations Convention Against Corruption (Arts. 51-59 on “asset recovery” from corruption) is a legally binding universal anti-corruption instrument.”

The US signed the anti-corruption Convention on December 9, 2003.

To fight global corruption, Power should lobby to amend 28 U.S.C. § 1350 as boldfaced thus: “The district courts shall have original jurisdiction of any civil [or criminal] action by an alien for a tort and a crime only, committed in violation of the law of nations or a treaty of the United States.”

Corruption can be prosecuted as a crime in “violation of the law of nations or a treaty of the United States,” namely the UN Convention Against Corruption.

II. Amend the RICO statute to include transnational corruption

The Racketeer Influenced and Corrupt Organizations Act (RICO) allows criminal prosecution and civil penalties for racketeering activity performed as part of an ongoing criminal enterprise.

There are 35 specific crimes prohibited under RICO include, among others,  money laundering, embezzlement and other illegal practices.

Power can lobby to amend Section 1961 of RICO as boldfaced thus: “Racketeering activity means (A) any act or threat involving murder, kidnapping, gambling, arson, robbery, bribery, extortion… and transnational corruption within the framework of the United Nations Convention Against Corruption…”

To learn more about RICO, click here.

III. Fully implement the (United Nations Convention Against Transnational Organized Crime a/k/a Palermo Convention).  

Article 8 (‘‘Criminalization of corruption’’) of the Palermo Convention requires a State Party to “have in place laws criminalizing the giving or receipt of bribes by its domestic public officials, along with participation as an accomplice in such offices, and to consider criminalizing such conduct when it involves a foreign public official or an international civil servant.” (Italics added.)

Power can lobby Congress to pass a law criminalizing not only public officials and international civil servants but also operators of financial institutions that facilitate transnational corrupt transactions.

IV. Amend “Public Law 116–283—JAN. 1, 2021, William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (at 22 USC 10009).

There is a special amendment I would personally enthusiastically support and labor day and night to pass!

Power should lobby Congress to pass the exact verbatim Sudan anti-corruption legislation for Ethiopia 

22 USC 10009 should be amended by substituting the name “Ethiopia” for “Sudan” as follows:

The Secretary of State, in coordination with the Secretary of the Treasury and the Attorney General, shall seek to advance the efforts of the Government of Ethiopia to recover assets stolen from the Ethiopian people, including with regard to international efforts—

(1) to identify and track assets taken from the people and institutions of Sudan through theft, corruption, money laundering, or other illicit means; and

(2) with respect to assets identified pursuant to paragraph (1), to work with foreign governments and international organizations—

(A) to share financial investigations intelligence, as appropriate;

(B) to oversee and manage the assets identified pursuant to paragraph (1);

(C) to advance civil forfeiture litigation, as appropriate, including providing technical assistance to help governments establish the necessary legal framework to carry out asset forfeitures; and

(D) to work with the Government of Ethiopia to ensure that a credible mechanism is established to ensure that any recovered assets are managed in a transparent and accountable fashion and ultimately used for the benefit of the Ethiopian people, provided that—

(i) returned assets are not used for partisan political purposes; and

(ii) there are robust financial management and oversight measures to safeguard repatriated assets.

The terrorist TPLF leaders and their supporters have stolen billons from Ethiopia over the past 27 years.

With earmarked legislation like Sudan, Ethiopia can recover multiple billions of terrorist TPLF assets secreted in the US.

That means, the US does not have to give Ethiopia a dime in aid! 

The Coming/Already Here New World Disorder

Biden says, “there’s going to be a new world order out there, and we’ve got to lead it. And we’ve got to unite the rest of the free world in doing it.”

 Power says, we are witnessing

a moment of profound weakness for the world’s illiberal forces, America and all who share our values…must build on the unity that we have demonstrated in Ukraine to try to extend a broader revolution of dignity to people seeking to be free.

There is NOT going to be a “Revolution of Dignity” or a new “new world order.”

The world Biden and Power are talking about – the O/B New World Order — has become the world of Humpty Dumpty.

Humpty Dumpty sat on a wall
Humpty Dumpty had a great fall
All the president’s horses and all the president’s men
Couldn’t put Humpty together again.

If we must look at the world in binary lens as Power insists, we now have democratic humpty dumpties and authoritarian humpty dumpties.

The democratic humpty dumpties are imploding from internal decay and rot.

Their body politics is terminally infected by the cancer of income inequality, poverty, racism, sexism, inflation and so on.

The authoritarian humpty dumpties are exploding from the cancer of poverty, disease, lack of accountable and transparent governance, ignorance, sectarianism, tribalism, overpopulation and so on.

“Insanity is doing the same thing over and over and expecting different results.”

To save the world, there must be a revolution in the mind, a thought revolution.

Power’s Revolution of Dignity seeks to bring change by blaming others and  demonizing and dehumanizing them.

Power wants to bring change in others but not in America itself.

Power would rather blather about her reverence for “our values, institutions and democracy” than to recognize other peoples and societies have the right to determine their destiny without the imperial orders of the Empire.

Power misses the simplest but biggest point of all in her “major foreign policy” preachments to the world.

When America changes itself, the world around America will change.

When America becomes the change it wants to see, the world will see the change in America and decide if it wants to follow.

When Biden and Co. call for a Revolution of Dignity from their position of economic, military and political superpower dominance, they send a wrong, arrogant and  humiliating message.

That message is clear: You either follow what the US tells you or you will be sent to American Sanctions Hell.

Biden, Blinken, Power, Rice, etc., are blinded by their arrogance and hubris.

The non-Western world is increasingly turning tone deaf to America’s pleas for support and turned off by coercive sanctions diplomacy.

Three days ago, Putin said the BRICS countries – Brazil, Russia, India, China, and South Africa – are currently working on setting up a new global reserve currency.

As Biden fiddles with useless sanctions and punitive measures, Putin is organizing BRICS to eat our lunches.

Enough is enough!

Power should read the Declaration of Independence and think about what brought about the American Revolution in 1776 as she prescribes a Revolution of Dignity to the rest of the world in 2022.

To paraphrase Thomas Jefferson, Africans, and specifically Ethiopians, will no longer suffer the “long train of abuses and usurpations, pursuing invariably the same Object evincing a design to reduce them under absolute imperial despotism.”

The history of the present Biden administration is “a history of repeated injuries and usurpations, all having in direct object the establishment of an absolute tyranny over African states.”

Power’s Revolution of Dignity will be seen in Africa as a supreme usurpation in African sovereignty and the endless meddling and interference an affront to African dignity.

Africans know that a rose by any other name would smell as sweet, but human rights by a new name “dignity” does not conceal the fact that it is an ideological  Trojan Horse for the O/BNWO.

Power’s “major foreign policy speech” is the ultimate exemplar of what not to do to bring about global change.

Power is morbidly obsessed with conflict, destructive competition and winning by playing a zero-sum game with “oligarchs,” “illiberal forces” etc.

Power does not understand leadership is about building consensus based on inclusiveness.

Dr. Martin Luther King Jr. said, “A genuine leader is not a searcher for consensus but a molder of consensus.”

There are deep and seemingly unbridgeable political, social, cultural and economic divisions in the world.

Those divisions will continue to deepen as the Biden administration flounders with a rudderless foreign policy managed by inept, air-headed bleeding heart-save-the-world liberals who take pride in being “educated as an idealist.”

What the Biden administration has done in the Summit for Democracy and Summit of the Americas was to seek dissensus. It got what it bargained for!

The “bad guys” in Africa and Latin America were not to be invited, indeed deliberately excluded, from engagement in matters that are of supreme mutual importance.

The real battleground for the “revolution”

The evilest man of the 20^th century said, “He alone, who owns the youth, gains the future.”

If Africa’s youth are the barometer of Africa’s future, the battle may have been lost.

It is amazing how China is winning the hearts, minds and imaginations of young Africans.

A recent survey showed 76 per cent of young Africans believe China had a positive influence on their lives, compared with 72% for the US.

In 2020, 83% of Africa youth saw the US’s influence as positive while 79% identified China.

What Power and Co. should realize is that preachments about human rights, lectures about the coming “Revolution of Dignity” and promises of the manna of democracy will not win the hearts, minds and stomachs of Africa’s youth.

Africa’s youth are hungry and angry.

They are hungry not just for food but also decent education, jobs and economic opportunity.

They are angry at those who make their lives miserable by imposing sanctions, dangling handouts as though they are house pets who will get a treat only if they do tricks.

They are sick and tired of being sick and tired of being treated like colonial subjects and charitable objects of white supremacy.

Africa’s youth are Africa’s future.

Africa’s youth are the salvation of Africa.

African youth are also the “ticking bomb” of Africa.

“He alone, who owns the youth, gains the future.”

Does America have a future in Africa?

It breaks my heart to see young Ethiopians all over that country harboring deep resentment against America because of the Biden administration’s support for the terrorist TPLF.

As I travelled throughout Ethiopia recently, the country where over 75 percent are said to be under 35, the question I invariably encountered was in the nature of, “Why does America hate Ethiopia? Why does America prefer terrorist TPLF than Ethiopia?”

I tell them emphatically America does not support the terrorist TPLF. Americans hate terrorists, domestic or foreign.

Every single day Americans are terrorized by mass shooters. Every single day!

In 2020, 45,222 Americans died from gun-related injuries!

Americans hate terrorists.

But there is no question in my mind Biden, Blinken, Power, Rice, Senators Coons, Risch, Markey and those I have designated as the “Dirty Dozen” have a special love affair with the terrorist TPLF.

Does America have a future in Ethiopia?

Power thinks she can conquer the world with clichés, platitudes and slogans about democracy and corruption.

To be continued… in Part IV