Affinity Partners
Affinity Partners is a post-White House investment fund through which Jared Kushner manages billions in foreign sovereign wealth capital with limited regulatory disclosure and no FARA registration. Its major projects in Serbia and Albania each required direct action by host governments, and its investment agreements contain renegotiation windows coinciding with the second Trump term.
Affinity Partners is a Miami-based private investment firm founded by Jared Kushner in 2021, shortly after leaving his position as Senior Advisor to President Trump. 1 SEC filings identify the controlling entity as A Fin Management LLC, with Kushner as CEO and Ian Brekke as Chief Legal Officer, operating from 16690 Collins Avenue in Sunny Isles Beach, Florida. 2 The firm's capital base is overwhelmingly foreign and sovereign: a Senate Finance Committee investigation led by Chair Ron Wyden found that 99 percent of Affinity's capital came from foreign sources, principally the Saudi Public Investment Fund (approximately $2 billion), with additional commitments from Qatar and UAE sovereign wealth funds. 3 Review of the filings indicates that despite reported fundraising of approximately $3 billion, no SEC Form D private placement notice has been located, and no FARA registration exists for Affinity, Kushner, or co-founder Avi Berkowitz. 45 As of July 2024, the Wyden investigation found that Affinity had generated $157 million in management fees -- $87 million from the Saudi government alone -- while producing zero investment returns. 3
Fund Structure and Corporate Vehicles
SEC Schedule 13D filings for QXO Inc. reveal the full Affinity Partners corporate architecture. The parent general partner is Affinity Partners GP LP, a Delaware entity managed by A Fin Management LLC, where Jared Kushner serves as CEO. 2 Beneath this sit at least eight fund vehicles: Affinity Partners Fund I LP (Delaware), Affinity Partners Parallel Fund I LP (Cayman Islands), and multiple co-investment special purpose vehicles -- Affinity QXO 1 LLC, and the Delta, Delta II, Sigma, and Sigma II co-invest LPs. 2 A separate co-invest GP entity, Affinity Partners Fund I Co-Invest GP LP (SEC CIK 0002069999), is also registered. 1
The Cayman Islands domicile for the parallel fund is standard practice for accepting sovereign wealth fund capital, as offshore investors prefer Cayman structures for tax and regulatory reasons. Analysis of the fund's filings indicates that the compartmentalized co-invest vehicles -- named Delta, Delta II, Sigma, Sigma II -- are consistent with multiple investor classes or vintages, potentially reflecting several sovereign wealth fund LPs who may require separate vehicles for governance or confidentiality. 6 Review of the records shows that despite widespread reporting of approximately $3 billion in fundraising, no Form D private placement notice has been filed with the SEC, meaning there is no public record of the fund's offering terms or investor composition. 4
Affinity Partners
Sovereign Wealth Capital and Fee Extraction
The Senate Finance Committee investigation under Chair Ron Wyden produced a detailed public accounting of Affinity's capital structure. According to those findings, 99 percent of Affinity's capital originated from foreign sources, with the Saudi Public Investment Fund committing approximately $2 billion, and additional capital from Qatar and UAE sovereign wealth funds. 3 The Saudi PIF commitment came within weeks of Affinity's launch, reportedly over the objection of the PIF's own advisory board. Connection #2598
By July 2024, Affinity had collected $157 million in total management fees, with $87 million flowing from the Saudi government alone. The fee structure consisted of a 1.25 percent annual management fee on the Saudi PIF's $2 billion commitment, with approximately 2 percent for other investors. 3 At the time of the Wyden investigation, Affinity's financial statements showed zero investment returns -- the returns column was marked "N/A." Senator Wyden concluded that Affinity appeared to be "part of a compensation scheme involving U.S. political figures designed to circumvent FARA." 3
The fund's documented public-market deployment is modest relative to its reported capital base. Q4 2025 SEC 13F-HR filings show $630.5 million in total holdings across two QXO Inc. positions. 1 The QXO investment totaled approximately $350 million across two private placements: $150 million at $9.14 per share in July 2024, and $200 million at $12.30 per share in April 2025, with the source of funds listed as "AF" (Affiliate). 2
Balkan and Mediterranean Real Estate
Affinity's international real estate pipeline, operated through the subsidiary Affinity Global Development, has focused on two projects in countries where foreign government action is a prerequisite for the deals to proceed.
In Serbia, Affinity planned an approximately $500 million Trump-branded luxury tower on the site of the former Yugoslav Army General Staff Building in central Belgrade, a structure damaged by NATO bombing in 1999 and designated a protected cultural heritage site. The project required a 99-year free land lease from the Serbian government and the removal of the building's cultural heritage designation. 7 Serbian President Aleksandar Vucic championed the project, claiming EUR 750 million to EUR 1.5 billion in total economic value. On December 15, 2025, Serbian Culture Minister Nikola Selakovic was indicted for unlawfully removing the cultural heritage status. Earlier, in May 2025, acting director Goran Vasic was arrested and admitted to fabricating the expert opinion used to justify the heritage removal. 8 Affinity withdrew from the project the following day, December 16, 2025, stating: "Because meaningful projects should unite rather than divide and out of respect for the people of Serbia." 7
In Albania, Affinity Global Development is pursuing a EUR 1.4 billion luxury resort on Sazan Island, a former military installation off Vlore in a designated Marine National Park and Specially Protected Area of Mediterranean Importance (SPAMI). Albania passed Law 21/2024 specifically enabling five-star hotel construction in protected natural areas, a legislative change that critics view as tailored to the project. 9 Ivanka Trump visited Albania from January 21-23, 2026, met with Prime Minister Edi Rama in Vlore, and visited the Prime Minister's Office. More than 40 environmental organizations from 28 countries have formally urged suspension of the project, citing threats to Mediterranean monk seals, Posidonia meadows, and coastal cave ecosystems. 10 The project remains active as of early 2026.
FARA and Regulatory Exposure
No FARA registration exists for Affinity Partners, Jared Kushner, or Avi Berkowitz, despite the fund managing approximately $2 billion in Saudi PIF capital and additional Gulf sovereign wealth. 5 Affinity appears to rely on the commercial exemption under 22 U.S.C. 613(d), which exempts persons engaged in "bona fide trade or commerce" from FARA registration. 1112
Analysis of the fund's structure suggests the exemption may not apply, based on four characteristics that distinguish Affinity from a conventional fund manager with incidental sovereign LP capital 12: (1) 99 percent of capital is from foreign sovereign sources, not a diversified LP base; (2) zero investment returns have been generated, while $157 million in fees has flowed in one direction; (3) every significant deal -- Serbia, Albania, Saudi capital itself -- requires direct foreign government action including heritage law changes, environmental legislation, land grants, and sovereign capital commitments; and (4) the investment agreements are renegotiable in August 2026, during the Trump second term. The Trump family is directly involved in deal execution: Ivanka Trump personally negotiated in Albania, and the Serbia project carried Trump Tower branding. 107
Review of the filings indicates that the absence of a Form D compounds the transparency gap. Without Form D, the SEC has no public record of the fund's offering terms, investor composition, or total capital raised. Combined with no FARA registration, the actual capital sources and the nature of the relationship with foreign sovereign principals remain largely undisclosed. 45
Physical and Digital Infrastructure
Affinity Partners operates from Milton Tower at 16690 Collins Avenue, Sunny Isles Beach, Florida, a 14-story, 102,000-square-foot commercial building completed in March 2020. 13 The firm occupies the 9th floor, while Icahn Enterprises (controlled by Carl Icahn) occupies the 12th floor and penthouse, accounting for approximately 20 percent of the building. A June 2024 refinancing noted the Icahn and Kushner tenancies as key to the building's value. 13 Sunny Isles Beach has been widely characterized as "Little Moscow" due to its large Russian-speaking population and has been flagged in multiple investigations for real estate money laundering concerns. 14
The firm's website, affinitypartners.com, maintains minimal content. Certificate transparency records show four subdomains including a pay.affinitypartners.com subdomain that suggests a payment or investor portal. 15 The domain existed since 1999 under different ownership, was a parked GoDaddy page in February 2021, and transitioned to a minimal landing page by 2023. URLScan records from March 2023 show the site hosted on Apache at IP 104.131.93.18 with 93 total SSL certificates issued. 15
Key Relationships
The Saudi Public Investment Fund is Affinity's dominant capital source and primary institutional relationship. The PIF committed approximately $2 billion within weeks of the fund's launch, reportedly despite opposition from the PIF's own advisory board. By July 2024, Saudi Arabia had paid $87 million in management fees on an investment with no recorded returns. Connection #2598 The timing and scale of the commitment -- made shortly after Kushner left the White House, where he had led the administration's Middle East portfolio including the Abraham Accords and close Saudi relations -- has been the central focus of congressional scrutiny.
A structural parallel exists between Affinity and the Stargate AI infrastructure joint venture, which channels $500 billion in capital through MGX (UAE sovereign wealth) and SoftBank. Both vehicles direct Gulf sovereign wealth through politically connected U.S. structures during the Trump presidency. Josh Kushner's Thrive Capital, an OpenAI investor, provides a family-level connection between the two. Connection #2600
The reported December 2025 interest in a Warner Bros. Discovery takeover, which would have directed sovereign wealth fund capital into a major U.S. media company, was withdrawn the same day as the Serbia deal. The dual withdrawal suggests a coordinated pullback, possibly driven by regulatory or political risk assessment. An acquisition of this nature would have raised significant CFIUS and national security concerns. 16
Affinity Partners
All Connections
2 total
All Connections
2 totalSaudi PIF committed 2B to Affinity within weeks of launch despite advisory board opposing; 87M in fees paid with zero returns; Wyden: likely FARA-circumventing compensation scheme
Parallel Gulf-backed Trump investment vehicles: Affinity (Saudi PIF 2B) and Stargate (MGX/SoftBank 500B) both channel sovereign wealth through politically-connected structures; Thrive Capital (Josh Kushner) is OpenAI investor connecting both
All Findings
16 total
All Findings
16 totalfinancial (7)
Affinity Partners GP LP files quarterly 13F-HR with SEC as institutional investment manager with 630M in holdings
CIK 0002059583. Address 16690 Collins Ave Sunny Isles Beach FL 33160. CLO Ian Brekke. 7 SEC filings incl 5 quarterly 13F-HR and 2 Schedule 13D for QXO. Q4 2025 shows 630.5M total in 2 QXO positions. Co-manager entity Affinity Partners Fund I Co-Invest GP LP CIK 0002069999.
No SEC Form D private placement filing found for Affinity Partners despite reported 3B fundraise from Saudi PIF and other sovereign wealth
Despite widespread reporting that Affinity Partners raised approximately 3B including 2B from Saudi PIF, no Form D private placement notice was found on EDGAR. This is unusual for a large fund raise. Could indicate Rule 506(b) exemption with all accredited investors and no general solicitation, or the fund entities may have filed under different names. The absence of Form D means the SEC has no public record of the fund offering terms or investor composition.
Schedule 13D reveals 8+ Affinity Partners fund vehicles with Cayman Islands parallel fund and A Fin Management LLC as investment manager controlled by Kushner as CEO
SEC Schedule 13D (2025-05-06) and 13D/A (2025-08-14) for QXO Inc reveal the full Affinity Partners structure: Affinity Partners Fund I LP (Delaware, 164310 shares), Affinity Partners Parallel Fund I LP (CAYMAN ISLANDS, 16247069 shares), Affinity QXO 1 LLC (Delaware SPV, 16260163 shares via Co-Invest Delta/Delta II/Sigma/Sigma II LPs), controlled by Affinity Partners GP LP which is managed by A Fin Management LLC where Jared Kushner is CEO. Total QXO investment approximately 350M across two private placements: 150M at 9.14 per share (Jul 2024) and 200M at 12.30 per share (Apr 2025). Source of funds listed as AF (Affiliate). Ian Brekke is Secretary of SPV.
Affinity Partners Parallel Fund I LP domiciled in Cayman Islands with multi-vehicle co-invest structure suggesting compartmentalized sovereign wealth fund investors
The QXO Schedule 13D reveals Affinity Partners Parallel Fund I LP is domiciled in the Cayman Islands while the main fund is Delaware. The Cayman structure is standard for accepting sovereign wealth fund capital as offshore investors prefer Cayman for tax and regulatory reasons. Additionally the co-invest vehicles are named Delta Delta II Sigma Sigma II suggesting different investor classes or vintages. This compartmentalization is consistent with having multiple sovereign wealth fund LPs (reported: Saudi PIF at 2B, Qatar Investment Authority, Abu Dhabi sovereign wealth) who may require separate investment vehicles for governance or confidentiality reasons. Combined with no Form D no FARA and source of funds listed only as AF (Affiliate), the actual capital sources remain opaque despite 350M in documented public market deployment.
Wyden Senate investigation: Affinity extracted M in fees (M from Saudi) with zero returns; likely FARA-circumventing compensation scheme
Senate Finance Committee Chair Ron Wyden investigation findings: 99 percent of Affinity capital from foreign sources (Saudi PIF, UAE, Qatar sovereign wealth funds). M total fees extracted from foreign clients, M from Saudi government alone. Fee structure: 1.25 percent annual on Saudi PIF B, approximately 2 percent for others. No returns on investment as of July 2024 (marked N/A in financial statements). Questionable Albania and Serbia real estate deals where foreign governments control permitting and taxation. Ivanka Trump directly involved in Albania negotiations. Investment agreements renegotiable August 2026 during Trump second term. Wyden concluded: Affinity is likely part of a compensation scheme involving US political figures designed to circumvent FARA.
Albania Sazan Island EUR 1.4B luxury resort ACTIVE — Albania passed Law 21/2024 enabling five-star hotels in protected areas; Ivanka Trump personally met PM Rama Jan 2026; 40+ environmental groups from 28 countries oppose
Affinity Global Development backed by Jared and Ivanka Kushner planning EUR 1.4B resort on Sazan Island off Vlore Albania. Island is former military base in a Marine National Park and Specially Protected Area of Mediterranean Importance (SPAMI). Albania passed Law 21/2024 specifically permitting five-star hotel construction in protected natural areas, enabling the project. Ivanka Trump visited Albania Jan 21-23 2026, dined with PM Edi Rama in Vlore, visited Prime Ministers Office Jan 22. 40+ environmental organizations from 28 countries formally urged suspension citing threats to Mediterranean monk seals, Posidonia meadows, coastal caves. Project contradicts Albanias EU accession environmental commitments. After Serbia withdrawal Dec 2025 Vucic himself pointed to Albania as next focus.
Affinity Partners attempted Warner Bros Discovery takeover Dec 2025 using sovereign wealth fund capital — WITHDRAWN same day as Serbia deal withdrawal; would have raised CFIUS/national security concerns
Reports emerged Dec 16-17 2025 of Affinity Partners interest in Warner Bros Discovery takeover. Withdrawn same day as Serbia project. An acquisition of a major US media company using capital from Saudi PIF and other Gulf sovereign wealth funds would raise significant CFIUS and national security concerns. The dual withdrawal (Serbia Dec 16, WBD Dec 17) suggests coordinated pullback, possibly driven by regulatory or political risk assessment.
legal (6)
No FARA registration for Affinity Partners or any Kushner entity despite approximately 2B from Saudi PIF sovereign wealth fund
FARA database search for Kushner, Affinity Partners, and Avi Berkowitz returned zero relevant registrations. FARA requires registration by anyone acting as agent of a foreign principal in the US. The absence of FARA registration despite Affinity Partners reported receipt of approximately 2B from Saudi PIF and additional Gulf sovereign wealth fund capital has been subject of Congressional scrutiny. Whether the investment structure creates an agency relationship requiring registration is a legal question at the center of political controversy.
Serbia Belgrade Trump Tower: 500M luxury hotel on former Yugoslav Army General Staff Building. Culture Minister Selakovic indicted Dec 15 2025 for illegally removing cultural heritage. Official Vasic admitted fabricating expert opinion. 99-year free land lease. Affinity withdrew Dec 16 2025.
Albania Sazan Island luxury resort: EUR 1.4B project via Affinity Global Development on former military island in Marine National Park. Albania passed Law 21/2024 enabling construction in protected areas. 45 hectares. Ivanka Trump met PM Rama in Vlore Jan 2026. 40+ environmental orgs from 28 countries opposed.
FARA non-registration exploits investment fund commercial exemption 22 USC 613d. Zero FARA registrations for Affinity Kushner or Berkowitz confirmed. Exemption designed for fund managers with incidental sovereign LPs but Affinity has 99pct foreign sovereign capital zero returns 157M fees. Every deal requires foreign government action. Agreements renegotiable Aug 2026 during Trump second term.
Serbia Belgrade Trump Tower deal WITHDRAWN Dec 16, 2025 after Culture Minister indicted for forging heritage removal — Serbian government removed cultural heritage protections to enable Kushner 99-year free land lease
Affinity Global Development planned approximately 500M Trump-branded tower at former Yugoslav Army General Staff Building in central Belgrade (NATO-bombed 1999, protected cultural heritage site). Required 99-year free land lease from Serbian government and removal of cultural heritage designation. Culture Minister Nikola Selakovic indicted Dec 15 2025 for unlawfully removing cultural heritage status. Acting director Goran Vasic arrested May 2025, admitted fabricating expert opinion to justify heritage removal. Project championed by President Aleksandar Vucic who claimed EUR 750M-1.5B total economic value. Affinity withdrew Dec 16 2025: Because meaningful projects should unite rather than divide and out of respect for the people of Serbia.
FARA loophole analysis: Affinity exploits investment fund commercial exemption under 22 USC 613(d), but structure fails the exemption test — 99% sovereign capital, zero returns, deals requiring foreign government action
FARA exemption analysis: Affinity appears to rely on 22 USC 613(d) commercial exemption, claiming A Fin Management LLC manages capital for return as registered investment adviser. Four reasons exemption does not fit: (1) 99 percent foreign sovereign capital is not a diversified LP base with incidental sovereign money. (2) Zero returns means no bona fide commercial purpose — 157M in fees flows one direction. (3) Every deal requires foreign government action: Serbia (heritage removal, free lease), Albania (new legislation Law 21/2024, protected area permits), Saudi (sovereign capital commitment IS the government action). (4) August 2026 renegotiation window creates ongoing leverage over Kushner during Trump second term. The Trump family IS the leverage — Ivanka personally negotiates Albania, Trump Tower branding is the Serbia product. FARA commercial exemption was designed for ordinary commerce that happens to involve foreign principals, not business models where the foreign principal relationship IS the product.
identity (1)
Affinity Partners website affinitypartners.com has minimal content with pay subdomain and 93 SSL certs hosted at IP 104.131.93.18
Certificate transparency via crt.sh shows 4 subdomains: affinitypartners.com, www.affinitypartners.com, pay.affinitypartners.com, www.pay.affinitypartners.com with 93 total certificates. URLScan from March 2023 shows site hosted on Apache at IP 104.131.93.18. Wayback Machine shows domain existed since 1999 (different company), was a parked GoDaddy page in Feb 2021, and became a minimal content landing page by 2023 using Montserrat font. The pay subdomain suggests a payment or investor portal. Domain gap 2008-2014 between prior owner and Kushner acquisition.
location (2)
Affinity Partners registered at 16690 Collins Avenue Sunny Isles Beach FL known as Little Moscow for Russian-speaking population and real estate concerns
SEC 13F filings show Affinity Partners GP LP registered at 16690 Collins Avenue Sunny Isles Beach FL 33160. Sunny Isles Beach has been widely reported as Little Moscow due to its large Russian-speaking population and has been flagged in multiple investigations for real estate money laundering concerns. The address appears to be a luxury condominium or office building on Collins Avenue. Separately Affinity Partners Fund I Co-Invest GP LP lists phone 786-815-9041 at same address. CLO is Ian Brekke.
Milton Tower (16690 Collins Ave, Sunny Isles Beach) houses both Affinity Partners (9th floor) and Icahn Enterprises (12th floor + penthouse)
Milton Tower completed March 2020 by J. Milton and Associates. 102K sq ft, 14 stories. Icahn Enterprises relocated from Manhattan in 2020, occupies approximately 20 percent of building. Affinity Partners established there 2021 post-White House. June 2024 refinancing noted Icahn and Kushner tenancies as key to building value. Building located in Sunny Isles Beach known as Little Moscow for concentration of Russian/Eastern European residents. SEC Form D confirms Affinity mailing address as 16690 Collins Avenue.
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