Freezing Order: A True Story of Money Laundering, Murder, and Surviving Vladimir Putin's Wrath

Bill Browder

54 pages 1-hour read

Bill Browder

Freezing Order: A True Story of Money Laundering, Murder, and Surviving Vladimir Putin's Wrath

Nonfiction | Autobiography / Memoir | Adult | Published in 2022

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Chapters 34-42Chapter Summaries & Analyses

Chapter 34 Summary: “Senator Grassley, Summer 2017”

The new judge in the Prevezon case admitted Gorokhov’s evidence. However, the night before the trial was slated to begin, Denis Katsyv agreed to pay $5.9 million to settle the case. Browder, who was to be the first witness (and was sick with the flu in Washington, DC), was relieved and pleased with this outcome. To avoid trial, the company paid a high price, including millions in legal fees. In addition, NBC aired a “hard-hitting exposé” (249) about the Magnitsky case, Nemtsov’s assassination, and Kara-Murza’s and Gorokhov’s attempted assassinations.


Browder was in Washington, DC, at the request of Republican Senator Chuck Grassley, who was interested in the lack of enforcement of the FARA law. Grassley planned to compel officials from the DOJ before his Senate Judiciary Committee to determine why they hadn’t followed up on Browder’s complaint.

Chapter 35 Summary: “Trump Tower, Summer 2017”

The New York Times reported that Veselnitskaya, the Russian attorney, met with Donald Trump, Jr., Jared Kushner (Trump’s son-in-law), and Paul Manafort, Trump’s campaign manager, at Trump Tower on June 9, 2016. Because the press was now very interested, Browder granted many interviews. Later, it was discovered that a former Soviet counterintelligence officer, Rinat Akhmetshin, was also at that meeting. Trump, Jr. claimed that he attended because the Russians promised evidence to incriminate Hillary Clinton. At a Gala dinner, Trump changed seats to sit near his wife, Melania, and near Putin, to whom he spoke without staff or translators for about an hour. Trump said that they spoke about the adoption ban, which Browder argues is code for the Magnitsky Act. Trump, Jr. added that this was discussed at the Tower meeting too. Browder attributes Putin’s intervention in American politics to his goal of undermining the Magnitsky Act. The Trump Tower scandal brought press attention to the Senate Judiciary Committee hearing on FARA to which Trump, Jr., Simpson, and Manafort had been invited. Finally, the press had “woken up to” (256) Browder’s FARA complaint.

Chapter 36 Summary: “Senate Judiciary Committee, Summer 2017”

The same day that Browder was to testify before the Senate Judiciary Committee, Trump, Jr., Simpson, and Manafort were supposed to do so too. As a result, there were crowds and lots of press. However, Trump, Jr. and Simpson cut a deal to testify behind closed doors, and Manafort wouldn’t come without a subpoena. The DOJ officials testified first and quite monotonously. The Democrats invoked the two-hour rule, ending the hearing after two hours, and required Browder to return the next day to give testimony. To his disappointment, there were no crowds and minimal press the next day. He nonetheless told his story, explaining Putin’s intentions in interfering with the US election. He connected the stolen $230 million to Putin’s close friend Roldugin and noted that this was one of “thousands of crimes Putin had benefited from, allowing him to accumulate an estimated $200 billion fortune” (263). The Magnitsky Act threatened that fortune. Despite the lack of journalists at the hearing, Browder’s testimony got extensive press coverage after it appeared on C-SPAN. More importantly, it shored up strong support in Congress and with the public for the Magnitsky Act. It would never be repealed.

Chapter 37 Summary: “Global Entry, Fall 2017”

Angered with the outcome of the Senate Judiciary hearing, Russia again put Browder on trial in absentia. On December 24, 2017, he was found guilty, and an 18-year prison sentence awaited him if he were extradited to Russia. Browder’s US visa and global entry status were briefly revoked because of a notice that Russia filed with Interpol. The arrest warrant was quickly deleted. Putin was undoubtedly incensed with Browder because Canada passed a Magnitsky Act in early October 2017. Browder saw this as a “major milestone” (265) because other countries were more likely to follow Canada’s than the US’s lead.

Chapter 38 Summary: “Danske Bank, Winter-Summer 2018”

Browder encountered a problem when trying to cross the Swiss border and was later arrested in Madrid, Spain. Chaika, the Russian general prosecutor, vowed to keep pursuing him. Browder nonetheless traveled to Denmark, where two journalists had confirmed Kleiner’s research showing that $200 of the stolen $230 million was laundered through the Estonian branch of Danske Bank—and found another $8.3 billion of suspicious money originating in Russia and former Soviet States from 2007 to 2015. Their article, published on July 3, 2018, created a national scandal, and the Danish bank underwent a thorough audit. It was the “third largest money laundering scandal” (274) in European history. Browder noted too that Lithuania and Latvia, former Soviet republics, passed Magnitsky Acts.

Chapter 39 Summary: “An ‘Incredible Offer,’” Summer 2018

Browder was uneasy about a threat to his life, especially in light of the Kremlin’s having sent two assassins to England to kill a former Russian intelligence officer in March 2018. Because he was in Aspen, Colorado, on the eve of the Trump–Putin summit, Browder felt more secure. Before the summit, the US had indicted 12 Russian military intelligence officers for hacking into the Democratic National Committee’s server and interfering in the US election. It was a strong case. At the summit, Putin publicly announced that he’d turn the 12 Russians over in exchange for Browder. Trump characterized this as “an incredible offer” (280). Browder’s phone exploded with texts and calls. The next day, he did multiple interviews but was sure to disguise his location. He didn’t want to disclose that he was in the US.

Chapter 40 Summary: “98-0, Summer, 2018”

Overplaying his hand, Putin accused Ambassador McFaul, Special Agent Hyman, Congressional staffer Kyle Parker, and others of being part of Browder’s crimes (284). The Russians listed others whom they wanted, and all had some tie to advocating for the Magnitsky Act or prosecuting Prevezon. Ambassador McFaul was outraged that the White House hadn’t immediately spoken out against these accusations. Browder was personally concerned because on the second day of interviews, his location in the US was inadvertently disclosed. However, there was widespread reaction in Washington, DC, and the Senate passed a resolution, 98-0, calling on Trump to never accept Putin’s offer of an exchange. The resolution specifically noted Browder’s bravery in exposing Magnitsky’s murder.

Chapter 41 Summary: “$234 Billion”

On September 13, 2006, Andrei Kozlov, chair of Russia’s Central Bank, was shot and killed. He’d identified and was trying to stop “a major money laundering scheme originating in Russia and flowing through Sampo Bank” (290) in Estonia. Danske Bank ultimately acquired Sampo Bank. After the journalists’ exposure of Danske Bank’s involvement in money laundering, a thorough audit revealed the total amount of dirty money moving from Russia to that branch: $234 billion. Browder notes that this was just one branch in one country and estimates that the total amount of dirty money flowing from Russia was at least $1 trillion. The revelation of the $234 billion prompted a criminal investigation in Denmark and eventually caused the EU to discuss passing a Magnitsky Act.


In response, Russia now accused Browder of murdering Magnitsky. Up to this point, they’d claimed that his death didn’t involve foul play. Browder argues that Putin would literally do anything to protect his fortune. However, Westerners such as Cymrot and Moscow have enabled Putin to commit such crimes.


Browder began this work to honor Magnitsky and continued it to survive—and because it was the right thing to do. At date of the book’s publication, Magnitsky Acts were in effect in 34 countries, and more than 500 people had been sanctioned because of these laws. Magnitsky’s sacrifice wasn’t in vain.

Chapter 42 Summary: “Epilogue”

Browder recounts what happened to some major players in this fight. Russian attorney Veselnitskaya was indicted by the US government on January 8, 2019, for falsely representing that she worked for a private Russian citizen when she worked for the government. Her US assets were frozen. Moscow, Cymrot, and BakerHostetler faced no consequences. Rohrabacher was defeated in his House race by a Democrat in 2018.


Gorokhov, who still lives in Moscow, is slowly going blind as a result of the attempt on his life. Kara-Murza continues to advocate for Magnitsky laws and was poisoned again in 2017 but survived. Magnitsky’s wife, Natasha, stayed in Russia for some time after her husband’s death. She was questioned about her husband and then summoned again and again but failed to appear after the first time. On September 20, 2012, she and Nikita, her and Sergei’s son, moved to London. Browder saw to their needs. Hoping that Nikita would attend an Ivy League university in the US, Browder was both surprised and proud when Nikita stood up for himself. He decided to study art at a top art and design school in the US.

Chapters 34-42 Analysis

Putin and the Russian government relentlessly sought to punish Browder and others who advocated for the Magnitsky Act, which emphasizes all three of the book’s themes: The Corruption and Criminality of the Russian Government, The High Price of Dissent in Russia and Beyond, and Western Choice—to Abet or Fight the Russian Government’s Crimes. The filing of notices with Interpol caused Browder problems and stress whenever he crossed international boundaries. The press conference after the Putin–Trump summit dealt a significant blow, with Putin calling for Browder’s extradition to Russia in return for 11 Russians charged with interfering in the 2016 US presidential election. Trump was open to it. Anyone—even a British citizen—pays a steep price for opposing corruption and crime in Russia. In this case, Putin overplayed his hand, accusing special agents and a US ambassador of crimes and calling for their extradition. Despite the US Senate’s bipartisan condemnation of Putin’s maneuver, the White House was largely silent. In the Trump Tower meeting and at a gala dinner, Trump and his son reported that they’d spoken with the Russians about the adoption ban. To Browder, this was code for the Magnitsky Act. The adoption ban was retaliation for the passage of the law. It was Putin’s most important objective to get the Magnitsky Act scrapped. It was concerning that Trump didn’t support the Magnitsky Act.


The scale of dirty money coming out of Russia and enriching Putin and Russian criminals is staggering. Browder highlights the $234 billion that flowed through a branch of one bank in Estonia. Given that, he projects that the total amount exceeds $1 trillion. Thus, Putin is relentless in protecting his fortune and those of his allies. He’ll use any means necessary to do so, including disinformation, false arrests, and murder. No distinction exists between the Russian government and organized crime.


Browder is pleased to see that Magnitsky Acts are making a difference and inflicting some financial pain on these criminals. He notes that 34 countries have passed such laws. The Prevezon case settled for $5.9 million. In addition, the company had to pay hefty legal fees. Browder considers this an admission of guilt. Freezing the assets from crimes and for those who violate human rights brings some measure of justice to the victims and allows them to be remembered. The fight, however, continues. In the epilogue, Browder notes that Putin’s Western enablers have yet to pay any price for supporting him.

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