Kushner Affinity Partners Form ADV: $6.16B AUM, 99% Non-U.S. Clients

On March 22, 2026, Jared Kushner’s private equity firm Affinity Partners filed its annual Form ADV with the SEC, disclosing:

• $6.16 billion in assets under management
• 99% of clients are non-U.S. persons
• Primary capital sources include: Saudi Public Investment Fund ($2B commitment, June 2021); Qatar Investment Authority + Lunate/Abu Dhabi ($1.5B additional, closed December 2024); other Gulf-state sovereign vehicles

The Conflict Structure

This disclosure is filed while Kushner serves as Trump’s informal foreign policy envoy with an active role in:

• U.S.-Gulf state diplomatic and commercial negotiations
• U.S.-Ukraine/Russia ceasefire diplomacy
• U.S.-Israel policy coordination

The 99% foreign-client ratio means virtually all of Affinity Partners’ fee revenue derives from the same foreign sovereign capital pools that Kushner simultaneously represents in policy contexts as an unofficial White House channel.

Prosecutorial Predicate Significance

Under Armitage’s framework, this disclosure constitutes the financial architecture of Kushner’s underboss position in the enterprise:

• New Jersey: Kushner’s residence and potential business nexus — NJ RICO statute is identified by Armitage as the most prosecution-friendly state vehicle
• Foreign Agents Registration Act (FARA): Kushner has not registered as a foreign agent despite managing funds with near-100% foreign sovereign clients while conducting U.S. foreign policy
• Emoluments: The Form ADV makes visible the cash-flow from foreign governments to a Trump family member currently exercising governmental influence — the “underboss” financial architecture in documentary form

Corpus Context

Prior Affinity Partners entries in cascade-timeline:

• 2021-06-01–saudi-pif-2b-affinity-partners-commitment — $2B Saudi PIF commitment, June 2021
• 2024-12-20–kushner-affinity-gets-1-5b-qia-lunate — $1.5B QIA/Lunate additional capital, December 2024

The March 2026 Form ADV is the first primary-source document in the cascade-timeline that discloses the aggregate AUM and foreign-client percentage in a single regulatory filing, making it the load-bearing citation for the prosecutorial-predicate characterization.