Seven Senate Democrats Request Immediate DOJ Review of Giuliani’s FARA Compliance

Public reports suggest Rudolph Giuliani has conducted numerous political & public relations activities on behalf of foreign entities

WASHINGTON – Today, U.S. Senators Tom Udall (D-N.M.), Elizabeth Warren (D-Mass.), Tammy Duckworth (D-Ill.), Richard Blumenthal (D-Conn.), Sheldon Whitehouse (D-R.I.), Jeff Merkley (D-Ore.), and Richard Durbin (D-Ill.) requested that the Department of Justice’s (DOJ) National Security Division immediately review whether President Trump’s personal attorney, Rudolph Giuliani, is in compliance with the Foreign Agents Registration Act (FARA), including whether he has an obligation to register any undisclosed political activities, has any delinquent filings, or has any deficiencies or abnormalities in his registration statements.

“We write regarding public reports that suggest the President’s personal attorney, Mr. Rudolph Giuliani, has conducted a number of political and public relations activities on behalf of foreign entities that implicate registration requirements of [FARA],” the senators wrote. “Mr. Giuliani’s numerous foreign clients and ongoing communications with senior U.S. government officials raise significant concerns.” As the senators note, Giuliani reportedly receives compensation from: the Party of Regions in Ukraine, the Mujahedin-e-Khalq (MEK), as well as unnamed clients in Colombia and Brazil. Press releases on Mr. Giuliani’s security company’s website describe additional work on behalf of the governments of Chile, Dominica, Uruguay, the Dominican Republic, and El Salvador.

“As President Trump’s personal attorney, Mr. Giuliani communicates in private with the President and his senior staff on a regular basis,” the senators continued. “Without further review, it is impossible to know whether Mr. Giuliani is lobbying U.S. government officials on behalf of his foreign clients.”

The senators wrote that Giuliani’s public activities also raise FARA concerns. “For example, Mr. Giuliani’s participation in the MEK’s lobbying effort to be removed from the U.S. State Department’s Foreign Terrorist Organization list is well-documented. In nearly every article describing the group’s lobbying effort, Mr. Giuliani’s name, quotes, and public remarks are used as evidence of the effort’s credibility. Mr. Giuliani also regularly advocates for regime change in Iran, which is one of MEK’s top objectives.”

The senators also cited as a matter of concern Giuliani’s work on behalf of the city of Kharkiv, Ukraine, whose mayor is a member of the Party of Regions – known for its connections to the Russian Government and anti-democratic activity. Paul Manafort and Rick Gates, who served in senior roles on the president’s 2016 campaign team, were convicted of or pleaded guilty to criminal acts in part because of their work on behalf of this Russian-backed Ukrainian political party.

“The purpose of FARA is to ensure the American public can make informed judgments about the political activities of foreign agents in the U.S. We appreciate the recent efforts by the Department to ensure better compliance with FARA, and as is the long-standing practice of the Department of Justice, this law should be applied without regard to political association, activities, or beliefs,” the senators wrote. “Given Mr. Giuliani’s ongoing relationships with foreign governments as well as his concurrent representation of the President, we hope you will agree this situation merits immediate review.”

The full text of the letter is below and here.

The Honorable John C. Demers

Assistant Attorney General

Department of Justice

950 Pennsylvania Avenue, NW

Washington, DC 20530-0001

Assistant Attorney General Demers:

We write regarding public reports that suggest the President’s personal attorney, Mr. Rudolph Giuliani, has conducted a number of political and public relations activities on behalf of foreign entities that implicate registration requirements of the Foreign Agents Registration Act (FARA). Given these reports regarding Mr. Giuliani’s work on behalf of foreign governments and interests, we request that the Department of Justice review whether he is in compliance with FARA, including whether he has an obligation to register any undisclosed political activities, has any delinquent filings, or has any deficiencies or abnormalities in his registration statements.

FARA generally requires individuals working to influence U.S. government officials or the public on behalf of a foreign entity to register that activity with the Department. The Act defines political activities that require registration as “any activity that the person engaging in believes will in any way influence any agency or official of the Government of the United States.” However, FARA also covers any type of public relations directly or indirectly on behalf of a foreign principal, as well as any advising on the domestic or foreign policies of the United States.

Mr. Giuliani’s numerous foreign clients and ongoing communications with senior U.S. government officials raise significant concerns. Mr. Giuliani reportedly receives compensation from: the Party of Regions in Ukraine, the Mujahedin-e-Khalq (MEK), as well as unnamed clients in Colombia and Brazil. Press releases on Mr. Giuliani’s security company’s website describe additional work on behalf of the governments of Chile, Dominica, Uruguay, the Dominican Republic, and El Salvador.

As President Trump’s personal attorney, Mr. Giuliani communicates in private with the President and his senior staff on a regular basis. Without further review, it is impossible to know whether Mr. Giuliani is lobbying U.S. government officials on behalf of his foreign clients.

Mr. Giuliani’s public activities have also raised FARA concerns. For example, Mr. Giuliani’s participation in the MEK’s lobbying effort to be removed from the U.S. State Department’s Foreign Terrorist Organization list is well-documented. In nearly every article describing the group’s lobbying effort, Mr. Giuliani’s name, quotes, and public remarks are used as evidence of the effort’s credibility. Mr. Giuliani also regularly advocates for regime change in Iran, which is one of MEK’s top objectives. Given Mr. Giuliani’s receipt of significant payment from the MEK and simultaneous advocacy on behalf of that group and its objectives, his actions may require registration under FARA.

Additionally, Mr. Giuliani’s work on behalf the city of Kharkiv, Ukraine, whose mayor is a member of the Party of Regions is also concerning. The Ukrainian Party of Regions’ connections to the Russian Government and anti-democratic activity are well-documented. Paul Manafort and Rick Gates, who both served in senior roles on the President’s 2016 campaign team, were convicted of or pleaded guilty to criminal acts in part because of their work on behalf of this Russian-backed Ukrainian political party. Mr. Giuliani’s financial connection to the organization, the organization’s close ties with the Russian government, and Mr. Giuliani’s ongoing public advocacy against Special Counsel Robert Mueller’s investigation of Russian interference in the 2016 election raises further questions that warrant review.

Most recently, it has come to light that Mr. Giuliani was paid for sending a letter in August of 2018 to the President of Romania criticizing that nation’s anti-corruption program on behalf of a global firm that reportedly has a wealthy Romanian citizen as a client. Mr. Giuliani’s letter advocates for a position that is in contradiction of the U.S. State Department’s position on the matter. This activity raises both the question of whether Mr. Giuliani may have attempted to influence U.S. policy and what the U.S. government’s true position is, given his role as the President’s personal attorney and public spokesman.

The purpose of FARA is to ensure the American public can make informed judgments about the political activities of foreign agents in the U.S. We appreciate the recent efforts by the Department to ensure better compliance with FARA, and as is the long-standing practice of the Department of Justice, this law should be applied without regard to political association, activities, or beliefs.

Given Mr. Giuliani’s ongoing relationships with foreign governments as well as his concurrent representation of the President, we hope you will agree this situation merits immediate review.

Sincerely,