Amid last week’s furor about Rudy Giuliani pledging to dig up dirt on Joe Biden in Ukraine — and Giuliani’s claim that he wanted to “meddl[e] in an investigation” regarding Biden’s son in Ukraine — was a small, buried detail that may yet unravel Giuliani’s entire plan.

Giuliani, President Donald Trump’s personal lawyer, has worked in Ukraine since Trump’s inauguration, nominally as a security adviser to the city of Kharkiv with his firm Giuliani Partners. However, one of his local clients claimed last week that Giuliani provided far more than technical advice and a handful of photo-ops.

According to Ukrainian developer Pavel Fuks, Giuliani had been hired to work as a “lobbyist” for the government of Ukraine, as well as for the eastern Ukrainian city of Kharkiv. “This is stated in the contract,” Fuks told the Times. The claim backs up local media coverage of the relationship, with one Ukrainian magazine writing that Fuks hired Giuliani in order to create an office in the U.S. for “supporting investment” in Kharkiv. As Mother Jones reported, Giuliani connected with Fuks via TriGlobal Strategic Ventures, a New York-based company that has “advised Russian oligarchs and others with Kremlin ties.”

Giuliani denied Fuks’ claim, saying that Trump remains his “only client.” Giuliani didn’t respond to ThinkProgress’ questions on the matter, and ThinkProgress’ efforts to contact Fuks were unsuccessful.

If anyone needs to be investigated, it’s Rudy Giuliani. Rudy was “a lobbyist for Kharkiv and Ukraine” but failed to register under FARA. His clients, Pavel Fuks and Gennadiy Kernes, have reported ties to organized crime. How is he different than Manafort? https://t.co/O0ZdUkmoex — Michael Carpenter (@mikercarpenter) May 10, 2019

However, Fuks’ claim adds significant fuel to longstanding concerns about Giuliani’s decision not to register as a foreign agent with the Justice Department — even as the agency goes to unprecedented lengths to enforce the Foreign Agents Registration Act.


FARA regulations, on the books since 1938, had remained an afterthought for decades. But thanks to Trump’s rise, and due especially to the work of special counsel Robert Mueller, FARA has seen new life. The DOJ already created a new task force to strengthen FARA, making sure that those working on behalf of foreign governments and officials disclose and detail their work with the DOJ, and prosecutors have shown a new willingness to finally enforce the regulations.

In just the past year, failing to register with FARA has tripped up former Trump campaign manager Paul Manafort and former White House counsel Gregory Craig — both of whom were found guilty of failing to register their work on behalf of the former Ukrainian government. Manafort’s former business associate Rick Gates pleaded guilty to conspiring to violate FARA.

Giuliani, though, has thus far managed to escape scrutiny. And no one’s quite sure why.

Last September, months before Fuks claimed that Giuliani had been hired directly to lobby on behalf of Ukraine, a number of Democratic senators signed a letter to the DOJ requesting information on Giuliani’s FARA filings (or lack thereof). Giuliani admitted last year that he’d never filed a single FARA registration.

The senators specifically pointed to Giuliani’s work in Ukraine, including a press release linking Giuliani with Kharkiv Mayor Gennady Kernes, himself a former member of the party affiliated with ousted Ukrainian strongman Viktor Yanukovych. Both Manafort and Craig were indicted for failing to disclose FARA-related work on behalf of Yanukovych’s regime.


The senators writing to DOJ — including Sen. Elizabeth Warren (D-MA), Sen. Dick Durbin (D-IL), and Sen. Tom Udall (D-NM) — specifically singled out Giuliani’s work in Ukraine:

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.

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And it’s not just Giuliani’s work in Ukraine. As the senators noted, Giuliani’s efforts at recruiting foreign clients — all while working closely with the sitting president — have spanned the globe. He’s represented the Mujahideen-e Khalq (MEK), an Iranian opposition group, in its efforts to lift their Foreign Terrorist Organization designation from the State Department. He recently signed up with Bahrain’s Ministry of the Interior, as The Daily Beast found. And, perhaps most notably, he wrote a remarkable letter to Romanian authorities, chastising the country’s prosecutor for being too effective at combating corruption — all while working at the behest of another lobbyist representing an official caught up in Romania’s anti-corruption dragnet.

But it was Giuliani’s misadventures in Ukraine that gained the most notoriety. And over the past week, the questions — about Giuliani’s aims, about who’s paying for his travel, about how much Trump knows — have only grown.

The DOJ, though, has been silent. As multiple staffers working for the Democratic senators told ThinkProgress, the DOJ never even bothered to reply to their inquiries about Giuliani’s FARA status.


“DOJ never responded to our letter,” a spokesperson for Udall told ThinkProgress. “However, we did confirm that they received it.”

As Sen. Tammy Duckworth (D-IL), another signatory of the letter requesting information on Giuliani’s FARA status, tweeted last Friday, “Giuliani has reportedly been paid by foreign [governments] + political parties, including in Ukraine, but FAILED to register as a foreign agent as the law requires. This is EXACTLY why I joined @SenatorTomUdall to ask DOJ to investigate. We never got a reply.”

Rudy Giuliani has reportedly been paid by foreign gvts + political parties, including in Ukraine, but FAILED to register as a foreign agent as the law requires. This is EXACTLY why I joined @SenatorTomUdall to ask DOJ to investigate. We never got a reply.https://t.co/1KPm7fHqlD https://t.co/ZA9iQKrhri — Tammy Duckworth (@SenDuckworth) May 10, 2019

Giuliani, unsurprisingly, has long denied any need to register as a foreign agent. Despite the fact that experts on FARA regulations have pointed to Giuliani’s foreign work time and again — both in terms of his speeches and political activities — as examples of FARA-related work, Giuliani has claimed that he’s not influencing American policy.

However, Giuliani also offered a caveat last week: “I don’t think I’m influencing American government except on behalf of my client to further an investigation.” That is, Giuliani admitted that he’s not working to “influence” U.S. policy — except when it comes to his client, the president of the United States.

It doesn’t appear concerns about FARA regulations will slow Giuliani’s work anytime soon. Despite calling off his trip to Ukraine — and despite Fuks’ claims that he has paperwork clarifying Giuliani’s work as a lobbyist in Ukraine — Giuliani has refused to acknowledge any issues with his work in Ukraine, especially as it pertains to FARA.

As he said on Friday, when it comes to Ukraine, “I’m going to make sure that nothing scuttles the investigation that I want.”