“Because Joe will not work with a Super PAC or take PAC money for his campaign, everyone is limited to $2,800 as a maximum gift,” Rasky wrote in fundraising email sent in April and obtained by POLITICO. “That will require a lot of work and a lot of checks to finance a presidential campaign effort.”

The same super PAC previously went by a different name, For the People PAC, but it existed only briefly in April, shortly before Biden launched his run for president. At the time, Matt Tompkins, a Democratic fundraiser, told The Hill: “You won’t win in 2020 by unilaterally disarming.”

But Biden senior adviser Kate Bedingfield shut down For the People PAC’s buzz when she replied to a tweet about the group with a brief statement: “. @JoeBiden does not welcome support from super PACs.” For the People PAC went quiet shortly afterward and never reported raising or spending money.

The filing for Unite the Country, which was first reported by Bloomberg News, marks the official beginning of an outside effort to boost the former vice president, a move that could raise and spend unlimited sums of money and give the cash-strapped Biden campaign a boost.

The group of operatives have hustled to form the PAC since Biden shifted his stance on super PACs and opened the door to their help last week. In past months, donors have been probed by Biden allies to see whether they’d be open to giving more money beyond their initial campaign checks. Several have told POLITICO they would.

Rasky isn’t a registered lobbyist, although others at his firm lobby for a handful of federal clients, including Raytheon, the Massachusetts-based defense contractor. Rasky owns an 87.2 percent stake in the firm, according to a Justice Department disclosure filing.

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Rasky registered as a foreign agent earlier this year to advise Azerbaijan’s government on strategic communications on a contract worth $15,000 a month. But he stopped working for Azerbaijan in August, he wrote in an email to POLITICO, supplying a copy of a letter his lawyer sent to the Justice Department on Aug. 27. The firm no longer represents foreign clients, he said.

Rasky’s firm also represented a Bangladeshi political party last year, reaching out to reporters at The New York Times, The Washington Post, POLITICO and other outlets on the party’s behalf, according to a disclosure filing. The firm worked for the party, the Bangladesh Nationalist Party, as a subcontractor to Blue Star Strategies, a Washington lobbying shop run by two veterans of the Clinton administration.

Blue Star has another connection to the Bidens: The firm advised the Ukrainian energy company Burisma Holdings while Hunter Biden served on its board, according to The Times .

Karen Tramontano, Blue Star’s chief executive, said in an interview that she didn’t know Rasky. She hired his firm because Anne Tyrrell, a senior vice president in Rasky Partners’ Washington office, had come recommended to her. Tyrrell has since left Rasky Partners. Tramontano declined to comment on her firm’s work for Burisma.

President Donald Trump has attacked Hunter Biden’s work for Burisma, accusing Joe Biden of pressing Ukraine to fire its top prosecutor while he was vice president in an effort to help the company. But Ukraine’s top prosecutor at the time, Viktor Shokin, was widely seen as corrupt and there’s no evidence Joe Biden acted improperly. Trump is facing potential impeachment for urging Ukraine’s president to investigate the Bidens.

Rasky never registered to work for the Bangladesh Nationalist Party, and his firm stopped working for the party in January, according to a disclosure filing.

“I know nothing about Blue Star,” Rasky wrote in an email to POLITICO. “I never worked on the account.”