A firm helmed by the man who helped run the Republican Party’s efforts in Israel is doing lobbying work for an anti-Semitic foreign strongman without registering as an agent of an overseas power.

Transparency watchdogs called it a likely violation of the rules governing foreign lobbying—the kind of rules that former Trump campaign boss Paul Manafort and Rick Gates were recently indicted for breaking. Manafort could spend the rest of his life in prison, in part for violating lobbying laws.

The news comes as human rights advocates criticize the Hungarian government for becoming increasingly repressive, and as the country’s prime minister makes barely veiled anti-Semitic attacks on his political opponents. That’s on top of Prime Minister Viktor Orbán’s past praise for Hungary’s World War II-era leader, who helped the Nazis kill a half-million Jews, and Orbán’s repeated calls to preserve Hungary’s “ethnic homogeneity.”

BSI Public Affairs, helmed by Tzvika Brot and Ariel Sender, is paying Christopher Harvin of Sanitas International to cultivate relationships with American government officials on Hungary’s behalf. Though federal law requires that lobbyists alert the Justice Department within 10 days when they sign to work for a foreign government, Sanitas waited months to give notice. According to a filing with the Justice Department, Harvin signed with BSI on Oct. 3, 2017, but didn’t alert the Department of Justice until March 7, 2018 (PDF).

That belated filing is also missing information it’s mandated to include. While it says BSI is paying Harvin, it doesn’t say how much and when. And it doesn’t say how the Hungarian government is paying BSI, which is headed by Brot, who ran get-out-the-vote operations in Israel for the Republican Party. Both pieces of information are required by law, though it’s unclear how the Justice Department may enforce these rules.

Additionally, BSI isn’t registered with the Justice Department at all—even though Sanitas’ filings say that BSI is working for a foreign government to influence policymakers in the United States. BSI is incorporated in Delaware.

Lydia Dennett—an investigator for the Project on Government Oversight, a Washington, D.C., watchdog group—said BSI’s failure to register may be illegal.

“It seems very clear that this would be captured by the law,” she said. “But there’s just enough of a gray area or squishiness in the language that it’s not 100 percent certain.”

Virginia Canter, executive branch ethics counsel for Citizens for Responsibility and Ethics in Washington, said she shared that concern.

“They are signing this document on behalf of Hungary,” she said of BSI. “So it seems to me that that they didn’t register raises questions as to whether or not they’re an unregistered foreign agent.”

The filings were first reported by Atlatszo, a Hungarian news site.

A spokesperson for BSI Public Affairs said the company did not register with the Justice Department through its Foreign Agents Registration Act (FARA) database because it has not yet started lobbying.

“BSI did not register under FARA for the simple reason that it was providing only strategic advice to Hungary internally and has not (yet) represented as an agent or otherwise acted on behalf of Hungary or any of its officials, agencies or instrumentalities before the U.S. Executive Branch, Congress, any other agency of the U.S. Government, nor has BSI acted to disseminate information on Hungary’s behalf to the American public,” said Marc Zell, counsel for BSI.

In a statement provided to The Daily Beast, Sanitas said it strives to comply with FARA requirements and that the issues with its filing were because of closing out a past account.

“This process was further delayed because Sanitas was required to update several corporate documents, which were required to file along with a new initial registration statement,” the statement said. “Again, we have worked with FARA throughout this process and an explanation of the delayed filing was detailed in a cover letter filed with the initial registration statement last week. We are also in the later stages of filing an amendment to the initial filing, which details outreach made, as well as the compensation received for our efforts.”

The statement also said that Sanitas is not a lobbying firm and did not provide “any stakeholder outreach in the U.S.” The firm’s FARA filings, however, say it was retained to do “[o]utreach to U.S. media and government officials,” to foster “closer cooperation with the United States,” and to strengthen ties with Western government officials.

The Hungarian Embassy in the U.S. did not respond to a comment request.

Harvin has done unpaid volunteer advance work for Vice President Mike Pence when he travels. He was also a spokesperson for Trump during the transition, according to the Orlando Sentinel.

BSI Public Affairs, meanwhile, appears to be well-connected in Israeli politics; Walla! News reported in January that Prime Minister Benjamin Netanyahu asked Brot to be his spokesman. During the 2016 campaign, Brot (whose name is also sometimes transliterated to Brut or Barot) ran the Republican Party’s efforts to get votes of the 300,000-odd U.S. citizens who live in Israel. According to YNetNews, Trump won three quarters of their votes. Brot is close to Israel’s right-wing Likud Party, per Haaretz.

Before special counsel Bob Mueller’s probe kicked off, firms that violated the Foreign Agents Registration Act rarely if ever faced legal action. But after Mueller charged former Trump campaign bosses Manafort and Gates with violating this law, many lobbyists scrambled to fully disclose any and all foreign-government work to the government.

BSI doesn’t appear to be among them.

Washington’s relationship with Budapest has drawn significant attention under the Trump administration. Breitbart News frequently praises Orbán’s “anti-globalist, conservative government,” and he is arguably the continent’s most powerful voice against helping migrants and refugees. Orbán presents himself as the Trump of Central Europe, and all but endorsed Trump in the 2016 election.

On Thursday, Orbán gave a speech in Budapest that blamed a stateless people group with connections to the financial industry—centuries-old codewords for Jews—for the country’s struggles.

“We are fighting an enemy that is different from us,” he said, according to Shaun Walker of The Guardian. “Not open, but hiding; not straightforward but crafty; not honest but base; does not believe in working but speculates with money; does not have its own homeland but feels it owns the whole world.”

Many human rights advocates say Orbán’s government has made the country less free.

“To a large degree, the Hungarian government is lobbying to deflect criticism of its growing repression of dissent,” said Daniel Balson of Amnesty International.

He said that Orbán’s criticism of billionaire financier and philanthropist George Soros has anti-Semitic overtones, that the media environment in Hungary is becoming increasingly repressive, and that Orbán’s party is looking to dramatically curtail the ability of charities and civil society organizations to help migrants fleeing violence in the Middle East.

“On human rights, the Hungarian government has been going in the wrong direction, and through its resolute inaction on these issues, the Trump administration has really been abating its slide,” Balson added. “The Hungarian government certainly wants to keep it that way and deflect any criticism of its growing human rights violations from being raised in Congress.”

And to do that, you need lobbyists.