As I’ve mentioned a number of times and as recently as the piece I wrote last night, the FARA enforcement system has always been a bit of a joke. There are various ways to tiptoe around compliance and the folks in charge of the office – at least back when I was actively reporting on these kinds of stories – were hardly interested in aggressive enforcement. But having perused some more materials and talked to a few more people, I think Paul Manafort likely has serious legal problems on his hands.

On its face, what Manafort was doing on behalf of Viktor Yanukovych was neither unprecedented nor wrong by many measures. ‘Wrong’ is a highly fungible and ambiguous term in the DC money game. My point is that it’s not something new or strange. It’s not illegal. Foreign leader wants his case made in DC circles. He hires someone in that line of work to do it. There’s a set of procedures you follow to do it legally.

Obviously, just who you’re working for and what their agenda is makes all the difference in the world in terms of the morality of the gig and how it affects your reputation. But that’s not what we’re talking about for the moment. We’re talking about legality. Leave aside for the moment whatever else Manafort may have had his hands in. We’re talking just about what the AP labeled the ‘influence campaign’ he was running on Yanukovych’s behalf. That makes it sound nefarious. But you can do that. That’s legal. But you need to file with the FARA office.

Now, here’s the thing. As I said, FARA is very lightly enforced. There are various ways to tiptoe around it. Various scenarios are arguably ambiguous. But just based on the evidence before us what Manafort was doing was not ambiguous. It’s textbook. And I know from people who’ve played in the same waters that the fact that he hadn’t filed had raised eyebrows long before he had any public association with Trump. If Manafort hadn’t become a household name in the US political world once again because of his role running Trump’s campaign it likely never would have mattered.

But now he has. Now you have pushed it right up in everyone’s face the fact that Manafort was doing exactly what the FARA law requires you to file for. And he didn’t file. It’s just really clear cut.

It’s clear cut enough that others in the mix wondered years ago what he was thinking. I suspect it will simply be too clear cut, too out in the open for everyone to see for the DOJ to ignore. That alone is a serious violation of criminal law that can lead to up to five years in prison. Just as importantly, once that kind of investigation gets started a lot of other things that were never supposed to see the light of day or be exposed to investigative scrutiny suddenly get a hard look. How far that goes, well it connects to other high profile people is for now a matter of speculation. On the FARA compliance front itself, there’s not much to speculate about. He’s got a real problem on his hands.