This one’s trouble because, unlike some of Cohen’s other grifting “consulting” work, the payment allegedly came from a foreign government. I’ll leave it to legal eagles to debate the finer points of the Foreign Agents Registration Act, but if a U.S. citizen is arranging meetings with high government officials on behalf of a foreign power, he’s probably a lobbyist for purposes of FARA and is required to register as a “foreign agent” under the law. Until recently, failing to register was no big deal: The statute was rarely enforced so lobbyists for foreign interests would register retroactively if and when it was noticed that they hadn’t done so. Between 1966 and 2017, there were just three indictments for failing to register.

But that changed with Russiagate. Bob Mueller charged Paul Manafort with violations of FARA and noted in Mike Flynn’s guilty plea that he had made material false statements in his own FARA filings. Ever since, lobbyists in D.C. have been racing to update their own FARA paperwork so that they don’t end up being hauled into court too under the newly revived statute.

The point is, Mueller is interested in FARA omissions and has already proved he’s willing to indict over them. If this BBC story is true, Cohen would seem to be a sitting duck.

Donald Trump’s personal lawyer, Michael Cohen, received a secret payment of at least $400,000 (£300,000) to fix talks between the Ukrainian president and President Trump, according to sources in Kiev close to those involved. The payment was arranged by intermediaries acting for Ukraine’s leader, Petro Poroshenko, the sources said, though Cohen was not registered as a representative of Ukraine as required by US law... Cohen was brought in, he said, because Ukraine’s registered lobbyists and embassy in Washington DC could get Mr Poroshenko little more than a brief photo-op with Mr Trump. Mr Poroshenko needed something that could be portrayed as “talks”.

Cohen denies it, of course, but Michael Avenatti told the BBC that some Suspicious Activity Reports about Cohen’s accounts include money from “Ukrainian interests.” Hmmmm.

A Twitter pal wondered when this story broke: Why would the president of Ukraine need to bribe Cohen to get some meaningful face time with POTUS? We’re allies. A presidential huddle normally would happen in due course, no palm-greasing required. Right — but the key word is “normally.” Trump, after all, had two reasons to be leery of Ukraine. One was his interest in detente with Russia, a preference that no doubt scared the hell out of Poroshenko and his advisors. The other was the fact that Manafort’s connections to Ukraine’s Putin-puppet former president were revealed during the campaign thanks to information from Ukrainian documents, which naturally annoyed POTUS. Ukraine favored Hillary in the election, believing that she’d be more likely to side with them against Moscow. Now suddenly they were forced to deal with Trump, who might hold a grudge and not want to meet them except for photo ops.

And so, if the BBC is to be believed, $400,000 found its way to Michael Cohen and Poroshenko got a more meaningful meeting in the Oval Office. But that raises a question. What did Trump supposedly get for sitting down with Poroshenko? The BBC notes that there’s no evidence that he knew about the payment to Cohen. But maybe there was something else on the table for him:

Shortly after the Ukrainian president returned home, his country’s anti-corruption agency stopped its investigation into Trump’s former campaign manager, Paul Manafort… One source in Kiev said Mr Poroshenko had given Trump “a gift” – making sure that Ukraine would find no more evidence to give the US inquiry into whether the Trump campaign “colluded” with Russia… A report by a member of a Western country’s intelligence community says Mr Poroshenko’s team believe they have established a “non-aggression pact” with Mr Trump.

They torpedoed their own investigation into Manafort for fear that the results might be used by Bob Mueller against Trump in the Russiagate probe. That’s not the first time that’s been reported, either: Three weeks ago the Times also noticed that Ukraine had shoved its corruption investigation of Manafort in a drawer — and, coincidentally, not long after received approval by the White House to buy anti-tank missiles from the U.S., a surprising development given Trump’s desire for better relations with Putin. (An intel report from a western agency obtained by the BBC also claims that Ukraine agreed to import U.S. coal and to purchase a billion dollars’ worth of diesel trains from the U.S. even though they produce all of that themselves.) Whether there was some stated “grand bargain” with Trump to buy his support against Russia or if these are things the Ukrainians are doing unilaterally to try to win his favor, Ukraine sources are candid about why the Manafort investigation has shriveled up. “In every possible way, we will avoid irritating the top American officials,” said one Poroshenko ally to the Times. Another unnamed Ukrainian official told the BBC, “I want the rule of law, but I am a patriot.” Whatever they need to do to keep America on their side against Russia, they’re going to do it. Whether that means letting Paul Manafort walk free or, allegedly, handing bags of cash to Michael Cohen.

Two points in closing. One: It’s nuts to think Cohen was the only Trump crony being wooed by corporate and foreign interests to try to land meetings with Trump. “Everyone was hiring ‘Trump whisperers’ in 2017 — every single hanger-on in the Trump orbit made a fortune in 2017,” said one GOP consultant to Politico a few weeks ago when Cohen’s alleged post-election grifting was first reported. The Daily Beast claimed in a story published last night that Cohen was telling potential clients at the time to stay away from Corey Lewandowski because only Cohen had real access to Trump. Trump cronies were competing with each other to shake down special interests for “consulting fees.” If Ukraine was desperate enough to throw nearly half a mil at Cohen to try to get a meeting, who else did they throw money at?

Two: Lest there was any doubt, Mueller *is* interested in money flowing from Ukraine to Trump-connected interests. Last month the NYT reported that his office was looking at a $150,000 “donation” made by Ukrainian billionaire Victor Pinchuk to Trump’s foundation in 2015 in exchange for a 20-minute video-linked appearance by Trump at a Ukrainian conference that month. The man who solicited that “donation” on Trump’s behalf? Michael Cohen, of course. It would be bizarre if Mueller’s investigation, which is dedicated to exposing Russian influence over the last election, instead ended up exposing Cohen and Trump for too-friendly dealings they had with Russia’s mortal enemy in Kiev, but that’s where we may be headed.