A little over a year ago, a grip of Democratic senators penned a letter to the Department of Justice with a simple request: review whether or not Rudy Giuliani, Donald Trump’s personal Nosferatu-cum-lawyer, was in compliance with the DOJ’s Foreign Agents Registration Act (FARA). The eighty-year-old statute, long dormant and nearly forgotten until Trump barreled into the presidency, had by this time tripped up Paul Manafort, Trump’s former campaign chair, as well as Mike Flynn, Trump’s former national security adviser. Giuliani, per the letter, looked like he was trying to make it a hat-trick of foreign subterfuge, juggling a number of foreign clients and interests, lining his pockets and upending American interests as he went.

“The purpose of FARA is to ensure the American public can make informed judgments about the political activities of foreign agents in the U.S.,” the senators, which included Democratic presidential contender Elizabeth Warren, wrote. “[T]his law should be applied without regard to political association, activities, or beliefs.”

The DOJ, as we now know, received the letter, but never bothered to respond. Months wound by, with Giuliani amping up his foreign meddling, and injecting himself directly into policy-making in countries like Ukraine. Giuliani also began picking up massive foreign tabs from individuals like Lev Parnas and Igor Fruman, the two post-Soviet clowns who were arrested and indicted last week on election-related charges—and whose source of income “remains a mystery.”

For reasons heretofore unknown, Giuliani has not registered as a foreign agent on their behalf—or on behalf of any of the foreign clients he’s accrued along the way. “I regularly play this game where I try to play devil’s advocate and try and figure out why Giuliani is not registered under FARA, and I regularly, when I play this game, cannot figure out why Giuliani is not registered under FARA,” Ben Freeman, director of the Foreign Influence Transparency Initiative for the Center for International Policy, told The New Republic. “I frankly can’t figure out why he would not be registered under FARA.”

The litany of foreign fiends looking to Giuliani for help is getting almost too lengthy to properly monitor.

The litany of foreign fiends looking to Giuliani for help—and looking for him to whisper directly in Trump’s ear to serve their ends—is getting almost too lengthy to properly monitor. There’s Reza Zarrab, the Turkish national at the center of the largest sanctions-evasion scheme ever run out of Iran, who opted to hire Giuliani for, supposedly, his legal acumen. Giuliani’s service to his client took him directly into the Oval Office: As The New York Times reported last week, Giuliani lobbied Trump directly for Zarrab’s release—a move that made former Secretary of State Rex Tillerson blanch, and warmed the cockles of Turkish strongman Recep Erdoğan, who’d long pushed for Zarrab’s return.