President Donald Trump’s new acting intelligence director, Richard Grenell, used to do consulting work on behalf of an Eastern European oligarch who is now a fugitive and was recently barred from entering the U.S. under anti-corruption sanctions imposed last month by the State Department.

In 2016, Grenell wrote several articles defending the oligarch, a Moldovan politician named Vladimir Plahotniuc, but did not disclose that he was being paid, according to records and interviews. Grenell also did not register under the Foreign Agents Registration Act, which generally requires people to disclose work in the U.S. on behalf of foreign politicians.

FARA is the same law that Trump’s former campaign manager Paul Manafort and former deputy campaign manager Rick Gates were convicted of violating. (Manafort went to trial. Gates pleaded guilty.)

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It’s not clear whether the articles were directly part of Grenell’s paid consulting work for Plahotniuc. Unpaid work could still require disclosures under FARA if it was directed by or primarily benefited a foreign politician, according to Matthew Sanderson, a lawyer at Caplin & Drysdale who advises people on complying with FARA. FARA contains several exemptions, such as for lawyers and businesses, Sanderson said, but none appear to apply to Grenell’s op-eds about Plahotniuc.

“There is real reason to believe that Mr. Grenell should have registered here,” Sanderson said after ProPublica described the circumstances to him. “This is exactly the type of circumstances I’d expect the Department of Justice to investigate further.”

Craig Engle, an attorney with the law firm Arent Fox, said he was responding to ProPublica’s questions on Grenell’s behalf. Engle declined to say what Grenell’s paid consulting work involved but said he did not have to register under FARA “because he was not working at the direction of a foreign power.”

“Ric was not paid to write these stories, in fact he has written hundreds of stories on his own time to express his own views,” Engle said. “But to be clear: he was not working for any individual, he was working for himself and was advocating the ideal of a pro-western political party that was emerging.”

Undisclosed work for a foreign politician would ordinarily pose a problem for anyone applying for a security clearance or a job in a U.S. intelligence agency because it could make the person susceptible to foreign influence or blackmail, according to the official policy from the office that Trump tapped Grenell to lead.

The policy specifies that among the “conditions that could raise a security concern and may be disqualifying” are:

“Failure to report or fully disclose, when required, association with a foreign person, group, government or country.”

“Substantial business, financial, or property interests in a foreign country … that could subject the individual to a heightened risk of foreign influence or exploitation or personal conflict of interest.”

“Acting to serve the interest of a foreign person, group, organization or government in any way that conflicts with U.S. national security interests.”

“That’s really easy, he should not have a clearance,” said Kel McClanahan, a Washington-area lawyer specializing in security clearances. “If he were one of my clients and just a normal [federal employee], he would almost assuredly not have a clearance.”

McClanahan said it’s unclear how Grenell could have already gotten a clearance as an ambassador. The House Oversight Committee is investigating whether the Trump administration has overruled career officials in granting security clearances to political appointees.

As Trump’s pick for acting director of national intelligence, Grenell will have access to the country’s most sensitive secrets. Grenell isn’t subject to Senate confirmation because Trump appointed him on a temporary basis.

The White House, the Office of the Director of National Intelligence and the State Department did not immediately respond to requests for comment.

Grenell, who is also continuing in his current posts as ambassador to Germany and special envoy for negotiations between Kosovo and Serbia, has gained Trump’s favor with his unwavering loyalty and combative tweets. (In one instance, he attacked ProPublica in response to reporting that Vice President Mike Pence’s office had intervened in foreign aid decisions.) He raised hackles in Berlin by injecting himself into the country’s domestic politics, a departure from usual diplomatic protocol.

Grenell does not have prior experience in intelligence. He was the U.S. spokesman at the United Nations during the George W. Bush administration.

In between his turns in government, Grenell had a public affairs consulting firm called Capitol Media Partners. One of the firm’s clients, according to the financial disclosure that Grenell filed when he became an ambassador, was Arthur J. Finkelstein, the late Republican political consultant whose international clients included Prime Minister Benjamin Netanyahu of Israel and Prime Minister Viktor Orban of Hungary. Grenell’s financial disclosure indicates that he received more than $5,000 from Finkelstein’s firm but does not specify how much.

According to a person familiar with the relationship, Grenell worked for Finkelstein as a media consultant for clients in Eastern Europe. That person and another individual said the client in Moldova was Plahotniuc, the country’s richest man and then a top official in its ruling political party.

In August 2016, Grenell published op-eds in the right-leaning Washington Examiner and Washington Times defending Plahotniuc and attacking his enemies as serving Russian interests. Plahotniuc and his allies at the time were fending off suspicions of their involvement in a $1 billion bank fraud in Moldova. “Blaming the ruling party and its leadership has its political benefits for Russia,” Grenell wrote in the Examiner article. “Plahotniuc has been around Moldovan politics, business and civic life for decades and has turned out to be an easy target.”

This narrative aligned with Plahotniuc’s efforts to present himself as pro-Western in Washington and European capitals, according to lobbying disclosure records. “Certainly there was an effort by him to engage U.S. officials at the time, that despite all this corruption he was the guy most likely to keep Russia at bay and therefore you should accept him,” said Jonathan Katz, who oversaw U.S. aid programs for Moldova at the time. “It didn’t match anything he was doing internally in the country,” Katz said, because Plahotniuc didn’t advance U.S. interests such as promoting democratic institutions and the rule of law.

Vladimir Plahotniuc's corrupt actions undermined the rule of law and severely compromised the independence of democratic institutions in #Moldova. Today, I publicly designate him. The U.S. stands with Moldova in its fight against corruption. — Secretary Pompeo (@SecPompeo) January 13, 2020

Grenell was also quoted in an October 2016 article in the Houston Chronicle criticizing a resolution proposed by Rep. Randy Weber, R-Texas, that accused Plahotniuc and his allies of corruption. “He’s trying to attack the only pro-European group in Moldova,” Grenell told the Chronicle.

“The reality is he’s pro-himself and nothing more,” Valeriu Pașa, who leads a prominent civil society group in Moldova called WatchDog.MD, said of Plahotniuc. “He was playing both sides for 15 years at least.”

Plahotniuc lost power in 2019 and fled Moldova. His current whereabouts are unknown. Last month, the State Department endorsed the corruption allegations against him, banning him and his family from entering the U.S.

“In his official capacity, Plahotniuc was involved in corrupt acts that undermined the rule of law and severely compromised the independence of democratic institutions in Moldova,” the State Department said in its announcement. “Today’s action sends a strong signal the United States does not tolerate corruption and stands with the people of Moldova in their fight against it.”