A Ukrainian politician who made headlines for being targeted by disinformation campaigns linked to former Trump campaign chair Paul Manafort is revealed as the beneficiary of a foreign influence operation financed through a network of shell companies and offshore accounts, according to new Foreign Agents Registration Act (FARA) disclosures identified in the Center for Responsive Politics’ Foreign Lobby Watch database.

That politician is former Ukrainian Prime Minister Yulia Tymoshenko, who is currently one of the frontrunners in Ukraine’s presidential election scheduled for March 31 with a second-round runoff between the top two candidates on April 2 if no candidate receives a majority.

Tymoshenko gained international attention after her imprisonment in Ukraine that was the subject of a controversial report and suspected disinformation campaigns uncovered in an investigation stemming from Special Counsel Robert Mueller’s probe into Russian meddling surrounding the 2016 election of Donald Trump. The report, along with a broader influence campaign by Manafort, former Trump campaign aide Richard Gates and Skadden Arps, attempted to legitimize Tymoshenko’s imprisonment. The campaign resulted in Skadden’s retroactive FARA registration in February 2019, a $4.6 million settlement for failure to register with DOJ and an ongoing probe into one of the foreign agents implicated in the scheme, former Obama White House counsel Greg Craig.

Court records and other reports indicate that Tymoshenko was the target of an extensive clandestine media strategy involving planted articles in major newspapers, social media targeting and other “black ops” orchestrated by Paul Manafort.

Revelations about the surreptitious influence operations against Tymoshenko have not deterred the emergence of other foreign influence and lobbying campaigns claiming to advocate for her interests, nor have they deterred agents allegedly acting on Tymoshenko’s behalf from their own clandestine methods. Leveraging a complex network of limited liability companies, offshore accounts, shell corporations and other secretive entities, foreign agents claiming to act on Tymoshenko’s behalf have churned over $2.3 million into influence operations in the United States without ever disclosing who is bankrolling them.

Amended reports shine light on foreign influence campaign

Washington law firm Wiley Rein submitted an amendment to the Justice Department (DOJ) admitting Tymoshenko is the “principal beneficiary” of FARA activities for a mysterious entity called Aveiro LP and that the firm has continued lobbying work for her husband, Oleksandr Tymoshenko, “for the principal benefit of Yulia Tymoshenko.”

“Activities reported under Aveiro LP have been to promote the interests of Yulia Tymoshenko and her political party,” according to the new disclosures.

New FARA disclosures identified with Foreign Lobby Watch also indicate that Wiley Rein has been quietly working for Yulia Tymoshenko’s husband, Oleksandr Tymoshenko, and engaged in foreign lobbying activities like meeting with members of Congress.

Wiley Rein disclosed working as a foreign agent lobbying for Oleksandr Tymoshenko from 2011 until his wife’s release in 2014, Lobbying Disclosure Act and FARA records show. In the five years that followed, Wiley Rein did not report any lobbying or other foreign influence operations for Tymoshenko.

However, the closely aligned mission of other mysterious foreign principals hiring Wiley Rein in the years since has raised speculation that the entities might be fronts for an undisclosed client like Tymoshenko.

In addition to the opaque entities listed as foreign principals, the firm disclosed being paid with funds routed through a variety of limited-liability companies and offshore entities with even more questionable ties. The new filings also provided additional information about the webs of offshore accounts and entities used to pay foreign agents alleging to advocate for Tymoshenko’s interests, revealing new appendages including Drake Ltd., which shares the name of an offshore entity implicated in the Panama Papers leaks.

Churning money through networks of entities that appear to be little more than shell companies, foreign influence operations have continued to beef up their teams of lobbyists and foreign agents that claim to represent Tymoshenko’s interests. But whether their activities are actually tied to Tymoshenko and her allies or are, in reality, part of a campaign to discredit her is less clear since it is nearly impossible to distinguish the secretive tactics utilized by both sides.

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Tymoshenko’s political opponents and activities touting anti-corruption efforts in Ukraine have seized on this lack of clarity, leading to media buzz about potential corruption charges against Tymoshenko in February 2019, with the Ukrainian presidential election just weeks away.

In response to the allegations, Tymoshenko issued a statement calling it “Manafort’s technologies” and rehashing a 2018 statement claiming that she “cannot work with lobbyists.” Tymoshenko’s statement centers around a secretive limited-liability company called TwoPaths LLC that inked a contract with Avenue Strategies Global LLC, a firm started by Trump campaign veterans Corey Lewandowski and Barry Bennett. Their contract to promote Tymoshenko’s interests in the United States was abruptly terminated just weeks later, within days of when Tymoshenko issued a statement that she is “grateful” to Avenue Strategies and “the people who financed the contract with the lobbyists” but “cannot work with” them.

But Avenue Strategies was just one of the firms involved in influence operations with foreign agents claiming to represent Tymoshenko’s interests. And, while Two Paths LLC’s contract with Avenue Strategies was terminated in 2018, multiple different foreign influence operations wielded by entities that appear to be little more than shell companies have signed on and built up activities since that time.

In fact, foreign agents had already signed on to work for another mysterious limited-liability company called Innovative Technology and Business Consulting LLC (ITBC LLC) less than a month after the contract between Avenue Strategies and Two Paths LLC was terminated.

US influence operations grow as Ukrainian election nears

Multiple foreign agents claiming to advocate for Tymoshenko’s interests have continued filing FARA disclosures with DOJ into 2019.

A lobbying firm run by former Rep. Bob Livingston (R-La.) signed on in 2018 to represent ITBC LLC. Although the registration paperwork made no mention of Tymoshenko, the firm quickly went to work touting her agenda and arranging meetings on her behalf.

In an interview after the arrangement came under scrutiny in Ukraine, Tymoshenko called the lobbying activities a “special operation against my discredit.” Decrying the campaign as “fake,” Tymoshenko claimed, “We will seek these people, we will refute this information, and we will demand that they also deny it. We did not sign any contracts.”

Nevertheless, the operation continued growing undeterred months after Tymoshenko’s public repudiation.

In November 2018, a “CNN Political Commentator & WSJ contributor” named Douglas Heye signed a new $15,000 contract beefing up the Livingston Group’s influence operations for IBTC LLC. Activities covered by the contract include “media placement and meetings with political journalists and media outlets” in the United States “to communicate information about the foreign principal and its issues of concern and to provide for contact between the principal and the U.S. media.”

In addition to Livingston Group’s growing team, another parallel foreign influence operation launched in August 2018. A foreign agent named Naomi Decter Munson signed a six-figure contract with IBTC LLC for work included securing media interviews for Yulia Tymoshenko, FARA records from September 2018 identified in Foreign Lobby Watch show.

Foreign shell company payments to foreign agents for lobbying and influence activities are not prohibited by federal law, but FARA does require disclosure of an influence operation or lobbying campaign’s principal beneficiary. There is no settled definition of “principal beneficiary,” but DOJ’s FARA unit has taken an increasingly broad view of what would make a foreign government the principal beneficiary of actions undertaken by an agent on behalf of a private business or individual.

For example, a U.S. subsidiary registered under the Lobbying Disclosure Act may think it has addressed any FARA exposure associated with its foreign parent, but if the subsidiary acts on behalf of its parent about an issue that is of significant interest to a foreign government, then that government may also be considered a principal beneficiary. If a foreign agent knows that activities are really being directed by someone other than the disclosed client or beneficiaries, then FARA requires the agent to disclose the actual client to DOJ.



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