Legal analysts said Parscale’s visit broke no laws so long as he does not do any lobbying in the United States on behalf of foreign clients without registering. But ethics experts said any money changing hands between foreign citizens and campaign officials creates an obstacle course of potential risks. And some ethics lawyers worried that Parscale’s engagement — which received little attention outside Romania at the time — is a sign that the 2016 Trump campaign’s freewheeling approach to foreign contacts may be carrying over to its 2020 successor.

“The appearances are terrible,” said Richard Painter, a chief ethics lawyer to President George W. Bush. “You would certainly think that a campaign manager would not take money from foreign nationals in this political environment.”

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Trump has not banned his campaign officials from taking money from foreign sources, and the campaign declined to comment about any changes it has made this cycle to encourage caution in dealing with foreign entities.

In a statement, Parscale said the “handful of international speeches” he has delivered have given him a chance to see the world with his wife and recuperate from campaign responsibilities.

“We did not grow up with the opportunity to travel internationally, and speaking opportunities have allowed me to share my talent with other professionals in a university setting while having a brief break from the rigorous campaign schedule that I maintain,” Parscale said. “This speaking engagement was fully vetted and approved through the necessary channels in advance.”

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He added, “This is yet another effort by the biased fake news media to systematically target another person in President Trump’s orbit.”

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Parscale did not respond to a question about how much he was paid in Romania, a trip sponsored by Romanian businessman Adrian Thiess. He also would not say how he decides which foreign engagements to accept. Parscale is listed with the Worldwide Speakers Group, an Alexandria, Va.-based agency. Its website notes his speaking fee as $15,000 to $25,000 and promotes his insider’s perspective as Trump’s 2016 digital media director.

Since 2016, Parscale has also spoken at conferences in Portugal, Monaco and Croatia.

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Trump campaign spokeswoman Kayleigh McEnany emphasized that Parscale was traveling “as a private citizen” and “followed the Trump campaign’s approval process governing invitations for outside speaking engagements.”

Political operatives from both major parties have said yes to foreign speeches or consulting gigs, but typically after a campaign has ended.

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Neither 2016 Clinton campaign manager Robby Mook nor 2012 Obama campaign manager Jim Messina gave paid speeches — foreign or domestic — while running their campaigns.

Nor did full-time staffers working on Republican presidential campaigns for George H.W. Bush, Sen. John McCain (Ariz.), businessman and diplomat Jon Huntsman, or former Ohio governor John Kasich, according to John Weaver, a campaign strategist who occupied senior roles for all of those candidates.

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“I’ve never heard of anything like this before,” Weaver said. “There are too many opportunities where there could be potential conflicts between a presidential campaign and the policies that the candidate could espouse and potential income. It is a conflict-of-interest zone that you just never enter into.”

Parscale’s engagements stand out because he is currently the full-time leader of a campaign and because that campaign took extensive heat for its foreign contacts in the last election cycle.

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Several top officials from Trump’s 2016 campaign had business relationships with foreign individuals and groups that later became political liabilities. They included Parscale’s predecessor, Paul Manafort, who pleaded guilty to lobbying on behalf of the Ukrainian president without properly registering and to hiding money from the Internal Revenue Service. Michael Flynn, a foreign policy adviser for the campaign who went on to briefly serve as national security adviser, admitted to lying about his consulting firm’s business with the Turkish government. A company owned by the family of Jared Kushner, Trump’s son-in-law and adviser, engaged in talks with China’s Anbang Insurance Group about a major redevelopment project in Manhattan during the campaign. The deal was scuttled after Kushner’s move to the White House.

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“It appears the Trump political organization has learned nothing from 2016 about the dangers of senior campaign personnel’s entanglement with foreign money,” said Trevor Potter, president of the nonpartisan Campaign Legal Center.

Noah Bookbinder, the executive director of Citizens for Responsibility and Ethics in Washington, said Parscale’s trip fits with his sense that Trump and his staffers have “a general approach that if something is not strictly illegal, then it’s fine. And the potential for the appearance of impropriety or the appearance of a conflict of interest? It’s just not something that concerns them.”

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A top Republican campaign finance lawyer who reached out at the request of the Trump campaign said it was unfair to compare Parscale’s speaking engagement with the business relationships of 2016 campaign officials.

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“I don’t see any relationship or resemblance between those two things,” said the lawyer, Cleta Mitchell. “There’s absolutely nothing wrong with this.”

Parscale “is not in the policy world. It’s not in the policy world in terms of the speech. It’s a campaign technician’s speech,” she said. “I think there’s a big difference between people who are involved in policy and people who are not.”

“I didn’t know much” about Romania before, Parscale told the country’s Antena 3 broadcaster during the visit.

“Romania seems to be a very pro-Trump country and a pro-America country, and that’s why it’s a great honor to come visit,” Parscale said.

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Although Romania is a U.S. ally, a member of the European Union and oriented against Russia as part of the NATO military alliance, it has been criticized for attempts to weaken judicial independence and labeled by Transparency International as one of the most corrupt countries in Europe.

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Leaders there have effectively decriminalized low-level corruption among government officials. The Romanian Parliament recently approved a new law that would wipe clean the criminal records of top politicians, despite protests from prosecutors, judges and civil-society organizations.

In an interview, Thiess said he invited Parscale because “the U.S. presidential campaign is an interesting story, and I read an interesting article about President Trump’s campaign boss. I thought it was an exciting story about a man who managed to change the establishment in the U.S. through an online campaign.”

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Thiess declined to say how much he paid for the visit, which was promoted by McCann/Thiess Conferences, an event-planning partnership with the Bucharest outpost of the McCann international marketing firm.

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“Obviously there’s a cost to hosting him here, but that’s all,” he said. “I can’t speak about any other legal details.”

Among others Thiess has hosted in Romania are former Soviet leader Mikhail Gorbachev; retired Navy SEAL Robert O’Neill, who says he killed Osama bin Laden; and American physicist and Nobel laureate Kip Thorne.

Parscale’s speech was billed inside Romania as an unusual chance to hear about U.S. politics directly from a senior campaign operative. Bucharest, whose center is dominated by the vast communist-era Palace of Parliament, is an infrequent stop for Americans on the European speaking circuit.

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Parscale addressed an invitation-only audience at a cultural forum; a recording indicates that he spoke about the 2016 and 2020 campaigns and made little reference to Romania. Asked about U.S. policy toward NATO — a major concern in Bucharest — he said: “That’s way too policy for me. I don’t work for the administration. Not going to talk about NATO.” He also attended a 40-person dinner in his honor, where he socialized with some of the country’s political elite.

“We had anyone who’s anyone” at the speech, Thiess said.

Some of those in attendance have been bruised by high-level anti-corruption investigations. Former prime minister Adrian Nastase — who has served prison time for bribe-taking, blackmail and illegally raising political funds — wrote in a blog post on his personal website that he gave Parscale a copy of his book, “Romanian-American Partnership — My Contribution.”

Also at the speech was Vlad Cosma, a former lawmaker who helped oust the country’s chief anti-corruption prosecutor and is battling his own corruption charges, which he denies. He did not respond to requests for comment.

Romanian Prime Minister Viorica Dancila did not meet with Parscale. The day after the speech she was in Washington, where she became the first foreign head of government in more than a year known to stay at the Trump International Hotel. A spokesman did not reply to a request for comment.

Parscale and his wife also met separately with the patriarch of the Romanian Orthodox Church and toured the city with Thiess and others.

“He joked that, for him, the East ends here because he’s never been further east than Romania,” said Dan Dungaciu, a sociologist who runs a Bucharest-based political science institute and helped host the visit. “He said that, back in America, he’ll be the biggest expert on Romania” in Trump’s orbit.