The former mayor of New York continues to represent many foreign clients in his private practise while also serving as the president’s private lawyer, an arrangement that runs the risk of violating federal ethics laws, according to a Washington Post report. As the newspaper notes, “Among the clients represented by Giuliani’s consulting firm is the city of Kharkiv, Ukraine, whose mayor was a leading figure in Party of Regions, the Russia-friendly political party at the center of the federal conspiracy prosecution of former Trump campaign chairman Paul Manafort.”

Giuliani also represents the anti-Iranian Mujahideen-e-Khalq (or MEK), which was listed by the State Department as a terrorist group until 2012. The MEK has been involved in killings of many Iranians and was once allied with Iraqi dictator Saddam Hussein. The former mayor of New York spoke at an MEK event in France recently.

Giuliani denies he’s done any lobbying on behalf of such clients. “I’ve never lobbied [Trump] on anything,” Giuliani told The Washington Post. “I don’t represent foreign government in front of the U.S. government. I’ve never registered to lobby.” One loophole that Giuliani seems to be exploiting is that he’s not taking any fees for being Trump’s lawyer. “I think Rudy believes because he is doing the job pro bono the rules do not apply to him, but they do,” commented Carrie Menkel-Meadow, a legal scholar at University of California-Irvine.

As with many conflict of interest problems in the Trump era, Giuliani’s activities involve an innovative merging of private and public interests. It could well be that Giuliani in technical terms is not lobbying, but it’s hard to deny that he’s using his unique access the president to shape foreign policy. Giuliani often comments on foreign policy during television appearances, something the president is likely to hear about. Giuliani also has extensive private conversations with Trump. The line between Giuliani’s work as the president’s lawyer and his other activities for his client is murky.