As he came aboard the Trump administration in early 2017, former White House chief of staff John Kelly found himself in hot water for failing to disclose his work for a Virginia-based lobbying firm called The Spectrum Group (TSG).

Now, however, there are fresh questions about TSG’s work — and whether Kelly was the only member to fail to disclose ties to the federal government.

TSG was founded in the 1990s, and pitches itself as a lobbying shop that works with a “diverse” range of clients. In addition to “companies pursuing global business interests,” the group’s website said as of this month that TSG also “work[s] with” foreign governments pushing their interests in the U.S.

As it advertised on its site, “We work with… select foreign governments seeking to advance their countries’ interests in the U.S.”

A screenshot of TSG's site earlier this month.

Among the listed “Client Services” that TSG — where Kelly worked as vice chairman until early 2017 — provides are “Foreign Cooperation and Foreign Government Representation.” And among the group’s “Subject Matter Expertise” are “International Government Relations and Advocacy.”

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It’s unclear which “select foreign governments” TSG was alluding to on its site. An examination of the Justice Department’s Foreign Agents Registration Act (FARA) database does not contain any filings showing that TSG represents foreign governments in the U.S. By law, if it was lobbying on behalf of foreign governments in the U.S., it would have to disclose this relationship and details of payments in a FARA filing. While there are certain FARA exemptions — for lawyers representing foreign governments, for instance — TSG does not appear eligible for any of these exemptions. Furthermore, the only FARA documents related to TSG date to 2008-09, but those registrations relate to a pair of Japanese companies, rather than to any government entities.

The Justice Department declined to comment.

There’s no indication that TSG has committed any illegal activity. The firm did not respond to ThinkProgress’ repeated requests for an interview about what foreign governments it represents and how.

After ThinkProgress’s inquiries, the firm removed language saying it works with foreign governments from its site.

Full spectrum

Unreported foreign lobbying has been in the spotlight over the past few years — in part because of former special counsel Robert Mueller’s investigation — with the DOJ recently reinvigorating FARA enforcement as a result.

At the same time, The Spectrum Group appears to have moved to downplay its links to foreign entities.

The firm lists 13 categories of “case studies” on its site. But some, like “strategic communications,” “strategic consulting,” and “government relations,” have no actual case studies highlighted. However, a search through the Internet Archive’s Wayback Machine reveals that until at least October 2018, TSG highlighted a number of foreign projects, including its work with entities from the U.K. and Israel. One case TSG specifically pointed to was its work for a “Danish water company” attempting to enter American defense markets.


But none of the listed examples, even those recently removed from the group’s site, relate to work on behalf of a foreign government — despite the site’s since-removed claim that The Spectrum Group works with foreign governments.

A screenshot of The Spectrum Group's "Case Studies" page, which was recently changed.

Kelly appears to have moved on from The Spectrum Group. In early 2017, The Intercept reported that Kelly avoided mentioning TSG on federal ethics forms, even though he was listed on the group’s website. Kelly’s name has since been removed. The Trump transition team released a statement in early 2017 saying that Kelly “had no knowledge” that he’d been listed on TSG’s website, despite the fact that Kelly had apparently “mentioned his relationship with Spectrum to Senate staffers during a meeting,” The Intercept wrote.

Since resigning from the administration in December 2018, Kelly joined the board of directors of Caliburn International. Caliburn is the parent company to Comprehensive Health Services, which operates a number of facilities that house unaccompanied migrant children in the U.S., CBS reported earlier this month.

Caliburn is owned by an investment firm called DC Capital. (Neither firm responded to ThinkProgress’s questions.) In 2016, Kelly served on DC Capital’s board of advisers. According to DC Capital’s website, the group’s founder is also the controlling shareholder another company: The Spectrum Group.