On a late-spring day in 2001, Rudy Giuliani’s divorce lawyer stood on the steps of the New York State Supreme Court Building and told reporters the shocking truth. His client, the mayor of the city—beleaguered by an angry wife who wanted more money—had only $7,000 to his name.

Perhaps it wasn’t quite the truth. Just a year earlier, the mayor had $400,000 to $800,000 in pension and retirement funds due him, and now he had a $3 million book deal. Still, in New York City, what was that for a powerful man of 57? Not much.

Three months later came 9/11.

Whatever deal Donna Hanover finally struck to end her marriage, she must feel cheated, because Giuliani is now worth somewhere between $18 million and $70 million. A chunk of his personal fortune has come from giving speeches, month after month, for a standard fee of $100,000. Much of it, though, has been earned as founder and chief rainmaker of his consulting company, Giuliani Partners. Headquartered in a 24th-floor office overlooking Times Square, it has reportedly earned more than $100 million in the past six years.

That office is a cheery one, filled with sports mementos (a wooden seat from the old Yankee Stadium, a football signed by Jets legend Joe Namath), the accoutrements of the ex-mayor’s passions (among them a beautiful wooden humidor for expensive cigars), and, on almost every flat surface, silver-framed photographs of his 53-year-old third wife, Judith Nathan. On his wooden desk sits a little sign with the inscription i’m responsible. It was here, over these last six years, that Giuliani placed calls to make things happen for his clients—many of them engaged in some aspect of the security industry that boomed as a direct result of 9/11.

These days Giuliani’s office sits mostly empty as he canvasses the country for money and votes in his bid to become the Republican nominee for president in 2008. Is he even still working for Giuliani Partners? It’s a relevant question, because if he isn’t—and, really, how could he be in these busy weeks of campaigning before the first Republican presidential primaries?—then he shouldn’t be drawing a salary from the firm. According to a former top Federal Election Commission official, that would be a breach of election law: the firm would in effect be making undeclared campaign contributions.

The answer, from Giuliani Partners C.E.O. Mike Hess, is that “Rudy is no longer involved in the day-to-day operations of Giuliani Partners. He maintains his ownership interest.” To the point of whether Giuliani is still earning money from Giuliani Partners, the answer seems a bit delphic, especially after a Washington Post article from October 30, in which Giuliani Partners spokeswoman Sunny Mindel described Giuliani as still working part-time for the company.

To anyone who has followed Giuliani’s meteoric rise in business, that dodge is unsurprising. There are, it seems, at least two Rudolph Giulianis. One is the crusading former U.S. attorney and 9/11-bedecked ex-mayor of New York, cloaked in the six core values prominently featured on Giuliani Partners’ Web site: Integrity. Optimism. Courage. Preparedness. Communication. Accountability.

The other Rudy Giuliani is the one who has brazenly built a business on his 9/11 fame. Some of his clients have been large, established companies, such as Aon, the global risk-management firm that lost 175 people in the World Trade Center attack; Entergy, which operates nuclear power plants; and Delta Airlines and U.S. Airways. But a number have been scrappy little penny-stock start-ups, one of them backed by an S.E.C.-disciplined stock swindler. These are the players who have needed Giuliani most, to promote them, to open doors for them in government or business, or merely to lend them his name, at a very high price, so they can boost their stock or get bought by bigger fish. In doing business with these companies, Giuliani has sometimes created at least an appearance of poor judgment, or greed, or both. But if the crusading ex–U.S. attorney understands the importance of appearances, the other Rudy Giuliani seems oblivious to them.