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I don’t know how anyone familiar with the English language can think it is a good branding ploy to name their company Fraud Guarantee. But that is exactly what Lev Parnas and David Correia did back in 2013. As the chief executive officer and chief operating officer they somehow attracted strategic advice and possibly seed money from Philip Reicherz who runs a venture capital fund called Magnolia Ventures. The company began with $1.5 million in the bank.

But their website indicates a defunct enterprise premised on vague promises of protection against investor fraud. The screenshot below is current as of October 15, 2019. It shows that they are promising to roll out their primary product, InvestSafe™, in the Spring of 2016. Either that never happened or they have a very lazy person running their website.

You can see that they were also saying they could provide a technology that would be an improvement on standard background checks. So, here we can see where they might be in need of some technological consulting work. Maybe back in 2015 or the winter of 2016, they might have hired someone for that purpose. Maybe a genius could figure out how to get a “technology” to listen for people “talking about fraudulent activity” by “scour[ing] the internet” and “crunch[ing] the data.” That’s certainly something some law enforcement and intelligence agencies are capable of doing. Why not two dudes in Boca Raton?

So, this is what Fraud Guarantee looks like. And here is what Rudy Giuliani has to say about it:

President Donald Trump’s personal attorney, Rudy Giuliani, was paid $500,000 for work he did for a company co-founded by the Ukrainian-American businessman arrested last week on campaign finance charges, Giuliani told Reuters on Monday… …Giuliani said [Lev] Parnas’ company, Boca Raton-based Fraud Guarantee, whose website says it aims to help clients “reduce and mitigate fraud”, engaged Giuliani Partners, a management and security consulting firm, around August 2018. Giuliani said he was hired to consult on Fraud Guarantee’s technologies and provide legal advice on regulatory issues.

Maybe it’s me, but August 2018 seems far too late to be offering technology advice to Fraud Guarantee. And this is a company that started with $1.5 million in seed money and never seems to have developed a product. How can they afford to pay Rudy Giuliani $500,000?

The New York Times reported last week that Parnas had told associates he paid Giuliani hundreds of thousands of dollars for what Giuliani said was business and legal advice. Giuliani said for the first time on Monday that the total amount was $500,000. Giuliani told Reuters the money came in two payments made within weeks of each other. He said he could not recall the dates of the payments. He said most of the work he did for Fraud Guarantee was completed in 2018 but that he had been doing follow-up for over a year.

It would be fascinating to see Giuliani explain to a prosecutor or congressional committee what kind of work he performed in 2018 and the nature of his follow-up work in 2019.

As for those two wire transfers Giuliani received, he says we shouldn’t worry about them.

According to an indictment unsealed by U.S. prosecutors, an unidentified Russian businessman arranged for two $500,000 wires to be sent from foreign bank accounts to a U.S. account controlled by [Igor] Fruman in September and October 2018. The money was used, in part, by Fruman, Parnas and two other men charged in the indictment to gain influence with U.S. politicians and candidates, the indictment said. Foreign nationals are prohibited from making contributions and other expenditures in connection with U.S. elections, and from making contributions in someone else’s name. Giuliani said he was confident that the money he received was from “a domestic source,” but he would not say where it came from. “I know beyond any doubt the source of the money is not any questionable source,” he told Reuters in an interview. “The money did not come from foreigners. I can rule that out 100%,” he said.

I’ve been saying that this is the biggest scandal in American political history, and this is just a small piece of it. Even John Bolton, of all people, wanted nothing to do this operation.

The aide, Fiona Hill, testified that Mr. Bolton told her to notify the chief lawyer for the National Security Council about a rogue effort by [Ambassador to the European Union] Mr. Sondland, Mr. Giuliani and [White House chief of staff] Mick Mulvaney, the acting White House chief of staff, according to the people familiar the testimony. “I am not part of whatever drug deal Sondland and Mulvaney are cooking up,” Mr. Bolton, a Yale-trained lawyer, told Ms. Hill to tell White House lawyers, according to two people at the deposition… …It was not the first time Mr. Bolton expressed grave concerns to Ms. Hill about the campaign being run by Mr. Giuliani. “Giuliani’s a hand grenade who’s going to blow everybody up,” Ms. Hill quoted Mr. Bolton as saying during an earlier conversation.

It’s amazing that Giuliani is still talking and still spinning. He says he’s 100% certain that he was not the recipient of two wire transfers totaling a half a million dollars that were sent by “an unidentified Russian businessman” to “gain influence with U.S. politicians and candidates” even as he freely admits that was paid exactly that amount in two wire transfers by the very same people.

As you might expect, and as the Wall Street Journal is reporting, federal prosectors are hot on Giuliani’s trail. They are not going to be any more satisfied with his answers than I am, and they have the tools to prove he’s a liar.

Lev Parnas and David Correia have both been arrested, along with Andrey Kukushkin and Igor Fruman. Two of them, Parnas and Fruman, were nailed at Dulles International Airport shortly after having lunch with Giuliani at the Trump International Hotel in Washington, DC. They were scheduled to testify before Congress but had one-way tickets indicating that they had no intention of fulfilling that commitment.

And, yet, Giuliani is still insisting on his innocence. He’s still saying things that can and will be used against him in a court of law.

And Trump is still complaining about the initial whistleblower, as if half his administration were not exposing the whole thing in sworn depositions before the House Intelligence Committee.