When reports emerged last August that the lobbying firm of then–Trump campaign manager Paul Manafort received over $12 million for work done as early as 2007 on behalf of a pro-Russian Ukrainian political party, he called the accusations “unfounded, silly, and nonsensical.” Days later, he left Trump’s bid for the presidency after just five months at the helm.

As it turns out, Manafort didn’t receive $12.7 million from the Party of Regions, the base of ousted Ukrainian President Viktor Yanukovych, as prior reports claimed. His firm actually raked in over $17 million, according to Department of Justice filings published Tuesday by the Washington Post.

More than two months after Manafort’s lawyer announced his client planned to register as a foreign agent, the filings revealed that between 2012 and 2014 Manafort’s consulting firm, DMP International, received $17.1 million for a lobbying campaign for the Party of Regions — and he failed to tell the U.S. government, as required by federal law.

Under the Foreign Agents Registration Act, anyone in the U.S. acting politically on behalf of a foreign country must register with the Department of Justice within 10 days of even agreeing to do the work. As Manafort’s 87-page filing reveals, however, he waited more than three years after completing it.

But Manafort was able to register now (and so far, without penalties) because, well, anyone can. The law allows foreign agents to file after the fact. And ever since changes to the law in 1966, investigations focus on voluntary compliance rather than criminal penalties. In fact, the Department of Justice often gives potential violators a head’s up and encourages them to register, even years later. That’s exactly what the agency did for Manafort.

The filing categorizes DMP International’s work for the Party of Regions as mostly domestic but also repeatedly identifies the goal as “greater political and economic integration between Ukraine and the West.” Yet in 2013, during Manafort’s time with the group, its leader and Ukraine’s then-president rejected a deal to join the European Union, leading to massive protests and months of unrest.

Another report puts the political consultant’s foreign work starting as early as 2005, when he reportedly proposed a secret strategy to benefit Vladimir Putin to one of the Russian president’s closest allies, Oleg Deripaska.

Manafort’s filing also acknowledges its advisory role to Brussels-based nonprofit the Centre for a Modern Ukraine. That work came to light in August, when consulting firms Mercury, which at one point denied working with Manafort, and The Podesta Group filed under the Foreign Agents Registration Act for work they did with Manafort setting up meetings between Ukrainian officials and U.S. politicians. And as Politico pointed out, the filing allows for amendments or changes, leaving open the possibility that Manafort and his firm did even more work for Ukraine.

To bring felony criminal charges, however, the DOJ must not only prove that someone acted as a foreign agent without registering but that they knew about having to register and didn’t — a high burden of proof to meet.

Since the amendments to the law in 1966, the DOJ has brought only seven criminal cases against alleged foreign agents, only one of which ended in a conviction. Before 1966, however, 23 criminal trials ended in guilty verdicts.

Manafort’s filing makes him the second member of Trump’s inner circle to retroactively register as a foreign agent. In March, nearly a month after Trump’s National Security Adviser Mike Flynn resigned from the Cabinet after lying to the vice president about his communication with Russian officials, he registered as a foreign agent for over half a million dollars of work he did for Turkey before Election Day.