Rudy Giuliani, through his Giuliani Partners consulting group, has done work for clients such as the city of Kharkiv, Ukraine, whose mayor is part of the same pro-Russia political party that was connected to the work Paul Manafort did. Giuliani said his firm worked for the mayor this year, and plans to again. Manafort is now facing criminal cases in Virginia and D.C. for charges related to that work. One of those charges is for allegedly failing to register as a foreign agent.
Giuliani claims that the work he has done for overseas organizations does not require registration under the Foreign Agents Registration Act (FARA) because he’s not lobbying the U.S. government. Even though he also works with President Trump, Giuliani insists he never crossed that line.
“I’ve never lobbied him on anything,” Giuliani told the Post. “I don’t represent foreign government in front of the U.S. government. I’ve never registered to lobby.”
While this may be true, it may not be enough to lift all concerns. In May of this year, Giuliani gave a speech in Washington, D.C. for the Iranian group MEK, once a designated terror group that opposes Iran’s government. Despite not being a lobbying effort, it still might be problematic when it comes to FARA.
“Political activity is a broad term,” attorney Joshua Ian Rosenstein, a partner at a firm that handles lobbying and FARA-related matters, told the Post. “It includes any actions — including speeches, PR work and media outreach — that are intended to or anticipated to influence the U.S. government or the U.S. public with regard to the formulation, adoption, or modification of the policies of the U.S., or with regard to the political or public interests, policies, or relations of a foreign political party.”
Even if Giuliani’s work is on the level and not in violation of any laws, it still raises ethical concerns given its appearance, as well as the possibility that foreign clients could have interests that may not be in line with President Trump’s.
University of California-Irvine legal ethics professor Carrie Menkel-Meadow noted that it’s not a good idea for a president’s attorney to have foreign clients for that very reason, even if Giuliani is volunteering his services for Trump.
“I think Rudy believes because he is doing the job pro bono the rules do not apply to him,” Menkel-Meadow said, “but they do.”
[Image via Andrew Burton/Getty Images]