Chile, crime, D'Avanzo, Dominica, Dominican Republic, El Salvador, FARA, FARA Datebase, foreign agent, foreign lobbying, Giuliani, Harald Giuliani, Iran, Lee D'Avanzo, mafia, Manafort, MEK, Mueller, organized crime, Romania, Russia, Senate Lobbyist, Senate Lobbyist Data Base, terrorism, Uruguay
We cannot find Giuliani either in the FARA database, or in the Senate Lobbyist data base:
Apparently no one else can, either. Public pressure has resulted in late filings by others. However, Giuliani seems to be above the law. Is it because of his matrilineal mob ties (D’Avanzo)? Or Harold Giuliani, his father’s, reputation? Harold went to Sing Sing for robbing a milkman at gunpoint. True or false, Harold had a reputation of continuing in a sort of mob enforcer role for the D’Avanzos. One D’Avanzo cousin – Lee – and his Albanian wife, was recently arrested: https://newyork.cbslocal.com/2019/12/20/mob-wives-arrest-drugs-weapons/
According to the information, below, FARA registration is required even for non-governmental foreign entities. However, Giuliani also lobbied on behalf of foreign governments. Forcing governments to hire lobbyists is also a sort of shakedown.
“SEPTEMBER 07, 2018
DUCKWORTH & DURBIN REQUEST FEDERAL INVESTIGATION INTO RUDY GIULIANI’S ONGOING WORK FOR FOREIGN ENTITIES
Senators question if Trump personal lawyer is violating law by failing to report activities & register as foreign agent as law requires
[WASHINGTON, D.C.] – U.S. Senators Tammy Duckworth (D-IL) and Dick Durbin (D-IL), along with Senators Tom Udall (D-NM), Elizabeth Warren (D-MA), Richard Blumenthal (D-CT), Sheldon Whitehouse (D-RI) and Jeff Merkley (D-OR), asked the Department of Justice’s (DOJ) National Security Division to immediately review whether President Trump’s personal attorney, Rudolph Giuliani, is violating the Foreign Agents Registration Act (FARA) by failing to register the political and public relations activities he has conducted on behalf of foreign entities. FARA requires individuals to promptly register with DOJ when they take on foreign governments, entities or political parties as clients and to periodically disclose information on their foreign lobbying activities.
“Mr. Giuliani’s numerous foreign clients and ongoing communications with senior U.S. government officials raise significant concerns,” the Senators wrote. “As President Trump’s personal attorney, Mr. Giuliani communicates in private with the President and his senior staff on a regular basis. Without further review, it is impossible to know whether Mr. Giuliani is lobbying U.S. government officials on behalf of his foreign clients.”
The Senators noted that Giuliani reportedly receives compensation from a political party in Ukraine that is known for its connections to the Russian government and anti-democratic activity and has previously employed Paul Manafort and Rick Gates, former Trump campaign senior staffers. Giuliani has also been paid significant amounts by the Mujahedin-e-Khalq (MEK), an Iranian opposition group, and lobbied for them to be removed from the State Department’s list of foreign terrorist organizations, and he has represented unnamed clients in Colombia and Brazil. Press releases on Giuliani’s security company’s website describe additional work on behalf of the governments of Chile, Dominica, Uruguay, the Dominican Republic, and El Salvador. Giuliani also was paid to send a letter to the President of Romania recently criticizing that nation’s anti-corruption program – which directly contradicted the U.S. State Department’s position – on behalf of a global firm that reportedly has a wealthy Romanian citizen as a client.
“The purpose of FARA is to ensure the American public can make informed judgments about the political activities of foreign agents in the US,” the Senators continued. “Given Mr. Giuliani’s ongoing relationships with foreign governments as well as his concurrent representation of the President, we hope you will agree this situation merits immediate review.”
Duckworth and Durbin have introduced legislation to strengthen enforcement of FARA and create civil financial penalties for foreign agents who break the law. https://www.duckworth.senate.gov/news/press-releases/duckworth-durbin-and-blumenthal-introduce-legislation-to-strengthen-enforcement-of-foreign-lobbying-transparency-law
The full text of the letter is below and here: https://www.tomudall.senate.gov/imo/media/doc/Giuliani%20FARA%20Letter%20(final).%20.pdf
Assistant Attorney General Demers:
We write regarding public reports that suggest the President’s personal attorney, Mr. Rudolph Giuliani, has conducted a number of political and public relations activities on behalf of foreign entities that implicate registration requirements of the Foreign Agents Registration Act (FARA). Given these reports regarding Mr. Giuliani’s work on behalf of foreign governments and interests, we request that the Department of Justice review whether he is in compliance with FARA, including whether he has an obligation to register any undisclosed political activities, has any delinquent filings, or has any deficiencies or abnormalities in his registration statements.
FARA generally requires individuals working to influence U.S. government officials or the public on behalf of a foreign entity to register that activity with the Department.
The Act defines political activities that require registration as “any activity that the person engaging in believes will in any way influence any agency or official of the Government of the United States.” However, FARA also covers any type of public relations directly or indirectly on behalf of a foreign principal, as well as any advising on the domestic or foreign policies of the United States.
Mr. Giuliani’s numerous foreign clients and ongoing communications with senior U.S. government officials raise significant concerns. Mr. Giuliani reportedly receives compensation from: the Party of Regions in Ukraine, the Mujahedin-e-Khalq (MEK), as well as unnamed clients in Colombia and Brazil. Press releases on Mr. Giuliani’s security company’s website describe additional work on behalf of the governments of Chile, Dominica, Uruguay, the Dominican Republic, and El Salvador.
As President Trump’s personal attorney, Mr. Giuliani communicates in private with the President and his senior staff on a regular basis. Without further review, it is impossible to know whether Mr. Giuliani is lobbying U.S. government officials on behalf of his foreign clients.
Mr. Giuliani’s public activities have also raised FARA concerns. For example, Mr. Giuliani’s participation in the MEK’s lobbying effort to be removed from the U.S. State Department’s Foreign Terrorist Organization list is well-documented. In nearly every article describing the group’s lobbying effort, Mr. Giuliani’s name, quotes, and public remarks are used as evidence of the effort’s credibility. Mr. Giuliani also regularly advocates for regime change in Iran, which is one of MEK’s top objectives. Given Mr. Giuliani’s receipt of significant payment from the MEK and simultaneous advocacy on behalf of that group and its objectives, his actions may require registration under FARA.
Additionally, Mr. Giuliani’s work on behalf the city of Kharkiv, Ukraine, whose mayor is a member of the Party of Regions is also concerning. The Ukrainian Party of Regions’ connections to the Russian Government and anti-democratic activity are well-documented. Paul Manafort and Rick Gates, who both served in senior roles on the President’s 2016 campaign team, were convicted of or pleaded guilty to criminal acts in part because of their work on behalf of this Russian-backed Ukrainian political party. Mr. Giuliani’s financial connection to the organization, the organization’s close ties with the Russian government, and Mr. Giuliani’s ongoing public advocacy against Special Counsel Robert Mueller’s investigation of Russian interference in the 2016 election raises further questions that warrant review.
Most recently, it has come to light that Mr. Giuliani was paid for sending a letter in August of 2018 to the President of Romania criticizing that nation’s anti-corruption program on behalf of a global firm that reportedly has a wealthy Romanian citizen as a client. Mr. Giuliani’s letter advocates for a position that is in contradiction of the U.S. State Department’s position on the matter. This activity raises both the question of whether Mr. Giuliani may have attempted to influence U.S. policy and what the U.S. government’s true position is, given his role as the President’s personal attorney and public spokesman.
The purpose of FARA is to ensure the American public can make informed judgments about the political activities of foreign agents in the U.S. We appreciate the recent efforts by the Department to ensure better compliance with FARA, and as is the long-standing practice of the Department of Justice, this law should be applied without regard to political association, activities, or beliefs.
Given Mr. Giuliani’s ongoing relationships with foreign governments as well as his concurrent representation of the President, we hope you will agree this situation merits immediate review.