tunittd Stuns WASHINGTON, DC 20510 September 5, 2013 The Honorable John C. Demers Assistant Attorney General National Security Division Department of Justice 950 Avenue, NW Washington, DC 20530-0001 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 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 PARA, including whether he has an obligation to register any undisclosed political activities, has any delinquent ?lings, or has any de?ciencies or abnormalities in his registration statements. PARA generally requires individuals working to influence US. government of?cials or the public on behalf of a foreign entity to register that activity with the Department.2 The Act de?nes political activities that require registration as ?any activity that the person engaging in believes will in any way in?uence any agency or of?cial of the Government of the United States."3 However, PARA also covers any type of public relations directly or indirectly on behalfof a foreign principal, as well as any advising on the domestic or foreign policies of the United States.4 Mr. Giulianiis numerous foreign clients and ongoing communications with senior US. government of?cials raise signi?cant 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}1 Press releases on Mr. Giuliani?s security company?s website deseribe additional work on behalf of the governments of Chile, Dominica, Uruguay, the Dominican Republic, and El Salvador."5 '22 U.S.USC. 6] 4 22 U.S.C. 61 1(g) and 5 Josh Dawsey et al., Giuliani Worksfor Foreign Clients White Serving as Trump '3 Attorney, WASH. POST, Jul. it), 2018, attorneyi'Zt} 8/07i09fe2 554ae-7938-l leE-SObe?6d32e I 0 See ag, Press Release, Giuliani Security ?it Safety, Luis Abinader Promises to Make Public Safety a Priority; Welcome?s Giuliani?s Planton ?le with author); Press Release, Giuliani Security Safety, Rudy Giuliani States that the Keys to Combating Crime: ?the Police Should Feel It Has Political Support,? (on ?le with author) {last accessed July 19, ZOIS). 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 PARA concerns. For example, Mr. Giuliani?s participation in the 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.8 Mr. Giuliani also regularly advocates for regime change in Iran, which is one of top objectives? Given Mr. Giuliani?s receipt of signi?cant payment from the MEK and simultaneous advocacy on behalf of that group and its objectives, his actions may require registration under PARA. 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.?J 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 ?nancial 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.'2 Mr. Giulianiis letter advocates for a position that is in contradiction of the US. State Department?s position on the 7 See Scott Shane, or Obscure iranian Exiie Group, Broad Supper! in US, NY TIMES, Nov. 26, Bill 1, ii I Elizabeth Rubin, Opinion, An iranian Coir and iis American Friends, NY TIMES, Nov. Aug. 2011, Eiizabeth Flock. iranian Terrorist Group ME-K. Pars Big in Make Hisioiy Go Airav, U.S. NEWS WORLD REPORT, Jul. 6, 20 I 2, littps usnewseomin ewsiaitic les?? IZiO?iitl?i iran tan-terrorist?group-me k-pays-big-to-makeuhistory-go- Daniel Benjamin, Giuliani Tonic Money From a Group that Americans. Does Tramp Care?, POLITICO Mao, Nov. 23, 2016, ligiuliani- mekuterrorist-grou p-moneyrbolton-iran-Z14479. 3 id. 9 [shaan Tharoor, is Regime Change in iron Parr of Trump Agenda?, WASH. POST, May 7, 21313, washingtonpostcomine wsiworldviewsiwpi?? ?3 Josh Dawsey et al., Worksfor Foreign Ciienis While Serving as Tramp 's Aiiorney, WASH. POST, Jul. 10, 2G I 8, attorneinOl 8i0?i09ie2l 1' Simon Sinister, How Pan! Manafori Heiperi Russia is Man in Ukraine, TIME, Oct. 31, 20 [2 Kit Giilet, Rudolph an Anticorrupiion Crackdown in Romania, NY TIMES, Aug. 29, 2013, bursa-5 I. matter. This activity raises both the question of whether Mr. Giuliani may have attempted to in?uence US. policy and what the US. 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 US. We appreciate the recent efforts by the Department to ensure better compliance with PARA, 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. Qua/(r Tom Udall Eliz eth Warren United States Senator Uni States Senator Sincerely, I Richard Blumenthal 1 United Stat 3 Senator United States Senator (24K 4% 4- heldon Whitehouse Jeffrey A. Merkley United States Senator United States Senator gm: ichard J. Durbin United States Senator