11mm! Sinus Earnatr WASHINGTON. DC 20510 September 25, 2019 Brandon L. Van Graek Director, PARA Registration Unit National Security Division US. Department of Justice 175 Street, NE, Constitution Square Washington, DC 20002 Dear Mr. Van Grack: We write to renew our request that the Department of Justice review whether President Trump?s personal attorney, Rudolph Giuliani, is in compliance with the Foreign Agents Registration Act (PARA). In a September 6, 2013 letter, we requested that given Mr. Giuliani?s political and public relations activities on behalf of foreign governments and interests the Department review whether he had an obligation to register any undisclosed political activities, had any delinquent ?lings, or had any de?ciencies or abnormalities in his registration statements. Since this request, we have received no formal response from the Department. In the meantime Mr. Giuliani has continued to engage in activities on behalf of foreign governments and interests while at the same time continuing to communicate with seniOr US. government officials and foreign leaders in his capacity as the President?s personal attorney. For example, public reports have established that: I. Mr. Giuliani headlined a pro-Russian conference in Armenia in October 2018 at the invitation ofa wealthy Russian Armenian, Ara Abramyan, where he shared billing at the event with Sergey Glazyev, an adviser to President Putin who has been sanctioned for his role in the illegal Russian occupation of Crimea.I 2. He met with the King of Bahrain in December of 2018 to discuss ?topics of joint interests? and subsequently signed a security consulting contract. The state media of Bahrain called Mr. Giuliani?s visit a ?high-level US. delegation.?2 'Josh Kovensky, Trump Lawyer Rudy Giuliani Headlines Pro-Russian Conference in Armenia, WASH. POST, Oct. 23, 2018, ference~in~ armenia. King receives high-level US delegation, BAHRAIN NEWS AGENCY, DEC. 1 I, 2013, Kingreceiveshi I 91:23 Dky?i?w?v'Q D. 3. He traveled to Albania in July 2019 to speak to the Mujahedin?e Khalq (MEK), a group formerly designated as a terrorist group by the U.S. government, where he spoke about the potential for regime change in Iran.3 4. At another MEK Sponsored appearance in Warsaw in February 2019, he reportedly ?reveled in condemning Iran even as he insisted he was in no way speaking for the TI?ttl?Ilp administration. He said the MEK. had been his client for 12 years, and that he had often spoken on its behalf, often for a fee.? He was also quoted, saying want to see a regime change in Iran.?4 These are just a handful of new and continued activities by Mr. Giuliani which appear to be paid by foreign entities and government with a desire to influence U.S. poiicy. Notably, recent reports regarding Mr. Giuliani?s e?brts to pressure the government of Ukraine to investigate former Vice President Joe Biden?s son to benefit the President?s reelection also raise serious additional questions about the legality of his work as a foreign agent while also representing and working on behalf the President regarding official US. policy;5 Like any other American, Mr. Giuliani has legal obligations to report his work on behalf of foreign clients, and the Department of Justice should not give him preferential treatment or exempt him from his obligation just because he is the President?s personai attorney. Accordingly, his work as a foreign agent requires thorough review by your of?ce to ensure his compliance with the PARA requirements. i?nafi-r Catr'sfor Iran Regime Change at Raf?e Linked to Extreme Grow), THE GUARDIAN, Jun. 2013, 4David E. Sanger and Marc Santora, Anti-Iran Message Seeps into Trump Forum Billed as Focusing on Mideast Security, NY TIMES, Feb. 13,2019, pompeohtml. - 5Greg Miller et Student Pans-Heal Shatter-r Ukraine Agenda as Key Foreign Pottcy O?icr?nts Were Stdetmed, WASH. POST, Sep. 24, 20l9, agenda?as-key-forei gn-policy- of?cials?wereusideiined?? 9f09t2 dice Eaaec-d ecc- 1 c9?be96? GadbS1321c90_sto1y.html. Sincerely, Um Wimg/ Tom Udall United States Senator United States Senator I. Shadon Whitehouse liza th Warren United States Senator Unite States Senator by. Tammy ckworth Richard J. Durbin United ates Senator United States Senator 4AA. 1% Jeffrey A. Merkley United States Senator Enclosure cc: The Honorable John C. Demers Assistant Attorney General