Former Republican presidential nominee Robert J. Dole has registered to work as a foreign agent to help Taiwan improve its relations with Congress and the administration, prompting complaints from Democratic critics who say the arrangement violates the terms of Dole's loan agreement with House Speaker Newt Gingrich (R-Ga.) not to lobby.

Dole and his law firm, Verner, Liipfert, Bernhard, McPherson and Hand, signed up last week to represent the Taipei Economic and Cultural Representative Office in the United States, Taiwan's unofficial embassy here. The deal, first reported by Legal Times, will bring the firm a monthly retainer of $30,000.

The filing marks the first time that the former Senate majority leader has registered as a foreign agent. In securing approval from the House ethics committee to borrow $150,000 from Dole to help pay off his $300,000 ethics penalty, Gingrich said he would replace the Dole arrangement with a bank loan if Dole ever became a registered lobbyist.

Dole's law firm said yesterday that his work for Taiwan would not jeopardize the loan arrangement because Dole would not actually lobby on Taiwan's behalf. Rather, said Verner Liipfert partner John Merrigan, Dole would provide "strategic advice and counseling."

He said Dole's planned work for Taiwan triggered a requirement that he register under the Foreign Agents Registration Act (FARA), which covers people who advise foreign governments on political strategies even if they don't directly contact lawmakers or the administration. In contrast, the Lobby Disclosure Act, the law governing other lobbyists, is triggered only when the lobbyist has two or more contacts with congressional or executive branch officials.

"We reached the conclusion that since he won't lobby and since {the ethics committee's} concern is that lobbyists won't be allowed to make loans and affect the judgments of those they lend money to, it's okay," Merrigan said.

Reps. James V. Hansen (R-Utah) and Howard L. Berman (D-Calif.), the chairman and ranking member of the House ethics committee, appeared sympathetic to that interpretation. "Registration under the Foreign Agents Registration Act in and of itself does not indicate whether lobbying of Congress will be undertaken," they said in a statement. "The committee is in the process of ascertaining whether such activities are intended."

Dole's law firm yesterday filed an amended statement making clear he would not engage in "any lobbying."

But Democratic Whip David E. Bonior (Mich.) said "this situation poses serious questions about the speaker's compliance" with the restrictions placed on the loan by the ethics panel and called on the committee to investigate.

Taiwan, which already has a large stable of lobbyists here, decided to hire Dole and the firm after a Dole trip there in May.

Merrigan said Dole "has been very reluctant" to register as a foreign agent but finally decided to do so because he had been a supporter of Taiwan throughout his legislative career.

Gingrich spokeswoman Christina Martin said Gingrich "will do whatever the ethics committee instructs him to do as relates to the loan" if it has any concerns about Dole's work for Taiwan. Gingrich already has repaid $50,000 and the arrangement provides that he cannot tap into the Dole loan until next January.

Ellen Weintraub, a former lawyer with the House committee, said that "a registered foreign agent is essentially a lobbyist for a foreign government. . . . I don't know why it would make a difference to the ethics committee whether his clients are foreign or domestic."

Whether or not Dole actually calls Gingrich or other members on Taiwan's behalf, she said, "there is an appearance issue when you have one very powerful man who is literally indebted to another man and he knows that man has a legislative ax to grind."

Before leaving the Senate, Dole pushed through an amendment that imposed a lifetime ban on the U.S. trade representative or deputy trade representative from advising foreign governments.

"The real problem here is one of appearance -- the appearance of a revolving door," Dole said at the time. "This appearance problem becomes all the more acute when former high government officials work on behalf of foreign interests."