More information about Rudolph W. Giuliani’s alleged role in the influence efforts underlying the impeachment probe against his client, President Trump, is revealed seemingly by the minute. For every detail we learn, even more questions arise. And with each new glimpse into the increasingly dominant role Giuliani played in U.S. foreign policy in Ukraine since 2018, the American public can’t help but wonder: Who was Giuliani really working for?

We have known since Giuliani began working for Trump that he had foreign clients and that he wasn’t severing ties with them to prevent conflicts of interest. Now Giuliani has confirmed that he was paid $500,000 in 2018 by a business called Fraud Guarantee — founded by Lev Parnas and set up by David Correia, both of whom were recently indicted on charges related to alleged violations of federal campaign finance laws. Giuliani claims that the payments were for “substantial business advice.” (Correia and another defendant pleaded not guilty last week, and Parnas is due to appear in court on Wednesday.)

The more we learn about Giuliani’s relationship to all his clients, the harder it is to tell whose interests Giuliani was representing in his influence efforts — especially since federal indictments state that at the same time Fraud Guarantee paid him $500,000 for services, it was representing the interests of an unidentified official of the Ukrainian government and at least one other foreign national.

So the revelation of the payment confirms that Giuliani was paid by his associates in the Ukraine scheme, but it doesn’t tell us much. There are plenty of reasons to question the true provenance of the funds used to pay him.

Fraud Guarantee was reportedly dissolved by Florida officials years before the Giuliani payment. The indictment says the two Giuliani associates have depended on foreign money for some of their business ventures in the past. For example, as they attempted to get a recreational marijuana business off the ground in 2018, they allegedly relied on funds from a foreign national to make illegal donations to candidates who could help them procure the necessary licenses.

Other reporting has documented that Igor Fruman, another Giuliani associate indicted this month, and Parnas have deep financial and business ties to foreign actors, including indicted Ukrainian oligarch Dmitry Firtash, who is fighting extradition to the United States.

Giuliani has insisted that he “knows exactly where the money came from,” but the American public doesn’t. Despite claiming to represent the president on official matters, he has refused to file a State Department financial disclosure report. The source of Giuliani’s paycheck is important, because the money he was receiving from his paying clients, including Parnas and Fruman, effectively subsidized his gratis work for Trump.

In some instances, the interests of Giuliani, Parnas, Fruman and Trump intersect. But without more information — like the sources of income that must be provided on a federal employee’s financial disclosure report — we don’t know what other interests might be at play.

At a minimum, though, it seems like he wasn’t representing the U.S. public’s interest. Giuliani is now reported to be under federal investigation for possible violations of the Foreign Agents Registration Act, or FARA. Under FARA, any person who tries to influence the U.S. government or the public on behalf of a foreign national must register with the Department of Justice and describe their activities. Giuliani has made no such disclosures, despite reportedly advocating for the firing of a U.S. ambassador, advancing Ukrainian investigations and pushing for the extradition of a Turkish cleric, a top priority of Turkish President Recep Tayyip Erdogan. If he was engaging in any of these activities on behalf of a foreign client, he violated the law by not registering under FARA.

Foreign actors certainly want influence in the U.S. government, and unvetted advisers provide an easy avenue. We know that Giuliani’s associates were able to buy access to government officials with their political contributions, which were allegedly illegally laundered. But without knowing the true origin of the Fraud Guarantee payment and Giuliani’s other streams of income, we are totally in the dark about what foreign actors might be influencing Giuliani’s work.

None of the information that is emerging through the press and law enforcement actions is a substitute for the transparency provided by financial disclosure and other ethics laws that attach to actual, federally employed public servants, or the FARA filings that show us what foreign interests are influencing U.S. policy.

This is why financial disclosure is so important and why the public deserves more information about who was paying Giuliani and for what services. The complicated tapestry of financial connections between Giuliani, Trump and others working on behalf of foreign interests has real consequences for national security and the stability of our democracy. The uncertainty surrounding Giuliani’s role in the administration has enabled him to evade the public accountability provided by ethics laws. As a result, the public has no idea whose interests Giuliani is representing while influencing decisions that affect all of us.

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