WASHINGTON - Rudy Giuliani continues to work on behalf of foreign clients both personally and through his namesake security firm while serving as President Donald Trump's personal attorney - an arrangement experts say raises conflict of interest concerns and could run afoul of federal ethics laws.
Giuliani said in recent interviews with The Washington Post that he is working with clients in Brazil and Colombia, among other countries, as well as delivering paid speeches for a controversial Iranian dissident group. He has never registered with the Justice Department on behalf of his overseas clients, asserting it is not necessary because he does not directly lobby the U.S. government and is not charging Trump for his services.
His decision to continue representing foreign entities also departs from standard practice for presidential attorneys, who in the past have generally sought to sever any ties that could create conflicts with their client in the White House.
"I've never lobbied him on anything," Giuliani said, referring to Trump. "I don't represent foreign government in front of the U.S. government. I've never registered to lobby."
Carrie Menkel-Meadow, a legal ethics professor at University of California-Irvine, said it is generally unwise for the president's lawyer to have foreign business clients because of the high likelihood they will have competing interests.
"I think Rudy believes because he is doing the job pro bono the rules do not apply to him, but they do," Menkel-Meadow said.
Since Trump hired him in April, Giuliani has repeatedly crossed the lines traditionally followed by presidential lawyers. He has regularly opined on Iran, North Korea and other policy issues outside his purview, while also publicly revealing details about his discussions with his client and with the office of special counsel Robert Mueller, which is investigating whether the Trump campaign assisted Russia in interfering with the 2016 election.
Among the clients represented by Giuliani's consulting firm is the city of Kharkiv, Ukraine, whose mayor was a leading figure in Party of Regions, the Russia-friendly political party at the center of the federal conspiracy prosecution of former Trump campaign chairman Paul Manafort. His firm worked for the mayor in 2018 and is expected to work for him again later this year, Giuliani said in an interview.
Kharkiv has contracted with a subsidiary of Giuliani's consulting firm, Giuliani Partners, to help set up a new office of emergency management there, according to Giuliani and others involved in arranging the deal. Giuliani traveled to Ukraine last November to meet with Kharkiv officials and then hosted a delegation from the city in New York in March, about three weeks before he was hired as Trump's attorney, according to officials and Ukrainian news reports.
Another current Giuliani client is the Mujahideen-e-Khalq, or MEK, an Iranian resistance group operating in exile that was listed as a terrorist group by the State Department as recently as 2012. Giuliani said he has regularly received payments from MEK over the past 10 years; he declined to disclose his fees.
Giuliani acknowledges giving a paid speech to the group in May in Washington, and he delivered another speech at an MEK gathering outside Paris on Saturday advocating regime change in Tehran. He said before the conference he planned to spend "three or four days" in Paris helping the group.
His consulting firm has also been hired by cities in Brazil and Colombia looking for new policing strategies and for ways to reduce crime, Giuliani said. He recently returned from a trip to Brazil to meet with clients before leaving for the MEK conference.
Lobbying experts said some of Giuliani's work for overseas clients is likely to require registration under the Foreign Agent Registration Act (FARA), which mandates disclosure to the Justice Department of attempts "to influence U.S. public opinion, policy, and laws" on behalf of foreign entities or individuals. Although violations are punishable by up to five years in prison and a $10,000 fine, the Justice Department has prosecuted only a handful of cases in recent decades.
Joshua Ian Rosenstein, a partner at the Sandler Reiff law firm, which specializes in FARA and other lobbying registration questions, pointed to Giuliani's MEK speech in Washington in May as an example of political activity requiring registration.
"Political activity is a broad term," Rosenstein said. "It includes any actions - including speeches, PR work and media outreach - that are intended to or anticipated to influence the U.S. government or the U.S. public with regard to the formulation, adoption, or modification of the policies of the U.S., or with regard to the political or public interests, policies, or relations of a foreign political party."
Two White House spokespeople declined to comment on Giuliani or whether his work for foreign entities posed any conflict of interests for the president.
But Giuliani's talkative and freewheeling style has irritated many White House officials, who say his frequent pronouncements are unhelpful and have often put the president in difficult positions. Giuliani often gives Trump personnel advice, White House aides said, and he said in a recent Post interview it would be good for Trump to have a more "political" chief of staff than John F. Kelly ahead of the 2018 midterms.
"He seems to be blending the services of a lawyer with the services of policy in the White House," said William Jeffress Jr., a lawyer who represented Dick Cheney's chief of staff Lewis "Scooter" Libby. "If you begin to stray to seek to influence the president or the White House that could be a problem. If you are seeking to influence the government in representing a foreign power, then you have a duty to register."
Giuliani has also lobbied the president to promote his son, Andrew, a low-level White House aide who has clashed with Kelly and others in the West Wing. The elder Giuliani said that before becoming Trump's attorney, he asked about a promotion he believed Trump had promised his son, and the president responded in the affirmative. He said he has not talked to the president about the issue since becoming his lawyer.
But three White House officials, who spoke on the condition of anonymity to discuss internal deliberations, said Giuliani continued to lobby Trump for his son's promotion after he became the president's lawyer.
Andrew Giuliani, who works in the White House Public Liaison Office, often arranges sports team visits to the White House and has been a regular Trump golfing partner for years. He suggested in an interview with The Post that some at the White House have bristled at his efforts to root out leaks.
"I've been lucky enough to know the president for close to 30 years and known him well for 20 years," Andrew Giuliani said. "I find him to be similar to an uncle, and I'm lucky enough to be very close to his family."
Trump remains pleased with Giuliani, lunching with him in New Jersey this weekend ahead of his Supreme Court nomination, praising his attacks on the special counsel and telling others that his situation has improved because of the former mayor, White House officials said.
After leaving the New York mayor's office following the 9/11 attacks in 2001, Rudy Giuliani built a lucrative career soliciting well-heeled clients for Giuliani Partners. He also worked with two law firms while accepting speaking fees on his own. He has since severed ties with the law firms but retains his security firm while representing Trump.
Giuliani said he is not as involved at the consulting company as he was before taking over as the president's lawyer. The firm did not respond to a request for comment.
Giuliani said he never brings up his other clients with the president. He also said he has turned down some potential clients who have approached him recently, including a Russian business; he declined to identify the company.
"I really don't think he does," Giuliani said, when asked if the president knew who his clients were. "He knows I do a lot of security work all over the world."
White House officials say they cannot be sure if Giuliani's claim about not discussing clients with the president is true or not. The two men often talk late at night and early in the morning, and the conversations are frequently wide-ranging.
Giuliani also defended his work with Kharkiv Mayor Gennady "Gepa" Kernes, who was close to deposed Ukrainian president Viktor Yanukovych before he fled to Russia and who has since sought to align himself with the new government in Kiev. Kernes uses a wheelchair after nearly being killed by an unidentified gunman in 2014. His allies have blamed Russian President Vladimir Putin for the attack, an allegation the Russian government has denied.
"I wasn't concerned about them because he just got his legs blown off by Putin," Giuliani said, referring to alleged links between Moscow and Kernes. "Maybe those ties were before."
Representatives for TriGlobal Strategic Ventures, a New York consulting firm involved in arranging the meetings between Kharkiv officials and Giuliani, did not respond to requests for comment.
On Giuliani's MEK relationship, a spokesman for the group, Shahin Gobadi, did not respond to a question about payments to Giuliani for speeches but said his appearances were not the same as working for the group.
"Mayor Giuliani's advocacy for the human rights and democracy in Iran has been consistent with his long-held views," Gobadi wrote in an email to The Post. "He has never worked for the MEK in any shape or form. He has never done any lobbying on behalf of the MEK."
He added later, "Of course, he has relation with the MEK and has publicly said to have worked with them in line with his views but he has not worked for them."
MEK was formally listed as a terrorist group by the State Department until the Obama administration dropped the designation in 2012 amid a sustained lobbying campaign. Members of the group have been implicated in the deaths of Americans and thousands of Iranians, primarily in the 1980s when the neo-Marxist group was allied with Iraqi dictator Saddam Hussein in the war between Baghdad and Tehran.
MEK supporters, including many U.S. conservatives, say the group has changed since then and is a valuable bulwark against the theocratic Iranian regime.
Daniel Benjamin, a State Department counterterrorism coordinator during the Obama administration, criticized Giuliani's advocacy for the MEK and suggested he and others may have violated the law. Benjamin said the Treasury Department was so concerned about an MEK lobbying and public relations program featuring Giuliani and other notables in 2012 that it opened a preliminary inquiry into the issue.
"Plenty of us working in counterterrorism found just the appearance of support for a listed organization that had American blood on its hands to be outrageous," said Benjamin, now a scholar at Dartmouth College. "An unfortunate consequence of the decision to delist was that this investigation got shelved."
MEK officials deny any inappropriate lobbying and said the Treasury review cited no violations by the group. They also say allegations of terrorism and of responsibility for the death of Americans are unfounded and distributed as part of a propaganda campaign on behalf of the Iranian government.
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The Washington Post's Carol D. Leonnig in Washington contributed to this report.