Recent interviews with Trump attorney and former New York City Mayor Rudy Giuliani have revealed that Giuliani has continued to work with foreign clients through his consulting firm, Giuliani Partners, while serving as President Trump’s attorney. Untraditional for the position, Giuliani’s dealings have blurred the lines of government service, and have called into question whether his dealings with foreign clients need to be registered under the Foreign Agents Registration Act (FARA), in order to protect government interests.

Sandler Reiff partner Josh Rosenstein believes that Giuliani’s actions, most specifically a paid speech given on behalf of Iranian Resistance group Mujahideen-e-Khalq, serves as an example of dealings needing registration under FARA, creating potential ethics violations for Giuliani.

“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.”

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