NEW: Rudy Giuliani has been pushing foreign interests nonstop for the past few years—so why the hell hasn't he registered with FARA? Here's our dive: newrepublic.com/article/155387…
This quote, from one of the FARA experts with whom I spoke, points to things to come:

"I fully expect that, once their investigation is concluded, you’ll see an indictment of Giuliani for FARA violations, too.”
Giuliani has consistently claimed that he's exempt from FARA registration, since he's a lawyer.

Which would be true... if he stayed in the courtroom with his clients, and wasn't constantly bouncing between green rooms and the Oval Office to lobby for those clients.
"I think you could take any law student in America, and have them quickly read through that [FARA] statute, and evaluate Giuliani’s behavior. And I would be very surprised if that law student wasn’t very concerned that Giuliani was not violating this law.” newrepublic.com/article/155387…
One other add: Giuliani's FARA-related issues in Ukraine are by no means limited to Fruman and Parnas (and potentially Firtash).

The guy who was bankrolling Giuliani's work in Kharkiv was *pretty* explicit that Giuliani had been hired as a(n unregistered) lobbyist.
There's one long-shot FARA exemption Giuliani could try for: the national security exemption, which would require the consent of Trump, Pompeo, and Barr.

We haven't seen it used in decades.... but that may not mean much with this crowd. newrepublic.com/article/155387…
This read, which just dropped, is a good microcosm of Giuliani not appearing to understand how FARA works: washingtonpost.com/politics/giuli…
Giuliani's blatant lack of FARA registration echoes the man who jump-started FARA in the first place: Ivy Lee, whose lobbying for the Nazis in the 1930s was so obvious Congress decided foreign lobbyists needed to register.
‘McCallion says FBI counterintelligence agents in February or March asked questions about some of Giuliani's Ukrainian business dealings.’ cnn.com/2019/10/16/pol…
‘Yes, Rudy Giuliani is, by all appearances, in blatant violation of FARA... But there’s a larger question about whether those same financial ties expose Rudy for much uglier conspiracy charges.’ emptywheel.net/2019/10/16/on-…
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