Ex-prosecutor says Giuliani could go down for illegal foreign lobbying — even if he wasn't paid

On CNN Wednesday, former federal prosecutor Elie Honig broke down the legal problems facing President Donald Trump's lawyer Rudy Giuliani, in light of new reports that Giuliani sought contracts to do work for the Ukrainian government.

"Elie, does this put Rudy Giuliani in any further or more legal jeopardy?" asked anchor John Berman. "What are the legal implications for all this new information?"

"It could, John," said Honig. "The problems for Rudy Giuliani just keep stacking up. Let's rewind. Parnas is indicted. Rudy Giuliani himself is being investigated by the Southern District, which he used to lead. We know that that whopper subpoena got served the other day relating to Rudy's business, listing all the crimes."

"The potential crime I see here is ... [the] Foreign Agents Registration Act. What that says is if you are representing, lobbying for a foreign interest, foreign national, you have to register with the U.S. government so that government officials up to and including the president will know who they are talking to and who they are aligned with," continued Honig. "The fact that he didn't get paid is helpful to Rudy because if he had, there's no question he's lobbying. But you don't need to have a payment. You can still be lobbying for free, for other consideration, for in exchange of favors as could have happened here as well. So it's just one more iron in the fire for Rudy."

"Yeah, he tried to get the U.S. ambassador to Ukraine fired," said Berman. "He ultimately succeeded in that. Who was he doing that for? That could be a key question."

"Exactly," agreed Honig. "Remember, Ambassador Yovanovitch picked a fight with Lusenko on anti-corruption initiatives."

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