Is Rudy Giuliani violating the law by failing to register as a foreign agent?

Giuliani’s overseas work has long drawn scrutiny. ProPublica reported last October on his increasing foreign trips while serving as the president’s lawyer.

“He has often traveled to Russia or other former Soviet states as guests of powerful players there,” it explained. “And since Trump was elected, he appears to have stepped up the frequency of those trips.”

It added: “There are many things we don’t know about Giuliani’s trips. We don’t know whether he’s being paid, and if so by whom. Giuliani declined to answer our questions.”

At one point, ProPublica reported:

Giuliani appeared in the former Soviet republic of Armenia, which has close trade ties with Russia. He was invited, according to local press accounts, by Ara Abramyan, an Armenian businessman who lives in Russia. Abramyan once helped reconstruct the Kremlin and also received a medal for “merit to the fatherland” from President Vladimir Putin of Russia. Giuliani said he was in Armenia as a private citizen, but on a local TV news show, Abramyan implied that he expected Giuliani to carry a message for him to Trump. (The conversation was in Armenian, so it’s not clear whether Giuliani understood what Abramyan was saying.)

And recently, The Daily Beast reported that Giuliani’s firm, Giuliani Security and Safety, is now working for the authoritarian government of Bahrain, ostensibly to train police. The New York Times reported that Giuliani had worked as a lobbyist in 2017 for Ukrainian-Russian developer Pavel Fuks:

Mr. Giuliani described that work as related to emergency management consulting, but Mr. Fuks said in an interview that he hired Mr. Giuliani as “a lobbyist for Kharkiv and Ukraine” to lure American investors. “This is stated in the contract.”

All of which raises the question, from senators and on Tuesday by ThinkProgress: Is Giuliani violating the law by failing to register as a foreign agent?

Enforcement of violations of the Foreign Agents Registration Act has been stepped up in the aftermath of Special Counsel Robert Mueller’s investigation, which leveraged investigations of these crimes in its pursuit of links between the Trump campaign and Russia. Most famously, Trump’s former campaign manager Paul Manafort was charged with violating the act for his work for a pro-Russia politician in Ukraine. Democratic senators have asked the Justice Department to look into Giuliani’s foreign work to ensure that it complies with the act — a particularly important request given his proximity to the president — but ThinkProgress reported that though the DOJ received the request, it hasn’t responded.

The issue was thrust into the spotlight last week when Giuliani announced he would be going to Ukraine to advocate on behalf of investigating Joe Biden, a top contender for the 2020 Democratic presidential nomination. He canceled the trip after a public outcry.

But it’s hard to have faith that the Justice Department will do the right thing and hold Giuliani to account for any potential violations. Each day, more evidence emerges that Trump is turning it into a political weapon, rather than a neutral arbiter of the law.