Text of the PDF in Q drop 3590
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FARA requires individuals to register with the Justice Department if they act, even
through an intermediary, “as an agent, representative, employee, or servant” or “in any other capacity” at the behest of a foreign principal, including a foreign political party, for purposes of
engagement with a United States official.8
The registration applies to anyone who attempts to influence a U.S. government official on behalf of a foreign principal in an effort to “formulat[e], adopt[], or chang[e] the domestic or foreign policies of the United States.”9 As such, the focus of FARA is to require registration for individuals engaged in political or quasi-political activity on behalf of a foreign government. Likewise, an individual whose activities are subject to registration under FARA and who sends informational material “for or in the interest of [a] foreign principal” with the intent or belief that such material will be circulated among at least two persons must transmit the material to the Attorney General no later than 48 hours after actual transmission.10 Notably, an ongoing failure to register is an ongoing offense.11

According to documents provided to the Committee, the Justice Department required the Podesta Group and Mercury LLC to register under FARA for working on behalf of the Ukrainian government.12 Their registration was required even though the client, the European Centre for the Modern Ukraine (ECFMU), wrote a letter saying it was not directly or indirectly controlled by the Ukrainian government. That did not matter to the Justice Department because their lobbying activity was not to “benefit commercial interests” of the ECFMU but instead to promote the “political or public interests of a foreign government or foreign political party.” The Justice Department made clear that an individual acting in the political or public interests of a foreign government must register under FARA. As such, because Podesta and Mercury were effectively working on behalf of Ukrainian government interests, they were required to register.

Unlike that situation where the Podesta Group and Mercury LLC worked for the
middleman (EFCMU) and not the Ukrainian government, here Chalupa reportedly worked
directly with Ukrainian government officials to benefit Ukraine, lobbying Congress on behalf of Ukraine, and worked to undermine the Trump campaign on behalf of Ukraine and the Clinton campaign. Accordingly, these facts appear to be exactly the type of activity Congress intended to reach with FARA. Please answer the following:

1. What actions has the Justice Department taken to enforce FARA’s requirements
regarding Chalupa given the public reporting of her actions on behalf of the Ukrainian government?