For @just_security, I wrote a deep dive into the evidence Giuliani was indeed a foreign agent who – on behalf of Ukrainian nationals – lobbied Trump and other officials to fire Yovanovitch.

But instead of registering under FARA, he tried to disguise his status as foreign agent. https://twitter.com/just_security/status/1392104245873319939

Giuliani has indicated his defense will be that, in seeking the ambassador's removal, he was acting only on Trump's behalf, and not for any Ukrainians: "My sole concentration... was to find evidence that proved [Trump] was innocent of Russian collusion." https://twitter.com/RudyGiuliani/status/1387941106025963521

But the evidence shows Giuliani was acting on behalf of both Ukrainian nationals *and* Trump. He saw that both sides wanted something, and that both sides were in a position to help the other.

And his FARA trouble results from his role in arranging a quid pro quo between them.

Prosecutor General Lutsenko & co. wanted Ambassador Yovanovitch removed from Ukraine, because her anti-corruption efforts were interfering with their corruption.

President Trump wanted a scandal for Biden in Ukraine, to harm his chances in the primary and general elections.

Lutsenko's terms were clear: if Trump gets rid of Yovanovitch, then we'll start a criminal investigation into Biden and assist Trump's campaign by creating a narrative that the only *real* collusion was with Biden & Ukraine – Russia had nothing to do with it.

It was Lutsenko's interests Giuliani was representing when he spent five months meeting with Trump, Pompeo, and other US officials to advocate for Yovanovitch's firing. Ukrainian nationals financed and directed the effort, and Giuliani was lobbying to get them what they wanted.

That Giuliani was carrying out a quid pro quo that would *also* benefit Trump doesn't negate that he was simultaneously lobbying on the Ukrainian nationals' behalf.

And Giuliani wasn't just a loyal pro bono lawyer willing to go to any lengths to help his non-paying client.

It was Parnas and Fruman who introduced Giuliani to Lutsenko, and they gave Giuliani $500,000 to do unspecified "consulting work" for their company, Fraud Guarantee. (Unsurprisingly, the SEC recently filed suit alleging the $500K paid to Giuliani had been obtained through fraud.)

After Giuliani was introduced to Lutsenko, he gave him a signed retainer agreement where, for $500K, Giuliani would represent Lutsenko's interests before US officials – i.e., lobby on Lutsenko's behalf.

But then Giuliani realized that was a bad idea, and took the retainer back.

So then Giuliani called in his friends Victoria Toensing & Joe diGenova, and arrangements were made for Lutsenko to hire their lobbying services – and, in turn, Toensing and diGenova would subcontract out some of the work to Giuliani (who would of course get a cut of the money).

As for what agreements were eventually signed, which Ukrainians the money was coming from, and whose pockets it ultimately ended up in – well, there's a lot there we don't know yet.

Maybe the recent search warrants for Rudy & Toensing's electronic devices can help answer that.

But while Giuliani's personal financial stake in the deal is an interesting fact question, his liability under FARA doesn't depend on it.

Giuliani was an agent of Ukrainian principals when he lobbied Trump to fire the ambassador–and he was (eventually) successful in his efforts.

The ambassador was fired. Trump's obligation under the quid pro quo was met; it was Lutsenko's turn to reciprocate.

But Giuliani took so long to get it done that, by the time he finally had, the political ground had shifted under everyone's feet.

Ukraine had a new president.

On April 24, 2019, Yovanovitch was told to fly back to DC from Kyiv.

But 3 days earlier, on April 21, Zelenskyy was elected. He replaced President Poroshenko – who Giuliani's associates had met with in February, to discussed with him a quid pro quo for a Biden investigation.

With Poroshenko out, the prior quid pro quo was out as well.

Lutsenko needed to keep his job under the new administration. Which meant that, even though Trump made good on firing Yovanovitch, Lutsenko was not able to move ahead with announcing the Biden investigation as planned.

One can only imagine how enraged Trump must've been. Trump never wants to go first in a deal – he wants contractors to do the work first, and then he may or may not decide to pay them after.

Only this time, he did go first. And he was given nothing from the Ukrainians in return.

In this post, I wrote about what happened next. After Yovanovitch was fired, but Ukraine still did not announce a Biden investigation, the quid pro quo transformed into something much more malicious. It was no longer a favor for a favor; it was extortion. https://viewfromll2.com/2020/01/29/lev-parnas-and-the-very-harsh-message-a-look-at-the-evidence-that-corroborates-the-may-12-meeting/

On May 12 – 6 days after Yovanovitch's firing became public – Giuliani sent Parnas and Fruman to deliver "a very harsh message" to incoming Pres. Zelenskyy: announce a criminal investigation into Biden within the next 24 hours, or else Pence won't be at Zelenskyy's inauguration.

This became a demand for a Biden investigation, or else Ukraine would be cut off from military aid. The rest is history.

But before all that, the quid pro quo had been a much friendlier arrangement. One in which Giuliani agreed to be an unregistered agent of Ukrainian nationals.